1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT ( CERCLA ), 42 U.S.C. SECTION 9609. 2. SHELL CHEMICAL COMPANY P.O. BOX 500 GEISMAR, ASCENSION PARISH, LOUISIANA 70734 3. RESPONDENT WAS IN VIOLATION OF THE THE NOTIFICATION RE- QUIREMENTS OF SECTION 103(A) OF CERCLA BY FAILING TO PRO- VIDE NOTICE TO THE NRC IMMEDIATELY AFTER A RELEASE OF ETHYLENE OXIDE ABOVE THE RQ FROM THE FACILITY. 4. RELIEF SOUGHT PURSUANT TO SECTION 109 OF CERCLA, EPA PRO- POSED A CIVIL PENALTY OF $13,750 FOR THE VIOLATION CITED.