1. SECTION 113 OF THE CLEAN AIR ACT ( CAA ), 42 U.S.C. SECTION 7413. 2. CITGO PETROLEUM CORPORATION (EAST PLANT), 1802 NUECES BAY BLVD., CORPUS CHRISTI, NUECES COUNTY, TEXAS 78407 3. RESPONDENT WAS IN VIOLATION OF SECTIONS 111 & 112 OF THE CAA BY: 1) FAILURE TO DRAIN SEAL MONTHLY; 2) FAILURE TO RECHECK VALVES FOR 2 MONTHS AFTER LEAK; 3) FAILURE TO MONITOR PUMPS TO DETECT LEAKS; 4) FAILURE TO INSPECT PUMPS WEEKLY FOR INDICATIONS OF LIQUIDS DRIPPING FROM PUMP SEALS; 5) FAILURE TO ATTEMPT TO REPAIR LEAKING VALVES WITHIN 5 CALENDAR DAYS AFTER A LEAK WAS DISCOVERED; & 6) FAILURE TO ATTEMPT TO REPAIR LEAKING PUMPS WITHIN 5 CALENDAR DAYS AFTER A LEAK WAS DISCOVERED. RELIEF SOUGHT PURSUANT TO SECTION 113 OF THE CAA, EPA SUBMITTED A DIRECT REFERRAL TO DOJ REQUESTING DOJ TO INITIATE A CIVIL JUDICIAL ENFORCEMENT ACTION AGAINST THE RESPONDENT. EPA IS SEEKING CIVIL PENALTIES FOR PAST REGULATORY AND PERMIT VIOLATIONS & INJUNCTIVE RELIEF.