In a letter dated 4/20/10, Respondent voluntarily disclosed to EPA that four lots of starting material having an analyte slightly over the [TSCA 5(e)] Consent Order limit were used in the manufacture of Consent Order PMN substances. The starting material at issue has been declared Confidential Business Information by Respondent and will be referenced in this matter as Chemcial A and its analyte. Respondent manufactured four separate lots of chemical A on 11/9/09, 12/12/09, 1/24/10, and 2/13/10 that failed to meet one of the analyte limit requirements in the TSCA 5(e) Consent Order. Respondent's use of the four lots of Chemical A during the manufacture of Consent Order PMN substances constitutes four violations under TSCA 15(1)(C), 15 U.S.C. 2614(1)(C). Respondent has agreed to pay a civil penalty of $52,500.