CIVIL JUDICIAL REFERRAL BASED ON FAILURE TO COMPLY WITH DUST CONTROL AND RELATED REQUIREMENTS IN THE CALIFORNIA STATE IMPLEMENTATION PLAN. IN ADDITION, THE COMPLAINT WILL ALLEGE VIOLATIONS OF SECTIONS 114 AND 113 OF THE CAA, RESPECTIVELY, BASED ON THE FAILURE TO RESPOND TO EPA INFOR- MATION REQUEST AND THE FAILURE TO COMPLY WITH EPA>S ADMIN- ISTRATIVE ORDER REQUIRING COMPLIANCE WITH EPA>S INFORMATION REQUEST. THE COMPLAINT WILL SEEK PENALTIES AND INJUNCTIVE RELIEF.