DURING INSPECTIONS ON 7/20 AND 7/21/99, THE EPA INSPECTOR DETERMINED THAT RESPONDENT HAD FORMULATED A PRODUCT LABELED GREAT WHITE SANITIZER BARDAC 205M-7.5 FROM BARDAC 205M-7.5, A PESTICIDE REGISTERED WITH EPA BY LONZA, INC. WITHOUT FIRST OBTAINING AN APPROVED SUPPLEMENTAL REGISTRATION FROM LONZA. EPA HAS DETERMINED THAT AN APPROPRIATE CIVIL PENALTY TO SETTLE THIS ACTION IS $4,000. RESPONDENT CONSENTS FOR THE PURPOSE OF THIS SETTLEMENT TO THE PAYMENT OF THE $4,000 CIVIL PENALTY. 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. PENALTY MAY BE MADE IN TWO INSTALLMENTS OF $2,000 EACH.