1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT ( CERCLA ), 42 U.S.C. SECTION 9609. 2. SHELL CHEMICAL COMPANY 15536 RIVER ROAD NORCO, SAINT CHARLES PARISH, LOUISIANA 70079 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 THE RELEASE OF NITRO- GEN DIOXIDE ABOVE THE RQ FROM THE FACILITY ON JUL. 5, 1997. 4. RELIEF SOUGHT PURSUANT TO SECTION 109 OF CERCLA, EPA PRO- POSES A CIVIL PENALTY OF $27,500.