1. SECTION 113(A) AND (B) OF THE CLEAN AIR ACT ( CAA ), 42U.S.C. SECTION 7413(A) AND (B).2. CITGO PETROLEUM CORPORATION S I-10 ON LOUISIANA HIGHWAY 108 LAKE CHARLES, CALCASIEU PARISH, LOUISIANA 70602 3. RESPONDENT WAS IN VIOLATION OF SECTIONS 110 AND 165(A)OF THE CAA BY: 1) PREVENTION OF SIGNIFICANT DETERIORATION (PSD) SIGNIFICANCE LEVELS WERE EXCEEDED FOR SO2, NOX, CO AND PM DUE TO MODIFICATIONS AT THE FCCUS; 2) FAILURE TO DO PSD ANALYSES OR PREPARE PERMIT APPLICATIONS FOR THE MODICIATIONS; 3) PERMIT APPLICATIONS WERE BASED ON IN-CORRECT NETTING ANALYSES AND EMISSION LIMITS INCLUDED IN THE ANALYSES HAD BEEN EXCEEDED; 4) USING NOX EMISSION FACTORS RATHER THAN TEST DATA; AND 5) MODIFICATIONS DONE WITHOUT PSD PERMITS.4. RELIEF SOUGHT PURSUANT TO SECTION 113(A) OF THE CAA, EPA SUBMITTED A COORDINATED REFERRAL TO DOJ REQUESTING THE INITIATION OF A CIVIL ENFORCEMENT ACTION AGAINST THE RE-SPONDENT FOR THE VIOLATIONS AT ITS LAKE CHARLES REFINERY.EPA IS SEKING BOTH PENALTIES AND INJUNCTIVE RELIEF TO BRING CITGO BACK INTO COMPLIANCE WITH APPLICABLE FEDERAL AND STATE REQUIREMENTS. 5. THIS CASE IS PART OF THE NATIONAL REFINERY INITIATIVE.