ON JULY 3, 2012, REGION III FILED AN ADMINISTRATIVE CONSENT AGREEMENT AND FINAL ORDER WITH RALISMAN ENERGY USA, INC. ( TALISMAN ) TO BOTH INITIATE AND RESOLVE MULTIPLE VIOLATIONS OF SECTIONS 311 AND 312 OF EPCRA, 42 U.S.C. SECTION 11021 AND 11022, AT MULTIPLE FACILITIES IN THE COMMONWEALTH OF PENNSYLVANIA. THE CAFO ALLEGES THAT TALISMAN VIOLATED SECTIONS 311 AND/OR 312 OF EPCRA, 42 U.S.C. SECTION 11021 AND/OR 11022, APPROXIMTAELY SIXTY NATURAL GAS AND PROCESSING FACILITIES IN THE COMMONWELATH OF PENNSYLVANIA BY FAILING TO SUBMIT CERTAIN CHEMICAL INVENTORY RECORDSD TO THE STATE EMERGENCY RESPONSE COMMISSION, LOCAL EMERGENCY PLANNING COMMITTE, AND/OR LOCAL FIRE DEPARTMENT FOR THOSE FACILITIES. TALISMAN PREVIOUSLY SELF-DISCLOSED THE VIOLATIONS BUT FAILED TO MEET THE REQUIREMENTS OF THE SELF-DISCLOSURE POLICY BECAUSE EPA REGION II INVESTIGATED EPCRA SECTION 311/312 COMPLIANCE PRIOR TO TALISMAN'S DISCOVERY AND SELF-DISCLOSURE. EPA DETERMINED THAT THE DISCLOSURE OF THE VIOLATIONS HAD NOT BEEN MADE INDEPENDENTLY AND PRIOR TO WHEN EPA OR ANOTHER GOVERNMENT AGENCY LIKELY WOULD HAVE DISCLOVERED THE POTENTIAL VIOLATIONS. THEREFORE, TALISMAN WAS NOT ELIGIBLE FOR FULL PENALTY MITIGATION UNDER EPA'S SELF-DISCLOSURE POLICY. IN THE CAFO, RESPONDENT AGREES TO PAY A PENALTY TO RESOLVE THE VIOLATIONS.