IN THIS ENFORCEMENT ACTION EPA ALLEGES THAT TREMCO MANUFACTURED THREE (3) NEW CHEMICAL SUBSTANCES PRIOR TO THE REQUIRED SUBMISSION OF A PREMANUFACTURE NOTICE FOR EACH OF THE 3 SUBSTANCES. EPA ALSO ALLEGES THAT TREMCO MANUFACTURED TWO OF THE THE THREE SUBSTANCES DURING THE PREMANUFACTURE REVIEW PERIOD. THIS ALLEGED CONDUCT VIOLATES THE TSCA SECTION 5 PREMANUFACTURE RULES. TREMCO HAD VOLUNTARILY DISCLOSED MOST OF THESE VIOLATIONS, AND THEREFORE IS ELIGIBLE FOR CERTAIN PENALTY REDUCTIONS.