1. SECTION 16(A) OF THE TOXIC SUBSTANCES CONTROL ACT, 15 U.S.C. SEC. 2601 ET SEQ. ( TSCA ). 2. NAVAJO REFINING COMPANY 501 EAST MAIN ARTESIA, NEW MEXICO 88210 3. RESPONDENT VIOLATED SECTION 8(A) AND 15(3)(B) OF TSCA BY FAILING TO SUBMIT A FORM U FOR 18 CHEMICALS BY THE RE- GULATORY DEADLINE OF FEB. 21, 1991. 4. RELIEF SOUGHT PURSUANT TO SECTION 16 OF TSCA, EPA PRO- POSES A PENALTY OF $108,000.00.