1. SECTION 16 OF THE TOXIC SUBSTANCES CONTROL ACT, AS AMEND- ED ( TSCA ), 15 U.S.C. SEC. 2615. 2. SHELL OIL COMPANY DEER PARK MANUFACTURING COMPLEX DEER PARK, TEXAS 3. RESPONDENT WAS IN VIOLATION OF SECTION 15(3)(B) OF TSCA BY FAILING TO REPORT THE MANUFACTURE OF ONE CHEMICAL SUB- STANCE TO EPA BY DEC. 23, 1986 AND FAILING TO REPORT THE MANUFACTURE OR IMPORT OF FIVE CHEMICAL SUBSTANCES TO EPA BY FEB. 21, 1991. 4. PROPOSED RELIEF PURSUANT TO SECTION 16 OF TSCA, EPA PRO- POSES A CIVIL PENALTY OF $102,000.00.