Item 3. LEGAL PROCEEDINGS

On July 17, 2019, an Occidental subsidiary received a draft consent agreement and final order from the EPA regarding alleged violations under the CAA and various sections of the EPA’s Chemical Accident Prevention Provisions at the Convent, Louisiana facility. The EPA’s order includes allegations associated with process reviews, procedures and recordkeeping. The EPA’s revised draft settlement proposal includes a civil penalty of $121,457. Occidental is currently negotiating a resolution of this matter with the EPA.

On September 13, 2019, an Occidental subsidiary received a draft consent agreement and final order from the EPA regarding alleged violations under the CAA and various sections of the EPA’s Chemical Accident Prevention Provisions at the Geismar, Louisiana facility. The EPA’s order includes allegations associated with operating procedures, inspections, contractor reviews, medical protocols in the emergency response plan, administrative updates and four historical on-site incidents. The EPA’s revised draft settlement proposal includes a civil penalty of $734,182. Occidental is currently negotiating a resolution of this matter with the EPA.

For information regarding legal proceedings, see the information under the caption “Lawsuits, Claims, Commitments and Contingencies” in the MD&A section of this report and in Note 11 - Lawsuits, Claims, Commitments and Contingencies in the Notes to Consolidated Financial Statements.