NATURE OF CASE: AMERICAN CYANAMID COMPANY OWNS AND OPERATES A CHEMICAL PLANT IN WESTWEGO, LOUISIANA WHICH IS IN VIOLATION OF THE LOUISIANA SIP REGULATION 22.3, WHICH IS AN EQUIPMENT STAN- DARD. AMERICAN CYANAMID PRODUCES ACRYLONITRILE (ACN) AND STORES IT IN 13 FIXED ROOF STORAGE TANKS WHICH ARE NOT EQUIPPED WITH ANY OF THE CONTROL DEVICES LISTED IN LOUISIANA REGULATION 22.3. REGULATION 22.3 REQUIRES THAT TANKS WHICH STORE VOC WITH GREATER THAN 40,000 GALLON CAPACITY BE EQUIPPED WITH AN INTERNAL FLOATING ROOF, AN EXTERNAL FLOATING ROOF OR A VAPOR RECOVERY SYSTEM. EACH OF THESE 14 TANKS ARE FIXED INSTALLED WITHOUT AN INTERNAL FLOATING ROOF AND VENT DIRECTLY TO THE ATMOSPHERE, THUS, A VIOLATION OF LOUISIANA REGULATION 22.3. AMERICAN CYANAMID IS LOCATED IN JEFFERSON PARISH WHICH IS CLASSIFIED AS NON ATTAINMENT FOR OZONE. VOC EMISSIONS ARE A PRECURSOR TO THE FORMATION OF OZONE, WHICH IS FORMED WHEN VOC IS COM- BINED WITH NITROGEN OXIDES IN THE PRESENCE OF SUNLIGHT. EPA ISSUED A SECTION 120 NOTICE OF NONCOMPLIANCE TO AMERICAN CYANAMID ON SEPTEMBER 28, 1984. CAUSE OF ACTION: AMERICAN CYANAMID'S STORAGE TANKS ARE NOT PROPERLY CONTROLLED AS REQUIRED BY THE LOUISIANA SIP. BECAUSE IT IS A MAJOR SOURCE, SECTION 120 OF THE CLEAN AIR ACT AUTHORIZES EPA TO IMPOSE AN ASSESSMENT ON THE S