THIS IS AN ADMINISTRATIVE COMPLAINT FOR PENALTIES UNDER CERCLA SEC. 109(A) AND EPCRA SEC. 325. ON DECEMBER 26, 1992, THERE WAS A RELEASE OF 200 POUNDS OF CHLORINE FROM THE SAGAMORE PLANT. CHLORINE IS A HAZARDOUS SUBSTANCE UNDER CERCLA AND AN EXTREMELY HAZARDOUS SUBSTANCE UNDER EPCRA, WITH A REPORTABLE QUANTITY OF 10 POUNDS. RESPONDENT FAILED TO IMMEDIATELY NOTIFY THE NRC AS SOON AS IT HAD KNOWLEDGE AS REQUIRED BY SECTION 103(A) OF CERCLA, FAILED TO IMMEDIATELY PROVIDE NOTICE TO THE SERC AS REQUIRED BY EPCRA SEC. 304(A), FAILED TO IMMEDIATELY PROVIDE NOTICE TO THE LEPC AS REQUIRED BY EPCRA SEC. 304(A), FAILED TO PROVIDE A WRITTEN FOLLOW-UP NOTICE TO THE SERC AS SOON AS PRACTICABLE AS REQUIRED BY EPCRA SEC. 304(C) AND FAILED TO PROVIDE A WRITTEN FOLLOW-UP NOTICE TO THE LEPC AS SOON AS PRACTICABLE AS REQUIRED BY EPCRA SEC. 304(C).