1. SECTION 112 OF THE CLEAN AIR ACT ( CAA ), 42 U.S.C. SEC- TION 7412. 2. LYONDELL PETROCHEMICAL COMPANY 12000 LAWNDALE HOUSTON, HARRIS COUNTY, TEXAS 77001 3. ON SEPT. 25, 1992, EPA REGION 6 COMMENCED A MULTI-MEDIA INSPECTION OF LYONDELL'S HOUSTON, TX. REFINERY. THE ONE WEEK INSPECTION INCLUDED A REVIEW OF THE REFINERY'S COM- PLIANCE WITH THE CAA, CWA, AND RCRA. VIOLATIONS OF BOTH THE CAA AND RCRA WERE IDENTIFIED; HOWEVER, THE RCRA VIO- LATIONS HAVE BEEN RESOLVED BY REGION 6 WITH THE ISSUANCE OF AN ADMINISTRATIVE COMPLAINT TOGETHER WITH A CONSENT A- GREEMENT AND CONSENT ORDER ASSESSING A $41,000 PENALTY FOR THE RCRA VIOLATIONS. THE ONLY OTHER VIOLATIONS IDENT- IFIED BY EPA REGION 6 THAT REQUIRES A FORMAL ENFORCEMENT RESPONSE RELATES TO THE CAA. THE EPA INSPECTORS IDENTIFI- ED SEVERAL POTENTIAL VIOLATIONS OF SECTION 112 OF THE CAA RELATING TO LYONDELL'S BENZENE PRODUCTION OPERATIONS AND ASBESTOS HANDLING PRACTICES. SUBSEQUENT INFORMATION RE- QUESTS AND MEETINGS WITH LYONDELL HAVE CONFIRMED THE VIO- LATIONS (AS WELL AS THEIR CORRECTION) WHICH ARE ADDRESSED IN THIS CIVIL LITIGATION REPORT. THE BENZENE VIOLATIONS DISCUSSED HEREIN RELATE TO LYON- DELL'S PRODUCTION OF HIGH PURITY AROMATIC STREAMS. AT THE TIME OF THE EPA INSPECTION IN 199