'**VIOLATIONS: 1) Failing to equip open-ended valves or lines with a cap, blind flange, plug, or a second valve; 2) Failing to monitor the components in VV service at the Platformer Unit in accordance with Method 21, resulting in the facility finding a lower leak rate than that found by EPA; 3) Failing to repair equipment in the Platformer Unit subject to the Refinery MACT, resulting in a pump leaking more than 15 days after it was initially found leaking, and 23 days after it was listed as repaired; 4) Failing to monitor 28 components at the Crude unit from the time Subpart CC required compliance with the equipment monitoring provisions until the date of inspection; 5) Failing to monitor 11 components at the Unifiner Unit from the time Subpart CC required compliance with the equipment monitoring provisions until the date of inspection; and 6) Failing to monitor one pump and 32 valves at the Platformer unit from the time 63 Subpart CC required compliance with the equipment monitoring provisions until the date of inspection. **PROPOSED PENALTY: $2,656,000.00; Penalties associated with the specific violations subject to this referral may be included in a larger settlement and or litigation of the national case. INJUNCTIVE RELIEF is requested to address the violations at the Refinery.