TEKNOR APEX FAILED TO FILE PMNS AND NOCS FOR THREE CHEMICALS. FOR TWO CHEMICALS TEKNOR APEX DISCLOSED THE VIOLATIONS WITHIN 10 DAYS AND MET ALL OTHER CRITERIA FOR PENALTY MITIGATION UNDER THE AUDIT POLICY. IT DID NOT DISCLOSE THE VIOLATION FOR THE THIRD CHEMICAL WITHIN TEN DAYS AND SO IT IS SUBJECT TO A PENALTY. THIS ACTION WILL BE COMMENCED AND CONCLUDED WITH SIMULTANEOUS COMPLAINT AND CONSENT AGREEMENT.