1. SECTION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT ( CERCLA ), 42 U.S.C. SEC- TION 9609. 2. UNION PACIFIC RESOURCES ROUTE 1, BOX 257 BISHOP, NUECES COUNTY, TEXAS 78343-9801 3. RESPONDENT WAS IN VIOLATION OF THE NOTIFICATION REQUIRE- MENTS OF CERCLA 103(A) BY FAILING TO NOTIFY THE NRC IM- MEDIATELY OF A RELEASE OVER THE RQ OF SODIUM NITRITE FROM THE FACILITY ON OCT. 11, 1996 FOR APPROXIMATELY 13 HOURS. 4. RELIEF SOUGHT PURSUANT TO SECTION 109(A) OF CERCLA, EPA PROPOSES A CIVIL PENALTY OF $8,250.