GE DIS7LOSED SEVERAL POTENTIAL VIOLATIONS OF THE TSCA EXPORT NOTIFICATION RULE, 40 CFR PART 707 SUBPART D. THEY HAVE MORE RESEARCH TO DO TO DETERMINE IF THE VIOLATIONS DID ACTUALLY OCCUR. THEIR DISCLOSURE WAS ACTUALLY A LITTLE PREMATURE. RESPONDENT FAILED TO FILE FOUR TSCA EXPORT NOTICES. RESPONDENT VOLUNTARILY DISCLOSED THE VIOLATIONS, BUT DID NOT QUALIFY FOR 100% PENALTY REDUCTION UNDER THE AUDIT POLICY BECAUSE OF A HISTORY OF SIMILAR VIOLATIONS WITHIN THE PAST 3 YEARS. RESPONDENT PAID TOTAL PROPOSED PENALTY IN CASH, WITHOUT THE FILING OF A CAFO.