CASE SYNOPSIS: CONOCO PIPELNE COMPANY OWNS AND OPERATES A PETROLEUM LIQUID STORAGE AND DISTRIBUTION FACILITY IN DEL CITY, OK. THE FACILITY RECEIVES FUELS BY PIPELINE, STORES THE FUELS IN TANKS, AND DISTRIBUTES THE FUELS TO TANK TRUCKS. FUELS THUS HANDLED INCLUDE GASOLINES AND JET AIRCRAFT FUELS. * THREE FUEL STORAGE TANKS ARE INVOLVED IN THIS ACTION AND HAVE BEEN IDENTIFIED BY CONOCO AS TANKS 103, 105, AND 108. THESE STORAGE TANKS, RESPECIVELY, ARE SUBJECT TO: THE STANDARDS OF PERFORMANCE FOR STORAGE VESSELS FOR PETROLEUM LIQUIDS FOR WHICH CONSTRUCTION, RECONSTRUCTION, OR MODIFI- CATION COMMENCED AFTER JUNE 11, 1973 AND PRIOR TO MAY 19, 1978; THE STANDARDS OF PERFORMANCE FOR STORAGE VESSELS FOR PETROLEUM LIQUID FOR WHICH CONSTRUCTION, RECONSTRUCTION OR MODIFICATION COMMENTED AFTER MAY 18, 1978, AND PRIOR TO JULY 23, 1984; AND THE STANDARDS OF PERFORMANCE FOR VOLATILE ORGANIC LIQUID STORAGE VESSELS FOR WHICH CONSTRUCTION, RECONSTRUCTION, OR MODIFICATION COMMENCED AFTER JULY 24, 1984. * AN EPA INSPECTION PERFORMED AT THE CONOCO FACILITY ON APRIL 7, 1988, NOTED THAT CONOCO OPERATES THE THREE STORAGE TANKS IN VIOLATION OF THE APPLICABLE NEW SOURCE PERFORMANCE STAN- DARDS. EPA SENT A LETTER TO CONOCO,