THE ALLEGATION IS THAT THE COMPANY ISSUED A FALSE NOTICE OF COMMENCEMENT IN VIOLATION OF 40 CFR SECTION 720.120. DURING A 12/20/89 INSPECTION IT WAS DETERMINED THAT NO COMMERICAL PRODUCTION TOOK PLACE OF A POLYETER RESIN (WHOSE IDENTITY IS CBI) FOR WHICH THE COMPANY HAD SUBMITTED A PREMANUFACTURE NOTIFICATION AND A NOTICE OF COMMENCEMENT.