1. SECTION 16 OF THE TOXIC SUBSTANCES CONTROL ACT, AS AMEND- ED ( TSCA ), 15 U.S.C. SECTION 2615. 2. PHILIPS ELECTRONICS NORTH AMERICA CORP, A.K.A. PHILIPS LIGHTING COMPANY, A DELAWARE CORPORATION 12429 ROJAS DRIVE EL PASO, EL PASO COUNTY, TEXAS 79928-5201 3. RESPONDENT WAS IN VIOLATION OF SECTION6 OF TSCA BY: 1) IMPORTING WITHOUT AN EXEMPTION OF PCBS AT CONCENTRATION GREATER THAN 50 PPM; 2) FAILING TO COMPLY WITH TSCA CERT- IFICATION REQUIREMENTS; AND 3) FAILING TO ESTABLISH AND MAINTAIN RECORDS REQUIRED BY TSCA AND PROVIDING TO THE DISTRICT DIRECTOR AT THE PORT OF ENTRY A COMPLETE CERTI- FICATION STATEMENT REPRESENTING THE TRUE COMPLIANCE STAT- US OF AN IMPORTED SHIPMENT OF PCB CAPACITORS WITH A CON- CENTRATION GREATER THAN 50 PPM FROM ITS FACILITY IN MEXICO. 4. RELIEF SOUGHT PURSUANT TO SECTION 16 OF TSCA, EPA ASSESS- ED THE RESPONDENT A CIVIL PENALTY OF $2,750.