RESPONDENT VIOLATED SECTION 103(A) OF CERCLA BY FAILING TO IMMEDIATELY NOTIFY THE NATIONAL RESPONSE CENTER ( NRC ) AND SECTION 304 (A) BY FAILING TO NOTIFY THE LOCAL EMERGENCY PLANNING COMMITTEE ( LEPC ) AND THE STATE EMERGENCY RESPONSE COMMISSION ( SERC ) AS SOON AS RESPONDENT KNEW OR SHOULD HAVE KNOWN THAT RELEASE OF A HAZARDOUS SUBSTANCE, NAMELY, BENZENE AND 1,2-BUTADIENE, HAD OCCURED AT RESPONDENT'S REFINERY IN AN AMOUNT EQUAL TO OR EXCEEDING THE APPLICABLE RQ ON SEPTEMBER 21, 2014 AND FEBRUARY 22, 2014, RESPECTIVELY.