RESPONDENT MANUFACTURED IN SMALL QUANTITIES 3 NEW CHEMICALS. ALTHOUGH APPARENTLY MANUFACTURED FOR R&D PURPOSES, RESPONDENT DID NOT MEET ALL REQUIREMENTS FOR AN R&D EXEMPTION TO THE PMN REGULATIONS. HAVING FILED NO PMN NOTICE FOR THE 3 NEW CHEMICALS, RESPONDENT'S MANUFACTURE OF THEM IS IN VIOLATION OF THE PMN REGULATIONS. A FOURTH COUNT AGAINST RESPONDENT ALLEGES THAT IT VIOLATED THE NOC REGULATIONS BY NOT SUBMITTING TO USEPA A TIMELY NOC WITH REGARD TO A FOURTH CHEMICAL IT MANUFACTURED.