1. SECTION 113(D) OF THE CLEAN AIR ACT ( CAA ), AS AMENDED, 42 U.S.C. SECTION 7413(D). 2. TEXACO CHEMICAL COMPANY FM 366 AND HOGABOOM ROAD PORT NECHES, TEXAS 3. RESPONDENT WAS IN VIOLATION OF 40 CFR SECTION 61.242-6(A) IN FOUR SEPARATE INSTANCES BY FAILING TO EQUIP AND SEAL WITH A PLUG OR SIMILAR CLOSURE DEVISE, AT ALL APPROPRIATE TIMES, THE 4 VALVES WHICH WERE IN VHAP/BENZENE SERVICE. IN THE AMENDED COMPLAINT THE RESPONDENT WAS IN VIOLATION OF TACB REGULATION VI, SECTION 116.4 IN 3 SEPARATE IN- STANCES BY FAILING TO EQUIP AND SEAL WITH A CAP, BLIND FLANGE, PLUG, SECOND VALVE, OR SIMILAR CLOSURE DEVICE, AT ALL APPROPRIATE TIMES, THE 3 VALVES WHICH WERE IN BUTA- DIENE SERVICE. 4. RELIEF SOUGHT PURSUANT TO SECTION 113(D) OF THE CAA, EPA PROPOSES A CIVIL PENALTY OF $149,000.