1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT ( CERCLA ), AS AMENDED, 42 U.S.C. SEC. 9609. 2. ARCO CHEMICAL CORPORATION P.O. BOX 30 CHANNELVIEW, HARRIS COUNTY, TEXAS 77530 3. RESPONDENT VIOLATED THE NOTIFICATION REQUIREMENTS OF SEC- TION 103(A) OF CERCLA BY FAILING TO PROVIDE NOTICE IMMED- IATELY TO THE NRC AFTER THE RELEASE OF BENZENE FROM THE FACILITY ON OCT. 9, 1994. 4. RELIEF SOUGHT PURSUANT TO SECTION 109 OF CERCLA, EPA PRO- POSES A CIVIL PENALTY OF $6,188.