1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPOSE, COMPENSATION, AND LIABILITY ACT ( CERCLA ), AS AMENDED, 42 U.S.C. SEC. 9609. 2. HOFFMAN-LA ROCHE INC. 1000 COUNTY ROAD 227 FREEPORT, TEXAS 77541 3. RESPONDENT VIOLATED THE NOTIFICATION REQUIREMENTS OF CERCLA 103(A) BY FAILING TO PROVIDE NOTICE TO THE NRC IMMEDIATELY AFTER THE RELEASE OF 4,500 LBS. OF AMMONIA OVER A SIX DAY PERIOD, STARTING ON AUG. 4, 1993. 4. RELIEF SOUGHT PURSUANT TO SECTION 109 OF CERCLA, EPA PRO- POSES A PENALTY OF $16,500.00.