THIS ORDER IS ISSUED TO CYCLO MANUFACTURING FOR FAILURE TO FILE A FORM R FOR ETHYLENE GLYCOL IN 1997; FOR 4,4 DIPHENYLMETHANE IN 1996; FOR 4,4 DIPHENYLMETHANE IN 1997; AND FOR METHYLENE CHLORIDE IN 1996. RESPONDENT ALSO FAILED TO FILE TWO TIER II REPORTS FOR CALENDAR YEAR 1998 AND STORED TWO HAZARDOUS CHEMICALS IN EXCESS OF THE 10,000 POUND THRESHOLD. RESPONDENT WILL PAY A CIVIL PENALTY IN THE AMOUNT OF $2,895 AND PERFORM A SEP. THE TOTAL COST OF THE SEP SHALL BE NO LESS THAN $8,683. THIS ORDER IS SUBJECT TO THE 22 RULE WHICH IS ENTERED INTO BY THE PARTIES FOR THE PURPOSE OF SIMULTANEOUSLY COMMENCING AND CONCLUDING THIS MATTER.