1. SECTION 113(D) OF THE CLEAN AIR ACT ( CAA ), AS AMENDED, 42 U.S.C. SEC. 7413(D), AND SECTION 325(C) OF THE EMERG- ENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT ( EPCRA ), 42 U.S.C. SEC. 11045(C). 2. KERR-MCGEE REFINING CORP. 906 SOUTH POWELL AVENUE WYNNEWOOD, GARVIN COUNTY, OKLAHOMA 73098 3. RESPONDENT WAS IN VIOLATION OF THE CAA BY COUNT 1: FAIL- URE TO EQUIP TWO OPEN-ENDED VALVES IN THE C3/C4 SPLITTER WITH A PLUG OR SECOND VALVE, COUNT 2: FAILURE TO RECORD ALL REQUIRED INFORMATION REGARDING A LEAKING VALVE, COUNT 3: FAILURE TO PERFORM TESTS AND RECORD DATA FOR TWO FU- GITIVE VOC ANALYZERS USED FOR LEAK DETECTION MONITORING, AND COUNT 4: FAILURE TO SUBMIT SEMI-ANNUAL REPORTS CERT- IFYING THAT THE INSPECTIONS REQUIRED BY SUBPART QQQ HAVE BEEN CARRIED OUT. THE RESPONDENT ALSO VIOLATED THE RE- PORTING REQUIREMENTS OF SECTION 313(A) OF EPCRA BY FAIL- ING TO SUBMIT A COMPLETE AND CORRECT FORM R TO THE AD- MINISTRATOR OF EPA AND TO THE STATE OF OKLAHOMA FOR CHROMIUM COMPOUNDS, DIETHANOLAMINE, LEAD COMPOUDS, MANG- ESE COMPOUNDS, AND ZINC COMPOUNDS FOR CALENDAR YEAR 1989. 4. RELIEF SOUGHT PURSUANT TO SECTION 113(D) OF THE CAA AND SECTION 325(C) EPCRA, EPA PROPOSES A CIVIL PENALTY OF $140,000 THE CAA VIOLATIONS AND $85,000 FOR THE EPCRA VIOLATIONS FOR A TOTAL OF $225,00