WHEREAS, the United States Complaint against Westlake sought injunctive relief and
civil penalties for alleged violations of Clean Air Act, 42 U.S.C. § 7401 et seq., and regulations
promulgated thereunder including violations of regulations promulgated pursuant to
Section 112(e) of the Act, 42 U.S.C. § 7412(e), and known as the National Emission Standards
for Hazardous Air Pollutants for Source Categories: Generic Maximum Achievable Control
Technology Standards, 40 C.F.R. Part 63, Subpart YY; and violations of the leak detection and
repair requirements (ÂLDAR RequirementsÂ) at 40 C.F.R. Part 63, Subpart UU;