1. SECTION 16 OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C SECTION 2615. 2. AMERICAN OVERSEAS PETROLEUM LIMITED, INC. (AMOSEA) 125 EAST JOHN CARPENTER FREEWAY IRVING, DALLAS COUNTY, TEXAS 3. RESPONDENT WAS IN VIOLATION OF SECTION 15(1)(C) OF TSCA BY THE IMPORTING, WITHOUT AN EXEMPTION, OF PCBS AT CON- CENTRATIONS THAN 50 PPM INTO THE U.S. DURING 1994, AND SECTIONS 15(3)(A) AND 15(3)(B) OF TSCA BY FAILING TO CERTIFY IMPORTS TO U.S. CUSTOMS SERVICE OFFICIALS OF IM- PORTED SHIPMENTS. 4. RELIEF SOUGHT PURSUANT TO SECTION 16 OF TSCA, EPA PRO- POSES A CIVIL PENALTY OF $15,000.