RESPONDENT FAILED TO SUBMIT A TIMELY LETTER OF INTENT TO TEST, OR A VALID EXEMPTION APPLICATION, PRIOR TO MANUFACTURING 1,3-DICHLOROPROPANOL, IN 1991, IN VIOLATION OF 40 C.F.R. SECTIONS 7900.45(A) & (D)(1) AND 799.5055, AND SECTION 15(1)(A) AND 3(B) OF TSCA; AND EXPORTED DIETHYLENE GLYCOL BUTYL ETHER ISREAL WITHOUT SUBMITTING THE INFORMATION REQUIRED BY 40 C.F.R. SECTION 707.65, IN VIOLATION OF SECTION 15(3) OF TSCA. THE PROGRAM IS ADDING ANOTHER COUNT WHICH I AM WAITING FOR.