THIS IS AN ADMINISTRATIVE PENALTY COMPLAINT PURSUANT TO SECTION 3008(A)(1) OF RCRA, AS AMENDED, 42 U.S.C. SECTION 6928(A)(1). ON OCTOBER 21, 1999, EPA CONDUCTED A RCRA COMPLIANCE INSPECTION AT THE ANADITE FACILITY IN SOUTH GATE, CALIFORNIA. FOLLOWING THE INSPECTION, A REQUEST FOR INFOR- MATION PURSUANT TO 3007(A) OF RCRA WAS ISSUED TO ANADITE ON 06/13/2000. AS A RESULT OF INFORMATION SUBMITTED BY ANADITE, EPA ISSUED A NOTIFICATION OF POTENTIAL FILING OF DETERM- INATION OF VIOLATION AND COMPLIANCE ORDER TO ANADITE ON DECEMBER 19, 2000. EPA AND ANADITE INITIATED SETTLEMENT TALKS ON FEBRUARY 13, 2001. DISCUSSIONS WERE SUCCESSFULLY CONCLUDED, AND THE COMBINED COMPLAINT AND CA/FO WAS FILED ON 09/28//2001.