1. SECTIONS 309 AND 311(B)(7) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1319 AND 1321(B)(7). 2. CONDEA VISTA COMPANY, A DELAWARE CORPORATION 2201-A OLD SPANISH TRAIL WESTLAKE, CALCASIEU PARISH, LOUISIANA 70669 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) AND 311 OF THE CWA BY: 1) UNAUTHORIZED DISCHARGE OF A POLLUTANT - ETHYLENE DICHLORIDE (EDC); AND 2) DISCHARGES OF POLLU- TANTS IN EXCESS OF NPDES PERMITTED LIMITATIONS. 4. RELIEF SOUGHT PURSUANT TO SECTION 309 OF THE CWA, EPA RE- FERRED THIS DIRECT REFERRAL REQUESTING DOJ TO INITIATE A CIVIL ENFORCEMENT ACTION FOR INJUNCTIVE RELIEF AND OTHER RELIEF AGAINST THE VIOLATOR, CONDEA VISTA COMPANY. THE RESPONDENT HAS OFFERED TO SETTLE THE VIOLATIONS CITED BY PAYMENT OF A CIVIL PENALTY IN THE AMOUNT OF $575,000. THE PROPOSED BOTTOM LINE CIVIL PENALTY IS $94,000. 5. ENVIRONMENTAL JUSTICES ISSUES: AN ENVIRONMENTAL JUSTICE COMPUTER ANALYSIS REVEALS ENVIRONMENTAL JUSTICE (EJ) IS- SUES. THE EJ INDEX REPORTS THAT THE 16.7% PER 50 SQUARE MILES IS OF MINORITY POPULATION, AND THAT 24.1% PER 50 SQUARE MILES IS ECONOMICALLY STRESSED. THE EJ INDEX IS 12 ON THE SCALE OF 1-100, WITH 100 AS THE MOST STRESSED.