THIS IS A COMPLAINT AND CONSENT AGREEMENT/FINAL ORDER (CA/F O) SIMULTANEOUSLY COMMENCING AND CONCLUDING AN ACTION PURSUA NT TO SECTION 325 OF EPCRA, 42 U.S.C. a 11045, ISSUED TO CH EVRON U.S.A., INC. THE VIOLATION INVOLVES FAILURE TO IMMEDI ATELY NOTIFY THE SERC AND LEPC OF A RELEASE OF OVER 500 POUN DS (THE RQ) OF SULFUR DIOXIDE ON JUNE 2, 1999. A CITIZEN RE PORT TO THE LOCAL AGENCY PROMPTED AN INVESTIGATION BY THAT A GENCY. AT THAT TIME (THREE HOURS AFTER THE FACILITY HAD KNO WLEDGE OF THE RELEASE), THE AGENCIES WERE OFFICIALLY NOTIFIE D. A LARGE POPULATION OF NON-ENGLISH SPEAKING LAOTIAN RESID ENTS LIVES ADJACENT TO THE FACILITY. THE COMPLAINT SEEKS A PENALTY OF $20,000; THE CA/FO PRESENTS THE AGREEMENT OF THE RESPONDENT TO PAY THE PROPOSED PENALTY.