1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT ( CERCLA ), AS AMENDED, 42 U.S.C. SECTION 9609. 2. CONOCO INC. LAKE CHARLES REFINERY - EXCEL PARALUBES 2200 OLD SPANISH TRAIL, P.O. BOX 37 WESTLAKE, CALCASIEU PARISH, LOUISIANA 70669 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 HYDROGEN SULFIDE HAD OCCURRED. 4. RELIEF SOUGHT PURSUANT TO SECTION 109 OF CERCLA, EPA PRO- POSED A CIVIL PENALTY OF $12,500 FOR THE VIOLATION CITED.