1. SECTION 113 OF THE CLEAN AIR ACT (CAA), 42 U.S.C SECTION 7413. 2. AMOCO OIL COMPANY 2401 5TH AVENUE SOUTH TEXAS CITY, TEXAS 77590 3. IN JAN. AND MAR.1996, EPA'S NATIONAL ENFORCEMENT INVESTIGATIONS CENTER CONDUCTED A MULTI-MEDIA INSPECTION OF AMOCO'S PETROLEUM REFINERY IN TEXAS CITY, TEXAS. DURING THE COURSE OF THE INSPECTION, SEVERAL VIOLATIONS OF SECTION 111 AND 112 OF THE CAA AND THE STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES (NSPS), AND NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) FOR BENZENE, RESPECTIVELY WERE NOTED. THE VIOLATIONS INCLUDE: 1) FAILING TO INCLUDE EXCEEDANCES OF THE ALLOWABLE H2S ON 5 QUARTERLY EXCESS EMISSIONS REPORTS (EERS), 2) EXCEEDING THE COMPLIANCE OPTION BY THE UNCONTROLLED RELEASE OF BENZENE, 3) EXCEEDING THE REGULATORY EXEMPTION FOR THE QUANTITY OF BENZENE ENTERING THE ACTIVATED SLUDGE UNIT, 4) FAILING TO SUBMIT QUARTERLY CERTICATIONS WITH REGARDS TO INSPECTION OF BENZENE NESHAP CONTROLLED EQUIPMENT IN A TIMELY MANNER, AND 5) 20 OPEN-ENDED VALVES NOT EQUIPPED WITH A CAP, BLIND FLANGE, PLUG, OR A SECOND VALVE. 4. RELIEF SOUGHT PURUSUANT TO SECTION 113 OF THE CAA, EPA REFERRED THIS CASE OT DOJ FOR CIVIL ACTION. THE RELIEF SOUGHT IS A CIVIL PENALTY AND INJUNCTIVE RELIEF REQUIRING AMOCO TO CORRECT THE VIOLATIONS.