1. SECTION 113 OF THE CLEAN AIR ACT ( CAA ). 2. WILLAMETTE INDUSTRIES, INC., AN OREGON CORPORATION HIGHWAY 335, LINCOLN PARISH ROAD SIMSBORO, LINCOLN PARISH, LOUISIANA 71275 3. RESPONDENT WAS IN VIOLATION OF SECTIONS 110, PART C, AND 165 OF THE CAA BY 1) FAILING TO OBTAIN PSD PERMITS FOR MAJOR MODIFICATIONS TO EMISSION SOURCES, 2) FAILING TO INSTALL BEST AVAILABLE CONTROL TECHNOLOGIES (BACT) FOR VOCS, NOX, CO, AND PM, AS REQUIRED BY THE PSD RULES, 3) FAILING TO COMPLETELY AND ACCURATELY REPORT THE TYPES AND QUANTITIES OF EMISSIONS ASSOCIATED WITH OPERATIONS AS RE- QUIRED, AND 4) FAILING TO COMPLY WITH FEDERALLY ENFORCE- ABLE STATE PERMIT EMISSIONS LIMITS ISSUED UNDER THE LA. AND AR. SIPS. 4. RELIEF SOUGHT PURSUANT TO SECTION 113 OF THE CAA, EPA RE- FERRED THIS DIRECT REFERRAL TO DOJ FOR INTIATION OF AN ENFORCEABLE CIVIL ACTION. EPA IS SEEKING INJUNCTIVE RE- LIEF REQUIRING THE RESPONDENT TO CORRECT THE VIOLATIONS BY OBTAINING THE NECESSARY PSD AND/OR SIP PERMITS, IN- STALL THE NECESSARY CONTROL EQUIPMENT REQUIRED BY THOSE PERMITS, AND PAY A SIGNIFIANT CIVIL PENALTY THAT RECOVERS THE ECONOMIC BENEFIT OF NONCOMPLIANCE AND REFLECTS THE GRAVITY OF THE ALLEGED VIOLATIONS. 5. NATIONAL COORDINATED EFFORTS: THESE VIOLATIONS WILL BE ADDRESSED IN A NATIONAL CASE TO B