1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT ( CERCLA ), AS AMENDED, 42 U.S.C. SEC. 9609. 2. REICHHOLD CHEMICALS INC. 1503 HADEN ROAD HOUSTON, TEXAS 77015 3. RESPONDENT WAS IN VIOLATION OF THE NOTIFICATION REQUIRE- MENTS OF CERCLA 103(A) BY FAILING TO PROVIDE NOTICE TO THE NRC IMMEDIATELY AFTER A RELEASE OF PHTHALIC ANHYDRIDE FROM THE FACILITY ON MAR. 12, 1995. 4. RELIEF SOUGHT PURSUANT TO SECTION 109 OF CERCLA, EPA PRO- POSES A CIVIL PENALTY OF $6,188.