On June 24, 2003, EPA filed an administrative complaint against Goldschmidt Industrial Chemcial Corp. The complaint was filed under Section 325 of EPCRA and was based on the failure to timely complete and submit chemical inventory forms to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local fire department or calendar year 2001 for one extremely hazaroud substance that was stored at its McDonald, Pennsylvania facility. This is a violation of Section 312 of EPCRA. The total penalty sought is $30,93