MEMORANDUM OPINION AND ORDER
HUDSPETH, District Judge.
This is an action by the United States to recover civil penalties under the Clean Air Act, 42 U.S.C. §§ 7401 et seq. Jurisdiction is founded upon 42 U.S.C. § 7413(b). With leave of Court, the State of Texas and the City of El Paso intervened as Plaintiffs.
Between 1967 and 1977, Chevron contracted with an unrelated corporate entity called El Paso Acid Corporation
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