THIS REFERRAL IS REQUESTED AGAINST THE HOLLY CORPORATION'S MONTANA REFINING COMPANY FOR ALLEGED VIOLATIONS OF THE CLEAN AIR ACT AS PART OF THE NATIONAL PETROLEUM REFINERY INITIATIVE. IN AUGUST 2001, NAVAJO REFINING AND MONTANA REFINING COMPANY, SUBSIDIARIES OF HOLLY CORPORATION AND EPA PARTICIPATED IN A MEETING IN DALLAS TO DISCUSS A NATIONAL RESOLUTION OF REQUIREMENTS RELATED TO PREVENTION OF SIGNIFICANT DETERIORATION (PSD), NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR BENZENE WASTE, AND LEAK DETECTION AND REPAIR. REGION 8 HAS NOT CALCULATED A CIVIL PENALTY FOR POTENTIAL CAA VIOLATIONS SINCE WE DID NOT UNDERTAKE AN INVESTIGATION OF SUCH VIOLATIONS.