1. SECTION 16(A) OF THE TOXIC SUBSTANCES CONTROL ACT, 15 U.S.C. SEC. 2601 ET SEQ. ( TSCA ). 2. UNION CARBIDE CORPORATION 3301 5TH AVENUE SOUTH TEXAS CITY, TEXAS 77590 3. RESPONDENT VIOLATED SECTIONS 8(A) AND 15(3)(B) OF TSCA BY FAILING TO SUBMIT FORM US FOR TWO CHEMICAL SUBSTANCES IN- CLUDED IN THE 1990 INVENTORY UPDATE REPORT. 4. RELIEF SOUGHT PURSUANT TO SECTION 16(A) OF TSCA, EPA PRO- POSES A CIVIL PENALTY OF $17,000.