1. SECTION 16(A) OF THE TOXIC SUBSTANCES CONTROL ACT, 15 U.S.C. SECTION 2601 ET SEQ. ( TSCA ). 2. BAKER PERFORMANCE CHEMICALS, INC. U.S. HIGHWAY 90, 15 MILES S.W. DAYTON, TEXAS 3. RESPONDENT WAS IN VIOLATION OF SECTIONS 8(A) AND 15(3)(B) OF TSCA BY FAILING TO SUBMIT SIX CHEMICAL SUBSTANCES TO BE INCLUDED IN ITS 1994 INVENTORY UPDATE REPORT. 4. RELIEF SOUGHT PURSUANT TO SECTION 16 OF TSCA, EPA PRO- POSES A CIVIL PENALTY OF $102,000. 5. UNDER CONFIDENTIAL BUSINESS INFORMATION (CBI) REGULATIONS CERTAIN INFORMATION IN THE COMPLAINT WAS DELETED.