1. SECTION 113 OF THE CLEAN AIR ACT ( CAA ), 42 U.S.C. SEC- TION 7413. 2. ULTRAMAR DIAMOND SHAMROCK, A DELAWARE CORPORATION STAR ROUTE 1 (L.P. MCKEE PLANT) SUNRAY, MOORE COUNTY, TEXAS 79086 3. RESPONDENT WAS IN VIOLATION OF SECTION 111 OF THE CAA BY FAILING TO IMPLEMENT A LEAK DETECTION AND REPAIR ( LDAR ) PROGRAM ON THE AFFECTED FACILITIES AT ITS SUNRAY, TX. FA- CILLITY BY JAN. 4, 1983 AS WAS REQUIRED. 4. RELIEF SOUGHT PURSUANT TO SECTION 113 OF THE CAA, EPA RE- FERS THIS DIRECT REFRERRAL TO DOJ FOR ENFORCEMENT ACTION SEEKING CIVIL PENALTIES AND POSSIBLY A GRAVITY COMPONENT UNDER THE CAA. EPA IS SEEKING AN ECONOMIC BENEFIT PENALTY OF $285,186 AND MAY SEEK GRAVITY PENALTIES OF $410,000 OR A REDUCED GRAVITY PENALTY OF 25% OF THAT AMOUNT. 5. TECH FOR THE RCRA PORTION IS RALPH FRANKS.