1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT ( CERCLA ), 42 U.S.C. SECTION 9609. 2. ADVANCE CHEMICAL DISTRIBUTION P.O. DRAWER 151 NOWATA, NOWATA COUNTY, OKLAHOMA 74048 3. RESPONDENT WAS IN VIOLATION OF SECTION 103(A) OF CERCLA BY FAILING TO NOTIFY NRC IMMEDIATELY OF THE RELEASE OVER THE RQ OF CHLORINE FROM THE FACILITY. 4. RELIEF SOUGHT PURSUANT TO SECTION 109 OF CERCLA, EPA PRO- POSES A CIVIL PENALTY OF $8,250.