1. SECTION 113 OF THE CLEAN AIR ACT ( CAA ), 42 U.S.C. SEC- TION 7413. 2. AIR LIQUIDE AMERICA CORPORATION 13140 TI BOULEVARD DALLAS, DALLAS COUNTY, TEXAS 75243 3. RESPONDENT WAS IN VIOLATION OF SECTION 608 OF THE CAA BY: 1) FAILURE TO REPAIR REFRIGERANT LEAKS TO KEEP THE RATES BELOW THE REQUIRED 35% AS REQUIRED; 2) FAILURE TO DO INI- TIAL LEAK VERIFICATION TESTS AS REQUIRED; 3) FAILURE TO DO FOLLOW-UP LEAK VERIFICATION TESTS AS REQUIRED; 4) FAILURE TO PREPARE A RETROFIT AND REPLACEMENT PLAN IN AC- CORDANCE; 5) FAILURE TO IMPLEMENT THE RETROFIT AND RE- PLACEMENT PLAN WITHIN ONE YEAR; AND 6) FAILURE TO REPORT FAILED FOLLOW-UP LEAK VERIFICATION TESTS AS REQUIRED. 4. RELIEF SOUGHT PURSUANT TO SECTION 113 OF THE CAA, EPA SUBMITTED A DIRECT REFERRAL TO DOJ REQUESTING PROSECUTOR- IAL ASSISTANCE FOR THE VIOLATIONS AT THE FACILITY. EPA IS SEEKING INJUNCTIVE RELIEF AND A CIVIL PENALTY OF $282,300 FOR THE VIOLATIONS CITED.