THIS IS A CIVIL JUDICIAL REFERRAL PURSUANT TO CLEAN AIR ACT SECTION 608 IN RELATION TO EIGHT INTERSTATE BRANDS CORPORATE FACILITIES. THE VIOLATIONS INVOLVE FAILURE TO REPAIR REF- RIGERANT LEAKS OR CONDUCT PROPER INITIAL AND FOLLOWUP TESTS AS REQUIRED BY 40 CFR 82.156, FAILURE TO KEEP RECORDS AS REQUIRED BY 40 CFR 82.166(K), FAILURE TO PREPARE RETROFIT PLANS, OR TO RETROFIT AND REPLACE LEAKING INDUSTRIAL REFRIG- ERATION UNITS, FAILURE TO REGISTER RECAPTURE EQUIPMENT, AND USE OF IMPROPER REFRIGERANT. IN ADDITION TO A CIVIL PENALTY, INJUNCTIVE RELIEF WILL REQUIRE INTERSTATE TO RETROFIT OR REPLACE ANY INDUSTRIAL PROCESS EQUIPMENT EXCEEDING THE ANNUAL 35% LEAK RATE, COMPLY WITH THE RECORD KEEPING REQUIRMENTS IN SUBPART F OF PART 82, AND REPLACING THE -409A CURRENTLY IN USE WITH A REFRIGERANT THAT IS APPROVED FOR USE IN INDUSTRIAL PROCESS EQUIPMENT. THIS REFERRAL IS PART OF A NATIONWIDE ENFORCEMENT ACTION.