THIS CASE IS THE RESULT OF U.S. EPA'S NAITONAL ENFORCEMENT SCREENING STRATEGY. UNDER THIS EFFORT, EPA, IN A COORDINATED EFFORT BETWEEN HQ AND REGIONS (3, 4, AND 5), ASSESSED THE COMPLIANCE STATUS OF ASHLAND, INC. ACROSS THE COUNTRY. FOLLOWING THAT ASSESSMENT, EPA DETERMINED THAT FURTHER INVESTIGATION OF ASHLAND PETROLEUM WAS APPROPRIATE. SUBSEQUENTLY, EPA CONDUCTED MULTI-MEDIA INSPECTION AT THE THREE REFINERIES LOCATED IN CANTON, OH, ST. PAUL, MN, AND CATLETTSBURG, KY. THIS REFERRAL IS FOR THE FILING OF A CIVIL COMPLAINT FOR VIOLATIONS DISCOVERED PRIMARILY DURING THESE INSPECTIONS. VIOLATIONS OF THE CAA (NSPS, NESHAPS, AND SIP), CWA (311 SPILLS, NPDES EXCEEDANCES, IMPROPER LABORATORY PRACTICES, UNATHORIZED DISCHARGE UNDER 301 AT MN ONLY) AND RCRA (MAINLY MANAGEMENT OF CONTAINERS/TANKS, PAPERWORK, AND INSTANCE OF IMPROPER TREATMENT AT MN AND KY) WERE DISCOVERED AT ALL THREE