THE CLEAN AIR ACT U.S. EPA SEEKS A PERMANENT INJUNCTION WHICH WOULD REQUIRE DEFENDANTS TO PROMPTLY COME INTO COMPLIANCE WITH THE APPLICABLE REQUIREMENTS OF THE CLEAN AIR ACT. MORE PARTICU- LARLY, U.S. EPA SEEKS INJUNCTIVE RELIEF FROM DEFENDANTS INCLUDING THE REPLACEMENT THEIR FACILITY'S CONTROL DEVICE, AND THE SUBMISSION AND MAINTENANCE OF VARIOUS REPORTS REQUIRED BY THE HON. SUCH INJUNCTIVE RELIEF SHOULD BRING DEFENDANTS' FACILITY BACK INTO COMPLIANCE WITH ALL APPLICA- BLE LAWS AND REGULATIONS, AND SHOULD REDUCE THE AMOUNT OF UNCONTROLLED VOCS CURRENTLY BEING EMITTED TO THE ENVIRON- MENT. U.S. EPA SEEKS A PENALTY OF NO LESS THAN $652,608 FOR THE VIOLATIONS OF THE CLEAN AIR ACT. THE CLEAN WATER ACT U.S. EPA SEEKS A PERMANENT INJUNCTION WHICH WOULD REQUIRE DEFENDANTS TO PROMPTLY COME INTO COMPLIANCE WITH THE APPLI- CABLE REQUIREMENTS OF THE CLEAN WATER ACT. MORE PARTICULAR- LY, U.S. EPA SEEKS INJUNCTIVE RELIEF TO REQUIRE DEFENDANTS TO DEVELOP AND IMPLEMENT AN SPCC PLAN FOR THEIR FACILITY AND ADJACENT AREAS WHERE DEFENDANTS OPERATE OIL STORAGE TANKS, WHICH MEETS ALL REGULATORY REQUIREMENTS. SUCH INJUNCTIVE RELIEF WOULD REDUCE THE POTENTIAL FOR OIL SPILLS FROM THE DEFENDANTS' FACILTY. U.S. EPA SEEKS A PENALTY OF NO LESS THAN $28,208 FOR THE VIOLATIONS OF THE CLEAN WATER ACT.