Section 103(a) of CERCLA, 42 U.S.C. 9603(a), requires any person in charge of a facility, as defined under CERCLA, to immediately notify the National Response Center (NRC), as soon as he or she has knowledge of any release (other than a federally permitted release) of a hazardous substance from the facility in a quantity equal to or greater than the reportable quantity. Respondent provided late notifications to the NRC and state emergency response commission (SERC), and written follow-up to the local emergency planning committee (LEPC).