1. SECTION 113(D) OF THE CLEAN AIR ACT ( CAA ), AS AMENDED, 42 U.S.C. SEC. 7413(D). 2. CITGO PETROLEUM CORPORATION 4401 LOUISIANA HWY. 108 LAKE CHARLES, LOUISIANA 3. RESPONDENT VIOLATED THE NESHAP AND VHAP REGULATIONS OF THE CAA BY OPERATING VALVES THAT WERE FOUND TO HAVE ENDS THAT WERE NOT EQUIPPED WITH A SECONDARY VALVE, PLUG OR FLANGE AND A VALVE THAT WAS NOT EQUIPPED WITH A CLOSED- PURGE OR CLOSED-VENT SYSTEM. 4. RELIEF SOUGHT PURSUANT TO SECTION 113(D) OF THE CAA, EPA PROPOSES A PENALTY OF $75,000.00.