1. SECTION 113(D) OF THE CLEAN AIR ACT ( CAA ), 42 U.S.C. SECTION 7413(D). 2. HOWELL HYDROCARBONS & CHEMICALS, INC. 1201 SOUTH SHELDON ROAD P.O. BOX 429 CHANNELVIEW, HARRIS COUNTY, TEXAS 77530-0429 3. RESPONDENT WAS IN VIOLATION OF SECTION 111(E) OF THE CAA BY FAILING TO PROPERLY EQUIP OPEN-ENDED VALVE OR LINES IN VOC SERVICE LOCATED IN THE C-300 UNIT AND FAILING TO PRO- PERLY EQUIP OPEN-ENDED VALVES OR LINES IN VOC SERVICE LO- CATED IN THE SWEET CRUDE UNIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 113(D) OF THE CAA, EPA PROPOSES A CIVIL PENALTY OF $66,000.