ON SEPTEMBER 26, 2003, REGION I FILED A CONSENT AGREEMENT AND ORDER (CAO) WHICH COMMENCED AND CONCLUDED A CIVIL ADMINISTRATIVE ACTION UNDER THE CLEAN AIR ACT AGAINST SEVILLE DYEING COMPANY, INC., INCLUDING ITS DORADO PROCESSING DIVISION, OF WOONSOCKET, RI. EPA's ACTIONS INCLUDES ALLEGATIONS THAT SEVILLE VIOLATED CERTAIN REQUIREMENTS OF THE RHODE ISLAND SIP AND THE CLEAN AIR ACT. THE CASE AROSE AS A RESULT OF EMISSIONS, PERMITTING, MONITORING, RECORD KEEPING AND REPORTING VIOLATIONS OF THE RHODE ISLAND STATE IMPLEMENTATION PLAN (SIP) AT THESE FACILITIES AFTER JOINT EPA-STATE INSPECTIONS IN JUNE AND JULY 1999. SEVILLE CEASED ALL OPERATIONS AT ITS DORADO DIVISION IN JUNE 2001 AND, IN MAY 2002, PERMANENTLY CLOSED ITS ONLY OTHER FACILITY. AT PRESENT, SEVILLE IS INVOLVED IN A STATE RECEIVERSHIP AND EPA's ABILITY TO PAY DETERMINATION, THE CAO DOES NOT ASSESS ANY MONETARY PENALTY. TERMS OF THE AGREEMENT, HOWEVER, DO REQUIRE THAT SEVILLE PERMANENTLY RETIRE ALL VOC AND NOx EMISSION CREDITS WHICH MAY HAVE BEEN GENERATED AS A RESULT OF THE CLOSURE OF ITS TWO PLANTS