1. SECTION 16A OF THE TOXIC SUBSTANCES CONTROL ACT ( TSCA ), 15 U.S.C. SEC. 2601 ET SEQ. 2. GREAT LAKES CHEMICAL CORPORATION 324 SOUTHFIELD CUTOFF (AKA: ROUTE 7, BOX 529, HIGHWAY 167 SOUTH) EL DORADO, ARKANSAS 71730 3. RESPONDENT VIOLATED SECTION 8(A) AND 15(3)(B) OF TSCA BY FAILING TO SUBMIT TWO CHEMICAL SUBSTANCES TO BE INCLUDED IN THE 1990 INVENTORY UPDATE REPORT, AND SECTION 15(1)(C) AND 15(3)(B) OF TSCA BY SUBMISSION OF AN UNTIMELY NOTICE OF COMMENCEMENT. 4. RELIEF SOUGHT PURSUANT TO SECTION 16 OF TSCA, A PENALTY OF $40,000.00 IS PROPOSED.