THIS CASE INVOLVES 28 COUNTS OF VIOLATIONS OF TSCA'S SECTION 5 PMN PROVISIONS. THE VIOLATIONS WERE COMMITTED BY EDWIN COOPER, INC., THE WHOLLY-OWNED SUBSIDIARY OF ETHYL. THE SUBSTANCE INVOLVED IS A NAIVE FUEL ADDITIVE. THE PRODUCT, AN IMPORT, WAS ORDERED FOR A SINGLE CUSTOMER, BURMAH CASTROL, INC. BECAUSE B-C FORMERLY OWNED EDWIN COOPER, INC. THE ORDER WAS PLACED VIA THE MOST DIRECT ROUTE, BYPASSING THE TSCA COMPLIANCE MEASURES WHICH HAD BEEN PUT INTO PLACE BY EDWIN COOPER.