CD Settled by ConocoPhiillips (CD originated when company was known as BP/Amoco)
1. SECTION 113 OF THE CLEAN AIR ACT (CAA), 42 U.S.C. SECTION 7413. 2. BP/AMOCO CORPORATION HIGHWAY 23 BELLE CHASSE. PLAQUEMINES PARISH, LOUISIANA 70037 3. RESPONDENT WAS IN VIOLATION OF SECTION 111 AND 112 OF THE CAA BY: 1) FAILURE TO PROPERLY MONITOR VALVES TO DETECT LEAKS IN THE THERMAL HYDRODEALKYLATION UNIT AS REQUIRED; 2) FAILURE TO EQUIP AN OPEN-ENDED VALVE WITH A CAP, BLIND FLANGE, PLUG, OR SECOND VALVE AS REQUIRED; 3) FAILURE TO PROPERLY MONITOR VALVES TO DETECT LEAKS IN THE AROMATICS EXTRACTION UNIT (AEU) AS REQUIRED; 4) FAILURE TO PROPERLY MONITOR PUMPS TO DETECT LEAKS IN THE AROMATICS EXTRACTION UNIT (AEU) AS REQUIRED; 5) FAILURE TO IDENTIFY EACH PIECE OF EQUIPMENT IN THE AEU AS REQUIRED; 6) FAILURE TO EQUIP AN OPEN-ENDED VALVE WITH A CAP, BLIND FLANGE, PLUG, OR A SECOND VALVE LOCATED IN THE AEU AS REQUIRED; 7) FAILURE TO PROPERLY MONITOR COMPONENTS TO DETECT LEAKS IN THE AEU AS REQUIRED; 8) FAILURE TO PROPERLY MONITOR VALVES TO DETECT LEAKS IN THE CATALYTIC REFORMING UNIT (CRU); AND 9) FAILURE TO PERFORM DAILY CALIBRATION DRIFT TESTS ON CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS). 4. RELIEF SOUGHT PURSUANT TO SECTION 113 OF THE CAA, EPA SUBMITTED A DIRECT REFERRAL TO DOJ REQUESITNG PROSECUTORIAL ASSISTANCE FOR CIVIL VIOLATIONS ACTIONABLE UNDER SECTION 113 OF THE CAA AGAINST THE RESPONDENT. EPA IS SEEKING CIVIL PENALTIES AND INJUNCTIVE RELIEF FOR THE VIOLATIONS CITED AT THE FACI