1. SECTION 16(A) OF THE TOXIC SUBSTANCES CONTROL ACT, 15 U.S.C. SEC. 2601 ET SEQ. ( TSCA ). 2. PRIDE REFINING, INC. 500 CHESTNUT STREET ABILENE, TX. 79602 3. RESPONDENT'S FAILURE TO SUBMIT A FORM U FOR CHEMICAL SUB- STANCES LISTED IN COMPLAINT BY THE REGULATORY DEADLINE OF FEB. 21, 1991, CONSTITUTES A VIOLATION OF 40 C.F.R. SEC. 710.33(B), A RULE PROMULGATED UNDER SECTION 8(A) OF TSCA, AND THEREBY CONSTITUTES A VIOLATION OF SECTION 15(3)(B) OF TSCA. 4. RELIEF IS SOUGHT UNDER SECTION 16 OF TSCA WHICH AUTHOR- IZES A PROPOSED PENALTY OF $60,000.00.