1. SECTION 16 OF THE TOXIC SUBSTANCES CONTROL ACT, AS A- MENDED ( TSCA ), 15 U.S.C. SEC. 2615. 2. SHELL OIL COMPANY DEER PARK MANUFACTURING COMPLEX DEER PARK, TEXAS 77536 3. RESPONDENT WAS IN VIOLATION OF SECTION 15(1)(C) OF TSCA ON COUNTS OF 1) FAILING TO MAINTAIN PROPER RECORDS OF IN- SPECTION AND MAINTENANCE HISTORY, 2) FAILING TO MARK ITS PCB LARGE HIGH VOLTAGE CAPACITOR LOCATION WITH THE ML LA- BEL, 3) FAILING TO INCLUDE THE ADDRESS AND EPA I.D. NUM- BER OF THE FACILITY, MANIFEST NUMBERS FOR WASTE DISPOSED OF, AND DATES THAT PCB WAS PLACED INTO TRANSPORT FOR OFF- SITE STORAGE OR DISPOSAL IN ITS ANNUAL DOCUMENT LOG, AND 4) FAILING TO INCLUDE THE DATE PCBS AND PCB ITEMS WERE PLACED INTO TRANSPORT FOR DISPOSAL AND THE TOTAL WEIGHT IN KILOGRAMS OF PCBS AND PCB ITEMS IN PCB CONTAINERS IN ITS 1989 ANNUAL DOCUMENT, AND FAILING TO INCLUDE THE TO- TAL QUANTITIES OF PCBS AND PCB ITEMS REMAINING IN SERVICE AT THE END OF THE CALENDAR YEAR IN ITS ANNUAL DOCUMENTS FOR THE YEARS 1981 THROUGH 1989. 4. PROPOSED RELIEF PURSUANT TO SECTION 16 OF TSCA, EPA PRO- POSES A CIVIL PENALTY OF $35,000.00.