1. PURSUANT TO SECTION 16 OF TSCA. 2. EXXON CHEMICAL AMERICAS 13501 KATY FREEWAY HOUSTON, TX. 77079 3. EXXON VIOLATED SECTIONS 5 AND 8A OF TSCA BY MANUFACTURING A NEW CHEMICAL SUBSTANCE BEFORE IT SIBMITTED A TIMELY NOTICE OF COMMENCEMENT ( NOC ) WITH EPA. ALSO, RESPONDENT FAIL TO SUBMIT A PRE-MANUFACTURING NOTICE ( PMN ) TO EPA BEFORE IT MANUFACTURED TWO NEW CHEMICAL SUBSTANCE. 4. PROPOSED RELIEF PURSUANT TO SECTION 16 OF TSCA, A CIVIL PENALTY OF $128,000.00. 5. ON SEPT. 17, 1990, EXXON VOLUNTARILY DISCLOSED TO EPA ITS FAILURE TO SUBMIT A NOC BEFORE IT MANUFACTURED A NEW CHEMICAL SUBSTANCE FOR COMMERCIAL PURPOSES. EXXON ALSO SUBMITTED A PMN ON JAN. 4, 1991, IN WHICH IT ADMITTED THAT IT HAD MANUFACTURED TWO NEW CHEMICAL SUBSTANCES FOR COMMERCIAL PURPOSES FROM MAR. 17, 1988, THROUGH NOV. 19, 1990. 1990.