RICHMOND TANK CAR CO OPERATES A RAILCAR COATING FACILITY IN HOUSTON, HARRIS COUNTY, TEXAS. THIS FACILITY COATS THE IN- TERIORS AND EXTERIORS OF RAILCARS AND STENCILS SOME OF THESE CARS. * RTC'S RAILCAR COATING PROCESS FACILITY IS SBJECT TO TACB REGULATION V, 115.191(9)(A)(III) AND 115.194. RULE 115.191 (9) PRESCRIBES THE MAX AMOUNT OF VOC EMISSIONS ALLOWED FROM THE EXTREME PERFORMANCE SURFACE COATING PROCESS. THIS REGU- LATION HAS BEEN APPROVED BY EPA AS PART OF THE SIP FOR TX. * ON 9/19/84, EPA CONTRACTOR PEDCO ENVIRONMENTAL, INC. IN- SPECTED RTC'S HOUSTON FACILITY TO DETERMINE ITS COMPLIANCE WITH REGULATION V, 115.191(9)(A)(III). ALTHOUGH NO DAILY COATING DATA WAS PROVIDED BY RTC, PROCESS OBSERVATIONS AND PLANT INFO SUPPLIED TO THE INSPECTORS INDICATED THAT THE FAC ILITY WAS SUBJECT TO REGULATION V. SUBSEQUENT COATING DATA WAS SUPPLIED TO EPA ON 6/13/85, IN RESPONSE TO AN INFORMA- TION SUPPLIED BYRTC IN 4/86, IT IS EVIDENT THAT RTS WAS IN VIOLATION OF THE APPLICABLE TEXAS SIP REGULATION FOR MORE THAN 30 DAYS AFTER EPA'S NOV. * REGION 6 PROPOSES THAT A CIVIL PENALTY IN THE AMOUNT OF $75,000 BE ASSESSED AGAINST RTC. FURTHER, IF RTC HAS NOT OBTAINED COMPLIANCE WITH THE REQUIRE