THE CONSENT AGREEMENT RESOLVES EPA'S CLAIM THAT RESPONDENT FAILED TO IMMEDIATELY REPORT A RELEASE OF HYDROCHLORIC ACID FROM ITS MANUFACTURING FACILITY IN JOHNSTOWN, PA. THIS VIOLATED SECTION 103 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT, ( CERCLA ), 42 U.S.C. SECTION 9603 AND SECTION 304 OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT ( EPCRA ), 42 U.S.C. SECTION 1004. RESPONDENT WILL PAY A PENALTY.