On July 10, 2019, EPA Region III filed a signed Consent Agreement and Final Order ( CAFO ) resolving an action against JBS Souderton, Inc. ( JBS ) for an alleged violation of Section 103 of CERCLA, Sections 304 and 312 of EPCRA, and Section 112 of CAA in connection with a facility located in Souderton, Pennsylvania. EPA alleges that JBS failed to notify the National Response Center after a July 12, 2017 release of more than a reportable quantity of anhydrous ammonia. EPA also alleges that JBS violated Section 304(a) and (c) of EPCRA, 42 U.S.C. 11004(a), (c), by failing to notify the State Emergency Response Commission ( SERC ) after the July 12, 2017 and October 15, 2017 releases of more than a reportable quantity of anhydrous ammonia, or to send required written follow-up reports to the SERC. EPA also alleges that JBS violated 304(s) of EPCRA by failing to notify the Local Emergency Planning Committee ( LEPC ) after the July 12 release. EPA further alleges that JBS violated Section 312 of EPCRA, 42 U.S.C. 11022, by failing to submit to the SERC, the LEPC and the local fire department a Chemical Inventory Form for calendar year 2016, identifying sulfuric acid as present at the Facility in a quantity equal to or greater than the threshold planning quantity, as required by Section 312. Finally, EPA alleges that JBS violated Section 112(r) of the CAA, 42 U.S.C. 7412(r), by failing to design and maintain a safe facility taking steps as are necessary to prevent accidental rel