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27. At all times relevant to this CAFO, chlorine was produced, used or stored at <br />Respondent's facility. <br />28. On January 7, 2015, at or about 1:20 p.m., a release occurred from Respondent's <br />facility of approximately 112 pounds of chlorine (the release). <br />29. In a 24-hour time period, the release of chlorine exceeded 10 pounds. <br />30. During the release, approximately 112 pounds of chlorine spilled, leaked, emitted, <br />discharged, escaped into the ambient air. <br />31. The release is a "release" as that term is defined under section 10 1(22) of <br />CERCLA, 42 U.S.C. § 9601(22). <br />32. The release is a "release" as that term is defined under section 329(8) of EPCRA, <br />42 U.S.C. § 11049(8). <br />33. Respondent had knowledge of the release on January 7, 2015, at approximately <br />1:20 p.m. <br />34. The release was one for which notice was required under section 103(a) of <br />CERCLA, 42 U.S.C. § 9603(a). <br />35. The release also required notice under section 304(a) of EPCRA, 42 U.S.C. <br />§ 11004(a). <br />36. The release was likely to affect the State of Minnesota. <br />37. At all times relevant to this CAFO, the Homeland Security and Emergency <br />Management Division of the Minnesota Department of Public Safety was the SERC for <br />Minnesota under section 301(a) of EPCRA, 42 U.S.C. § 11001(a). <br />38. Respondent notified the NRC of the release on January 8, 2015, at 12:53 p.m. <br />1 <br />