WHEREAS, the United States alleges that Calcasieu has violated or continues to violate the following statutory and regulatory provisions: 1) New Source Performance Standards (NSPS) found at 40 C.F.R. Part 60, Subparts A and J, promulgated under Section 111 of the Clean Air Act, 42 U.S.C. 7411 (Refinery NSPS Regulations), for fuel gas combustion devices; and 2) Leak Detection and Repair (LDAR) requirements promulgated pursuant to Sections 111 and 112 of the Clean Air Act, and found at 40 C.F.R. Part 60 Subparts VV and GGG; 40 C.F.R. Part 61, Subparts J and V; and 40 C.F.R. Part 63, Subparts F, H, and CC (LDAR Regulations); and 3) Prevention of Significant Deterioration (PSD) requirements found at Part C of Subchapter I of the Clean Air Act (the Act), 42 U.S.C. 7475 and the regulations promulgated thereunder at 40 C.F.R. 52.21 (the PSD Rules); and Plan Requirements for Non Attainment Areas at Part D of subchapter I of the Act, 42 U.S.C. 7502-7503 and the regulations promulgated thereunder at 40 C.F.R. 51.165(a) and (b) and at Title 40, Part 51, Appendix S and at 40 C.F.R. 52.24 (PSD/NSR Regulations), for heaters and boilers for nitrogen oxide (NOx) and sulfur dioxide (SO2); and 4) National Emission Standards for Hazardous Air Pollutants (NESHAP) for Benzene Waste Operations promulgated pursuant to Section 112(e) of the Act, and found at 40 C.F.R. Part 61, Subpart FF (Benzene Waste Operations NESHAP Regulations);WHEREAS, the United States also specifically alleges that, upon inf