AN EPA REVIEW OF THE TOXIC RELEASE INVENTORY REPORTING FORMS (FORM, RS) SUBMITTED BY KOCH REFINING COMPANY FOR CALENDAR YEARS 1989, 1990, AND 1991 RESULTED IN THE PRELIMINARY CON- CLUSION THAT THE NUMBERS SUPPLIED FOR FUGITIVE AIR EMISSIONS WERE UNUSUALLY LOW. ADDITIONAL INFORMATION WAS REQUESTED WITH RESPECT TO THE CALCULATIONS AND SUPPORTING DOCUMENTA- TION, WHICH WAS REVIEWED. THE COMPANY'S EMISSION ESTIMATES FOR SPECIFIED CHEMICALS LISTED UNDER 40 C.F.R. SEC. 372.65, WHICH WERE EITHER MANUFACTURED, IMPORTED, PROCESSED, OR OTHERWISE USED IN QUANTITIES EXCEEDING THE ESTABLISHED TOXIC CHEMICAL THRESHOLDS SET FORTH IN 40 C.F.R.SEC. 372.25, WERE FOUND TO BE INCORRECT AND GROSSLY UNDERESTIMATED. ON JUNE 15, 1994, REGION 6 FILED AN ADMINISTRATIVE COMPLAINT AGAINST KOCH REFINING COMPANY FOR ALLEGED VIOLATIONS OF EPCRA SEC. 313(A) AND 40 C.F.R. SEC. 372.30. THE COMPLAINT SEEKS A PENALTY IN THE AMOUNT OF $585, 000. ADDRESS: SUNTIDE ROAD CORPUS CHRISTI, TX. 78410