1. SECTION 16(A) OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2601 ET SEQ. 2. CROSS OIL REFINING & MARKETING, INC., AN ARKANSAS CORP. 484 E. 6TH STREET SMACKOVER, UNION COUNTY, ARKANSAS 71762 3. RESPONDENT WAS IN VIOLATION OF SECTION 15(3)(B) OF TSCA BY FAILING TO ACCURATELY SUBMIT THE PRODUCTION AND SITE REPORT (FORM U) TO EPA FOR CHEMICAL SUBSTANCES BY THE RE- GULATORY DEADLINE OF DEC. 23, 1994. 4. RELIEF SOUGHT PURSUANT TO SECTION 16(A) OF TSCA, EPA PRO- POSES A CIVIL PENALTY OF $102,000.