1. SECTIONS 110, 111, 112, 113 AND 114 OF THE CLEAN AIR ACT, 42 U.S.C. SECS. 7410, 7411, 7412, 7413 AND 7414; 40 C.F.R. PART 60, SUBPART A OF THE NEW SOURCE PERFORMANCE STANDARDS (NSPS); 40 C.F.R. PART 61, SUBPARTS A, F, V, AND FF OF THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP); AND TEXAS STATE IMPLEMENTATION PLAN (SIP) PERMITS. 2. FORMOSA PLASTICS CORPORATION 201 FORMOSA DRIVE POINT COMFORT, TEXAS 77978 PSD PERMIT NO. PSD-TX-226M-5 & 6 3. FORMOSA WAS IN VIOLATION OF CAA INCLUDING RELEASES OF VINYL CHLORIDE MONOMER AS A RESULT OF INADEQUATE OPERA- TION AND MAINTENANCE PRACTICES, IN VIOLATION OF NESHAP. THERE WERE ALSO RECORD-KEEPING AND REPORTING VIOLATIONS UNDER NESHAP AND UNDER THE STATE SIP PERMIT. 4. RELIEF SOUGHT PURSUANT TO 40 C.F.R. PART 60 AND PART 61, INJUNCTIVE RELIEF IN THE FORM OF NEW PROCEDURES IS RE- QUESTED. ALSO, A CIVIL PENALTY OF AT LEAST $2,171,947.00 IS REQUESTED. 5. DATE REFERRAL WAS SIGNED BY THE RA IS SEPT. 30, 1994.