A CIVIL ADMINISTRATIVE COMPLAINT WAS FILED ON DECEMBER 22, 1988 SEEKING A PENALTY OF $213,750 FROM ROYAL LUBRICANTS COMPANY, INC., EAST HANOVER, NEW JERSEY FOR VIOLATIONS OF TSCA CHEMICAL PREMANUFACTURE NOTICE REQUIREMENTS. ROYAL VOLUNTARILY DISCLOSED THAT IT HAD MANUFACTURED THREE CHEMICAL SUBSTANCES IN VIOLATION OF TSCA AND ACCORDINGLY WAS ELIGIBLE FOR A 50% REDUCTION IN THE PROPOSED PENALTY, AS SPECIFIED IN THE TSCA 5 PENALTY POLICY. VINCENT GIORDANO REPRESENTS EPA IN THIS MATTER. ROYAL'S ANSWER IS DUE ON OR BEFORE JANUARY 19, 1989.