Primarily alleging violations at the Defendant's facility of the CAA Vinyl Chloride NESHAP, as well as violations of RCRA subtitle C, TSCA-PCB, CWA-SPCC, and EPCRA-313 requirements.
Request that DOJ, pursuant to section 309 of the CWA, seek appropriate relief, including penalties and injunctive relief, against the Defendant for violations of the CWA and or conditions in the New Jersey Pollutant Discharge Elimination System (NJPDES) permit issued to the Defendant under Section 402 of the CWA.