On June 25, 2003, EPA Region III issued an administrative complaint to C&S Wholesale Grocers, Inc. ( C&S ), seeking a total penalty of $30,251.00 for violations of Section 103 of CERCLA and Sections 304 and 311 of EPCRA. C&S failed to notify the NRC and the SERC immediately following a release of approximately 407 pounds of ammonia from its facility in Aberdeen, Maryland on July 5, 2000. Additionally, C&S failed to provide to the SERC an MSDS for ammonia, or a list identifying ammonia as present at its Aberdeen facility in a quantity greater than its minimum threshold for reporting. ORIGINAL PENALTY BREAKDOWN (19,938 (EPCRA) AND 10,313 (CERCLA