ON SEPTEMBER 30, 1999, EPA ISSUED TWO ADMINISTRATIVE COMPLAINTS AGAINST ROHM AND HAAS CORPORATION ALLEGING VIOLATIONS OF EPCRA SECDTION 304, 42 U.S.C. 11004 AND CERCLA SECTION 103, 42 U.S.C. 9603 AND ASSESSING PENALTIES UNDER EPCRA SECTION 325, 42 U.S.C. 11025 AND CERCLA SECTION 109, 42 U.S.C. 9609. THE CERCLA COMPLAINT ALLEGES THAT ROHM AND HAAS, ON TWO OCCASIONS, FAILED TO IMMEDIATELY REPORT THE RELEASE OF A HAZARDOUS SUBSTANCE, EQUAL TO OR ABOVE THE APPLICABLE REPORTABLE QUANTITY TO THE NATIONAL RESPONSE CENTER AS REQUIRED BY CERCLA SECTION 103. THE EPCRA COMPLAINT ALLEGES THAT ROHM AND HAAS: (1) ON TWO OCCASIONS, FAILED TO IMMEDIATELY REPORT THE RELEASE OF A HAZARDOUS SUBSTANCE, ABOVE THE APPLICABLE REPORTABLE QUANTITY, TO THE APPROPRIATE STATE EMERGENCY RESPONE COMMISSION (SERC) AS REQUIRED BY EPCRA SECTION 304(A) AND (B); (2) ON OCCASIONS FAILED TO IMMEDIATELY REPORT THE RELEASE OF A HAZARDOUS SUBSTANCE, ABOVE THE APPLICABLE REPORTABLE QUANTITY, TO THE APPROPRIATE LOCAL EMERGENCY PLANNING COMMISSION (LEPC) AS REQUIRED BY EPCRA SECTION 304(A) AND (B); (3) ON THREE OCCASIONS, FAILEDTO PROVIDE TIMELY WRITTEN FOLLOW-UP NOTIFICATION CONCERNING A REPORTABLE RELEASE TO THE APPROPRIATE SERC AS REQUIRED BY EPCRA SECTION 304(C); (4) ON THREE OCCASIONS, FAILED TO PROVIDE TIMELY WRITTEN FOLLOW-UP NOTIFICATION CONCERNING A REPORTABLE RELEASE TO THE APPROPRIAT