1. SECTION 113(B) OF THE CLEAN AIR ACT (CAA), 42 U.S.C. SECTION 7413(B). 2. PAN PACIFIC PRODUCTS DBA DOMINANCE INDUSTRIES, INC. ROUTE 4, BOX 371 BROKEN BOW, MC CURTAIN COUNTY, OKLAHOMA 74728 3. RESPONDENT WAS IN VIOLATION OF SECTIONS 110 AND 165 OF THE CAA BY 1) FAILURE TO OBTAIN AN ACCURATE AND APPROPRIATE PREVENTION OF SIGNIFICANT DETERIORATION (PSD) PERMIT FOR START-UP OF A NEW FACILITY AND FAILING TO INSTALL BEST AVAILABLE CONTROL TECHNOLOGY (BACT) FOR VOCS, AS REQUIRED BY THE PSD RULES; AND 2) EXCEEDING THE PERMITTED VOC EMISSION LIMITS IN 1997 AND 1998 ON TWO SEPARATE UNITS. 4. RELIEF SOUGHT PURSUANT TO SECTION 113(B) OF THE CAA, EPA SUBMITTED A DIRECT REFERRAL REQUESTING DOJ TO INITIATE A CIVIL ENFORCEMENT ACTION AGAINST PAN PACIFIC. EPA IS SEEKING INJUNCTIVE RELIEF AND A PROPOSED PENALTY OF $8,041,904.