1. SECTION 16(A) OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2601 ET SEQ. 2. HOWELL HYDROCARBONS & CHEMICALS, INC. 1201 SOUTH SHELDON ROAD CHANNELVIEW, TEXAS 77530 3. RESPONDENT WAS IN VIOLATION OF THE REPORTING REQUIREMENTS OF SECTION 8(A) AND 15(3)(B) OF TSCA BY FAILING TO TIMELY SUBMIT SIX CHEMICALS SUBSTANCES IN THE 1994 INVENTORY UP- DATE REPORT (FORM U ). 4. RELIEF SOUGHT PURSUANT TO SECTION 16(A) OF TSCA, EPA PRO- POSES A CIVIL PENALTY OF $102,000.