The complaint was filed under Section 109 of CERCLA and Section 325 of EPCRA and is based on ICI's violation of the notification requirements of Section 103 of CERCLA and Section 304 of EPCRA in regards to the release of propylene oxide on April 9, 2002, at its Uniqema, Atlas-Point Plant located in New Caste, Delaware. The region seeks a penalty of $17,188.00 for the CERCLA violation and $55,002.00 for the EPCRA violations. The total penalty sought is $72,190,00.