1. SECTION 113(D) OF THE CLEAN AIR ACT ( CAA ), 42 U.S.C. SECTION 7413(D). 2. GATX TERMINALS CORPORATION, A DELAWARE CORPORATION 906 CLINTON DRIVE, P.O. BOX 486 GALENA PARK, HARRIS COUNTY, TEXAS 77547 3. RESPONDENT WAS IN VIOLATION OF SECTION 110 OF THE CAA, (TEXAS STATE IMPLEMENTATION PLAN (SI), SECTION 111 OF THE CAA (NEW SOURCE PERFORMANCE STANDARDS (NSPS), AND SECTION 112 OF THE CAA (NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) BY 1) FAILURE TO SEAL WITH A SEC- OND VALVE, A BLIND FLANGE, A PLUG, OR CAP OPEN-ENDED VALVES IN VOLATILE ORGANIC COMPOUND (VOC ) SERVICE, 2) FAILURE TO PROVIDE NOTIFICATION OF START-UP FOR BOILER NO. 4, AND 3) FAILURE TO PROVIDE QUARTERLY REPORTS OF IN- FORMATION ON BENZENE TRANSFER OPERATIONS. 4. RELIEF SOUGHT PURSUANT TO SECTION 113(D) OF THE CAA, EPA PROPOSED A CIVIL PENALTY OF $160,000 FOR THE VIOLATIONS CITED.