COMPLAINT FILED 9/21/99 PROPOSING A PENALTY OF $31,000. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO SUBMIT AN ACCURATE NOC TO THE EPA WITH- IN THIRTY DAYS AFTER MANUFACTURING THE FIRST COMMERCIAL BATCH OF CHEMICAL B. IN VIOLATION OF TSCA 40 C.F.R. SECTION 720.102(A). COUNT II RESPONDENT FAILED TO REFERENCE ON THE NOC THE SITE WHERE THE COMMERCIAL BATCH OF CHEMICAL A WAS MANUFACTURED. IN VIOLATION OF TSCA 40 C.F.R. SECTION 720.102(C)(1)(VIII). CAFO ISSUED 5/9/00 ASSESSING A PENALTY OF $18,600. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. REDS NO: 2000 052 441 OWO 7H