1. SECTION 16(A) OF THE TOXIC SUBSTANCES CONTROL ACT, 15 U.S.C. SECTION 2601 ET SEQ., ('TSCA ). 2. TOLSON USA, INC. 16800 GREENSPOINT PARK DRIVE, STE. 205S HOUSTON, HARRIS COUNTY, TEXAS 77060 3. RESPONDENT WAS IN VIOLATION OF THE REPORTING REQUIREMENTS OF SECTION 8(A)(1)(A) AND 15(3)(B) OF TSCA BY FAILING TO SUBMIT AN ACCURATE FORM U BY THE REGULATORY DEADLINE. 4. RELIEF SOUGHT PURSUANT TO SECTION 16 OF TSCA, EPA PRO- POSES A CIVIL PENALTY OF $119,000.