1. SECTION 113 OF THE CLEAN AIR ACT (CAA), 42 U.S.C. SECTION 7413. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA), 42 U.S.C. SECTION 6901 ET SEQ. 2. ULTRAMAR DIAMOND SHAMROCK CORP., A DELAWARE CORP. 301 LEROY STREET THREE RIVERS, LIVE OAK COUNTY, TEXAS 78071 3. RESPONDENT WAS IN VIOLATION OF SECTION 111 OF THE CAA BY FAILING TO IMPEMENT A LEAK DETECTION AND REPAIR (LDAR) PROGRAM ON THE AFFECTED FACILITIES AT THE THREE RIVERS,TX. PETROLEUM REFINERY BY JAN. 4, 1983, ASA REQUIRED. RESPONDENT WAS IN VIOLATION OF SECTION 3005(A) BY 1) FAILING TO MEET CONDITIONS OF PERMIT EXEMPTION AT 3 CONTAINER STORAGE AREAS, AND 2) FAILING TO MEET CONDITIONS OF PERMIT EXEMPTION AT 2 SATELLITE ACCUMULATION AREAS. 4. RELIEF SOUGHT PURSUANT TO SECTIONS 113 OF THE CAA AND 3008(A) OF RCRA, EPA REFERS THIS DIRECT REFERRAL TO DOJ SEEKING CIVIL PENALTIES (ECONOMIC BENEFIT) AND POSSIBLY A GRAVITY COMPONENT UNDER THE CAA AND RCRA. 5. THE TECH FOR THE RCRA PORTION OF THIS REFERRAL IS RALPH FRANK, X2249. THE TECH FOR THE CWA PORTION IS TED PALIT.