1. SECTION 16 OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2615. 2. CITY OF KIRBYVILLE KIRBYVILLE LIGHT AND POWER 107 SOUTH ELIZABETH KIRBYVILLE, JASPER COUNTY, TEXAS 75956 3. RESPONDENT WAS IN VIOLATION OF SECTION 15(1)(C) OF TSCA BY FAILING TO PROPERLY DISPOSED OF PCBS. 4. RELIEF SOUGHT PURSUANT TO SECTION 16 OF TSCA, EPA PRO- POSES A PENALTY OF $27,500.