A 2 COUNT COMPLAINT WAS ISSUED 4/24/91 CHARGING DESOTO WITH MANUFACTURING A SUBSTANCE WITHOUT HAVING FILED A PRE-MANU- FACTURE NOTICE ( PMN ) IN VIOLATION IF TSCA, AND WITH MANU- FACTURING ANOTHER SUBSTANCE WTIHOUT HAVING FILED A NOTICE OF COMMERCEMENT ( NOC ) IS VIOLATION IF TSCA. A CONSENT AGREE- MENT WAS FILED SIMULTANEOUSLY SETTLING THE CASE. UNDER THE CONSENT AGREEMENT DE SOTO AGREED TO PAY A CIVIL OF $469,000. THE PENALTY WAS PAID BY CASHIER'S CHECK DATED 5/22/91.