PURSUANT TO THE 8.28.86 MEMORANDUM ENTITLED EXPANDED CIVIL JUDICIAL REFERRAL PROCEDURES , REGION II IS INITIATING A DIRECT REFERRAL TO DOJ TO COLLECT A PENALTY ASSESSED BY EPA PURSUANT TO TSCA. REGION II RECOMMENDS THAT A COMPLAINT BE FILED PURSUANT TO TSCA SECT. 16A4, 15 USC 2615A4 AGAINST N.O.C. INCORPORATED, TRADING AS NOBLE OIL COMPANY, TO COLLECT THE $40,000 FINE. THE COMPANY HAS EXHAUSTED ITS ADMINISTRATIVE AND JUDICIAL APPEALS; THE FINAL STEP OCCURRED IN JUNE 1986 WHEN THE U.S. SUPREME COURT DENIED THE COMPANY'S PETITION FOR A WRIT OF CERTIORARI. DESPITE REMINDERS FROM EPA SINCE THEN, NOBLE HAS STILL NOT PAID THE PENALTY. ************** FLAIRE MILLS CLAIMS HELEN AND WILKIE HAS ALL DOCUMENTATIONS ON THIS CASE AND TO ASK THEM FOR ANY INFO NEEDED.