1. THIS CASE IS BEING DEVELOPED AS PART OF THE NATIONAL ENFORCEMENT. 2. SCREEN STRATEGY EFFORT (NESSE), AN OECA EFFORT TO SCREEN LARGE CORPORATIONS WITH MULTIPLE FACILITIES TO DETERMINE COMPLIANCE PROGRAMS. ASHLAND, INC., IS ONE OF THREE CORPORATIONS TARGETED FOR FURTHER REVIEW UNDER NESSE. THE ASHLAND NESSE TEAM FOCUSED ON THE THREE PETROLEUM REFINERIES OPERATED BY ASHLAND IN CATLETTSBURG, KY; CANTON, OH; AND ST. PAUL, MINNESOTA. EPA (REGION 4, REGION 5, AND OECA) PERSONNEL AND NEIC CONDUCTED MULTI-MEDIA INSPECTIONS OF THREE REFINERIES IN FALL 1996. BASED UPON THESE INSPECTION OF THREE REFINERIES IN FALL 1996. BASED UPON THESE INSPECTIONS EPA DETERMINED THAT THERE WERE VIOLATIONS OF CAA, CWA, RCRA, SDWA, AND EPCRA AT CATLETTSBURG, AND CAA, CWA, AND RCRA AT CANTON AND ST. PAUL. EPA IS SEEKING A MAJOR PENALTY FROM ASHLAND FOR THESE VIOLATIONS, ALONG WITH INJUNCTIVE RELIEF THAT SHOULD INCLUDE: BENZENE AND HYDROCARBON