1. SECTION 16 OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2615. 2. CITY OF WEST MEMPHIS UTILITIES, AN ARKANSAS MUNICIPAL CORPORATION 604 EAST COOPER WEST MEMPHIS, CRITTENDEN COUNTY, ARKANSAS 72301 3. RESPONDENT WAS IN VIOLATION OF SECTION 15(1)(C) OF TSCA BY (1) FAILING TO NOTIFY EPA OF PCB WASTE ACTIVITY; (2) FAILING TO DATE PCB ARTICLES WHEN THEY ARE PLACED IN STORAGE FOR DISPOSAL, AND (3) FAILING TO DEVELOP AND MAINTAIN ANNUAL DOCUMENT LOG FOR CALENDAR YEAR 1993 AND 1995. 4. RELIEF SOUGHT PURSUANT TO SECTION 16 OF TSCA, EPA PRO- POSES A CIVIL PENALTY OF $40,600 FOR THE VIOLATIONS CITED.