THIS DIRECT REFERRAL TO DOJ IS TO INITIATE COLLECTION PROCEEDINGS TO ENFORCE A STATUTORY PENALTY WHICH WAS AGREED TO IN ADMINISTRATIVE ORDER ISSUED 10/27/86. P C B DID NOT PAY ANY PORTION OF THE CIVIL PENALTY NOR UNDERTAKE ANY OF THE ACTIONS REQUIRED BY TERMS OF THE ORDER. THIS CASE IS A STRAIGHT-FORWARD COLLECTION MATTER IN WHICH THERE IS NO DISPUTE OVER THE VIOLATIONS OR THE CIVIL PENALTY ASSESSMENT OF $120,000.