EPA Region 1 (New England) issued a direct referral to the Department of Justice for initiation of a civil judicial action against Solutia Inc. for violations of Section 112 of the Clean Air Act and regulations entitled the National Emission Standards for Hazardous Air Pollutants [NESHAP] for Amino/Phenolic Resins Production (and other rules referenced in the ?A/P NESHAP,? 40 C.F.R. Part 63, Subpart OOO), as well as violations of a Title V Operating Permit, a federally-enforceable construction permit designed to control volatile organic compound (VOC) emissions, and CAA new source performance standards applicable to formaldehyde storage tanks at a former Monsanto plant located in Springfield, Massachusetts. Most of the violations occurred from 2003 to 2010 and arise out of severe shortcomings in the facility?s leak detection and repair (LDAR) program associated with a process line where melamine-formaldehyde resins are made for use in automobile coatings. Region 1 recommends filing a civil complaint for penalties and injunctive relief associated with these violations which include, among others, failing to identify and monitor equipment subject to LDAR requirements, failing to use suitable leak detection devices for monitoring, and failing to report important compliance-related information to EPA. By not meeting LDAR and other regulatory obligations, Solutia?s ability to control HAP and VOC emissions (especially methanol and formaldehyde) was substantially compromised.