1. SECTION 16(A) OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SECTION 2601 ET SEQ. 2. STERLING CHEMICALS, INC., A DELAWARE 201 BAY STREET SOUTH TEXAS CITY, GALVESTON COUNTY, TEXAS 77590 3. RESPONDENT WAS IN VIOLATION OF SECTION 15(3)(B) OF TSCA BY: 1) FAILURE TO SUBMIT A PRELIMINARY ASSESSMENT INFORM- ATION REPORT (PAIR) FOR NAPHTHALENE. 4. RELIEF SOUGHT PURSUANT TO SECTION 16(A) OF TSCA, EPA PRO- POSED A CIVIL PENALTY OF $34,189.