THIS REFERRAL SEEKS INJUNCTIVE RELIEF AND CIVIL PENALTIES AS AUTHORIZED BY SECTION 113(B) (1) AND (2) OF THE CAA, 42 USC 7413(B)(1) AND (2), FOR VIOLATION OF A REQUIREMENT OF AN APPLICABLE IMPLEMENTATION PLAN MORE THAN 30 DAYS AFTER ISSUANCE OF A NOV; AND FOR VIOLATION OF A COMPLIANCE ORDER ISSUED PURSUANT TO SECITON 113(A) OF CAA, 42 USC 7413(A). ON 10/29/85, EPA ISSUED A SECTION 113 NOV TO KAISER ALUMINUM AND CHEMICAL FOR DOCUMENTED VIOLATIONS OF THE FEDERALLY APPROVED STATE OPACITY STANDARDS. SUBSEQUENT VIOLATIONS WERE OBSERVED 11/5 AND 12/5/85. ON 1/16/86, EPA ORDERED KAISER TO COMPLY FULLY WITH THE 20% OPACITY LIMITATION BY 2/1/86. SINCE THAT DATE, KAISER HAS CONTINUED TO VIOLATE THIS PROVISION OF THE STATE IMPLEMENTA- TION PLAN AS DOCUMENTED BY NOV'S ISSUED BY SCAPCA AND SUPPORTED BY COMPANY OPACITY CHARTS WHICH INDICATE EXCESSIVE EMISSIONS ON A MUCH MORE FREQUENT BASIS.