1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT ( CERCLA ), 42 U.S.C. SECTION 9609. 2. EL DORADO CHEMICAL COMPANY 4500 NORTHWEST AVENUE EL DORADO, UNION COUNTY, ARKANSAS 71730 3. RESPONDENT WAS IN VIOLATION OF THE NOTIFICATION REQUIRE- MENTS OF SECTION 103(A) OF CERCLA BY FAILING TO NOTIFY THE NRC IMMEDIATELY OF A RELEASE OVER THE RQ OF NITROGEN DIOXIDE. 4. RELIEF SOUGHT PURSUANT TO SECTION 109 OF CERCLA, EPA PRO- POSES A CIVIL PENALTY OF $16,500.