1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT (CERCLA), AS AMENDED, 42 U.S.C. SEC. 9609. 2. STERLING CHEMICALS INC. 201 BAY STREET SOUTH TEXAS CITY, TEXAS 77592 3. RESPONDENT WAS IN VIOLATION OF THE NOTIFICATION REQUIRE- MENTS OF CERCLA 103(A) BY FAILING TO PROVIDE NOTICE TO THE NRC IMMEDIATELY AFTER THE RELEASE OF 193 POUNDS OF HYDROGEN CYANIDE ON APR. 30, 1994 OCCURRED. 4. PROPOSED RELIEF PURSUANT TO SECTION 109 OF CERCLA, EPA PROPOSES A CIVIL PENALTY OF $20,000.00. 5. FACILITY ID NO. TXD008079527 SIC CODE: 2865 DUN & BRADSTREET: 15-430-0024