FAILURE TO NOTIFY OF INTENTION TO MANUFACTURE A CHEMICAL SUBSTANCE NOT ON THE TSCA INVENTORY (5 COUNTS) AND FAILURE TO COMPLY WITH NOTICE OF COMMENCEMENT REQUIREMENTS. ** ON MARCH 16, 1989 U.S. EPA ISSUED AN EIGHT-COUNT COMPLAINT AGAINST WORTHEN INDUSTRTIES, INC. - UPACO ADHENSIVES DIV- ISION CHARGING WORTHEN WITH VIOLATING TSCA SECTION 5 REQUIREMENTS FOR THE SUBMISSION OF PREMANUFACTURING NOTIFICATIONS (PMNS) AND NOTICES OF COMMENCEMENT (NOCS) EPA PROPOSED TO ASSESS A CIVIL PENALTY OF $3,429,500. WORTHEN FILED AN ANSWER ON APRIL 10, 1989, IN WHICH WORTHEN GENERALLY DENIED THE ALLEGATIONS AND ASSERTED NUMEROUS AFFIRMATIVE DEFENSES. SETTLEMENT NEGOTIATIONS ARE IN PROGRESS.