THE AGENCY HAS FILED A COMPLAINT AGAINST ROYAL CROWN FOR VIOLATING SECTION 312 OF EPCR: FAILING TO REPORT THE PRESENCE OF ANHYDROUS AMMONIA TO THE STATE EMERGENCY RESPONSE COMMISSION AND LOCAL EMERGENCY PLANNING COMMISSION FOR THE 1994 AND 1995 CALENDAR YEARS. ON JULY 17,1996, U.S. EPA CONDUCTED AN EPCRA COMPLIANCE INSPECTIONS AT ROYAL CROWN BOTTLING COMPANY OF CHICAGO, CHICAGO, ILLINOIS. THE INSPECTOR CALCUATED THE AMOUNT OF ANHYDROUS AMMONIA IN THE REFRIGERATION SYSTEMS TO ABOUT 4,000 POUNDS. ANHYDROUS AMMONIA IS AN EXTREMELY HAZARDOUS SUBSTANCE WITH A THRESHOLD PLANNING QUANTITY AND MINIMUM THRESHOLD LEVEL OF 500 POUNDS. THE FACILITY VIOLATED EPCRA SECTION 312 BY NOT SUBMITTING THE EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM TO THE STATE EMERGENCY RESPONSE COMMISSION AND THE LOCAL EMERGENCY PLANNING COMMITTEE FOR THE CALENDAR YEARS OF 1994 AND 1995. ON JUNE 19, 1998, U.S. EPA FILED AN ADMINISTRATIVE COMPLAINT AGAINST THE RESPONDENT WITH ALLEGED VIOLATIONS OF EPCRA SECTION 312 WITH A PROPOSED PENALTY OF $78,692.44. ALTER- NATIVE DISPUTE RESOLUTION WAS USED DURING AUGUST 19, 1998 UNTIL SEPTEMBER 22, 1998 AS PART OF THE ADMINISTRATIVE LAW JUDGES PROJECT. ON FEBRUARY 23, 1999, U.S. APA FILED THE CONSENT AGREEMENT AND CONSENT ORDER TO RESOLVE THIS MATTER. THE RESPONDENT HAS AGREED TO PAY A CASH PENALTY OF