SUN COMPANY, INC. AND ITS SUBSIDIARY, SUN REFINING AND MARKETING, HAVE COMMITTED SEVERAL VIOLATIONS OF THE CLEAN AIR ACT DURING 1990 AND 1991, AT THEIR PHILADELPHIA REFINER- IES. THIS REFERRAL SEEKS INJUNCTIVE RELIEF AND PENALTIES FOR DEFENDANT'S FAILURE TO OBTAIN A PROPER PSD PERMIT AND VIOLATIONS OF RULES REGARDING EMISSIONS OF PARTICULATE MATTER, VOCS, NOX, AND SO2. CIVIL COMTEMPT TO ENFORCE CD SENT TO DOJ 09/30/97.