S.P. MARKETING LLC, MAJID HUSSAIN PRESIDENT

THIS MEMORANDUM REQUESTS YOUR REVIEW AND SIGNATURE OF 6 CONSENT ORDERS, ATTACHED. THE CONSENT ORDERS ARE EACH A PART OF A “SUPER” CONSENT AGREEMENT AND FINAL ORDER (“SUPER CAFO”) WHICH WAS DEVELOPED BY EPA REGION III TO FORMALIZE INDIVIDUAL SETTLEMENTS PURSUANT TO AN EXPEDITED SETTLEMENT AGREEMENT (“ESA”) STRATEGY. SPECIFICALLY, THE VIOLATIONS BEING SETTLED ARE OF MARYLAND REGULATIONS WHICH CONTAIN THE REQUIREMENTS FOR GAS STATIONS SUBJECT TO THE CLEAN AIR ACTS’S STAGE I AND II VAPOR RECOVERY PROGRAMS, WHICH ARE FEDERALLY ENFORCEABLE THROUGH THE MARYLAND STATE IMPLEMENTATION PLAN (“SIP”). ADDITIONAL SUPER CAFOs WILL FOLLOW IN ADVANCE OF THE END OF OUR FISCAL YEAR. PURSUANT TO THE EXPEDITED SETTLEMENT STRATEGY, EACH VIOLATING FACILITY WAS SENT A STREAMLINE SUPER CAFO WHICH SETS FORTH ALLEGED VIOLATIONS AND A PROPOSED CIVIL PENALTY ASSESSMENT CRITERIA SET FORTH IN SECTION 113(e) OF THE CLEAN AIR ACT, 42 U.S.C. SUBSECTION 7413(e), AND EPA’S OCTOBER 25, 1991 CLEAN AIR ACT STATIONARY SOURCE CIVIL PENALTY POLICY.