1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT ( CERCLA ), 42 U.S.C. SECTION 9609. 2. ROHM AND HAAS TEXAS, INCORPORATED 1900 TIDAL ROAD, P.O. BOX 1330 LA PORTE, HARRIS COUNTY, TEXAS 77572 3. RESPONDENT WAS IN VIOLATION OF THE REPORTING REQUIREMENTS OF SECTION 103(A) OF CERCLA BY FAILING TO PROVIDE NOTICE TO THE NRC IMMEDIATELY AFTER HAVING KNOWLEDGE THAT A RE- LEASE OF SULFURIC ACID, ABOVE THE RQ, OCCURRED. 4. RELIEF SOUGHT PURSUANT TO SECTION 109 OF CERCLA, EPA PRO- POSED A CIVIL PENALTY OF $20,000 FOR THE VIOLATION CITED.