1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT ( CERCLA ), AS AMENDED, 42 U.S.C. SECTION 9609. 2. DYNAGEN, INC. P.O. BOX 2032 ODESSA, ECTOR COUNTY, TEXAS 79760 3. RESPONDENT WAS IN VIOLATION OF THE NOTIFICATION REQUIRE- MENTS OF SECTION 103(A) OF CERCLA BY FAILING TO PROVIDE NOTICE TO THE NRC IMMEDIATELY AFTER HAVING KNOWLEDGE THAT A RELEASE OF BUTADIENE OVER THE RQ OCCURED ON MAR. 24, 1997. 4. RELIEF SOUGHT PURSUANT TO SECTION 109 OF CERCLA, EPA PRO- POSES A CIVIL PENALTY OF $25,000.