COUNT I - MENUFACTURE OF NEW CHEMICAL SUBSTANCE PROIOR RO EXPIRATION OF 90 DAY REVIEW PERIODS. TSCA SECTION 5 AND 8. 40 CFR SECTION 720.3, 720.22,(A)(I) 720.40(B). COUNT II - FAILURE TO SUBMIT AN ACCOUNTS NOTICE OF COMMERMENT (NOC) FOR NEW CHEMICAL SUBSTANCE. NOC INDICATED WRONG DATE OF PREDUCTION TSCA SECTION 5. 40 CFR SECTION 720.102(C), 720.120(F). COUNT III - LATE REPORTING UNDER INVENTORY, UPDATE RULE. 3M FAILED TO SUBMIT REPORT FOR 1,1,1,-TRICHLOROETHANE BY FEBRUARY21, 1991, AS REQUIRED. TSCA SECTION 8A, 40 C.F.R. SECTION 710.28, 710.32. COUNT IV - LATE RREPORTING UNDER INVENTORY UPDATE RUEL. 3M FAILED RO SUBMIT REPORT FOR 2-METHYL PREPARE BY FEBRUARY 21, 1991, AS REQUIRED. TSCA SECTION 8A 40 C.FR. SECTION 710.28, 710.32. PENALTY FOR COUNT I MITIGATED FOR VOLUNTARY DISCLOSURE. PENALTY FOR COUNTS II-IV ENCHANCED FOR PRIOR HISTORY OF SIMILAR VIOLATIONS.