1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT ( CERCLA ), AS AMENDED, 42 U.S.C. SECTION 9609. 2. REYNOLDS METALS COMPANY HIGHWAY 361 EAST GREGORY, NUECES COUNTY, TEXAS 78359 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 SODIUM HYROXIDE FROM THE FACILITY OCCURRED. 4. RELIEF SOUGHT PURSUANT TO SECTION 109 OF CERCLA, EPA PRO- POSED A CIVIL PENALTY OF $27,000 FOR THE VIOLATION CITED.