REGION 5 OF THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (U.S. EPA ) IS RECOMMENDING THAT THE U.S. DEPARTMENT OF JUSTICE FILE A COMPLAINT AGAINST QUALITY SPECIALTY PRO- DUCTS CORPORATION ( QSP ) FOR FAILURE TO PAY A CIVIL PENALTY ASSESSED PURSUANT TO A CONSENT AGREEMENT AND FINAL ORDER ( CAFO ). THE COMPLAINT SEEKS TO COLLECT A DEBT OF %5,000, PLUS INTEREST, ADMINISTRATIVE, AND PENALTY CHARGES, AS WELL AS COSTS, OWED TO THE UNITED STATES AND ARISING FROM THE COMPANY'S TOTAL DISREGARD OF THE OBLIGATION TO PAY A CIVIL PENALTY PURSUANT TO A CAFO. SPECIFICALLY, THE U.S. EPA ISSUED AN ADMINISTRATIVE COMPLAINT AGAINST QSP ALLEGING THAT IT VIOLATED SECTION 7(C)1, 7 U.S.C. 136E(C)(1), AND 40 C.F.R. 167.85, OF THE FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT ( FIFRA ). THE COMPLAINT PROPOSED A CIVIL PENALTY OF $5,000. ON JULY 14, 1997, THE ACTING REGIONAL ADMINISTRATOR FOR U.S. EPA ISSUED A CAFO ASSESSING A CIVIL PENALTY OF $3,600 AGAINST QSP. THE CAFO BECAME EFFECTIVE WHEN IT WAS FILED WITH THE REGIONAL HEARING CLERK ON JULY 16, 1997. DUE TO QSP'S FAILURE TO MAKE TIMELY PAYMENTS OF THE ENTIRE ADJUSTED PROPOSED PENALTY OF $5,000 FOR VIOLA- TING THE CAFO. ADDITIONALLY, THIS DEMAND LETTER INFORMED QSP THAT IT WAS LIABLE FOR THE $192.29 IN INTEREST, $195 IN ADMININSTRATIVE CHARGES, AND $213.01 IN PENALTY CHARGES THAT HAD ACCRUED ON THE ORIGINAL $3,