3/21/94: PRA INFORMATION: PENALTY WAS SER AT $45,000. BASED ON PENALTY POLICY; BEN, GRAVITY AND OTHER FACTORS. NO PENALTY ADJUSTMENT MADE FOR PRA, EXCEPT THAT IN CALCULATING STARTING MAXIMUM PENALTY FOR NEGOTIATION PURPOSES, THIS MAXIMUM WAHAD TO BE CONSISTENT WITH PRA ISSUES. THER ARE FOUR VIOLATIONS IN THIS CASE. THREE OF THESE ARE INFORMATION ORIENTED.