COMPLAINT ALLEGES FAILURE TO TIMELY SUBMIT NOTICE OF IN- TENT TO TEST FOR 8 CHEMICAL SUBSTANCES TO DETERMINE WHETHER THEY ARE CONTAMINATED WITH HDDS/HDFS, PURSUANT TO 40 CFR PART 766. EPA BELIEVES THAT RESPONDEMT MANUFACTURED 8 CHE- MICALS SUBJECT TO 40 CFR PART 766 WITHOUT SUBMITTING TIMELY LETTERS OF INTENT TO TEST. THE COMPLAINT CONTAINS 8 COUNTS AT $17,000 EACH FOR A TOTAL OF A $136,000 PROPOSED PENALTY. THE IDENTITY OF THE 8 SUBSTANCES IS CLAIMED AS CONFIDENTIAL BUSINESS INFORMATION (CBI) BY RESPONDENT.