SOUTHERN PACIFIC PIPE LINES OPERATES A GASOLINE BULK TERM- INAL IN FRESNO, CA. FRESNO COUNTY IS A NONATTAINMENT AREA FOR OZONE WHICH RECEIVED AN EXTENSION UNTIL 1987 TO DEMON- STRATE ATTAINMENT. SPPL IS A DELAWARE CORPORATION REGISTER- ED TO DO BUSINESS IN CALIFORNIA AND HAS ITS CORPORATE HQ IN LOS ANGELES. SPPL PIPES GASOLINE FROM VARIOUS LOCATIONS IN CALIFORNIA TO FRESNO, PLACES IT IN STORAGE TANKS AT THE FRESNO FACILITY AND LOADS IT INTO GASOLINE TRUCKS VIA LOADING RACKS FOR TRANSPORT TO GAS STATIONS. SPPL'S FRESNO FACILITY IS ONE OF THE LARGEST GASOLINE BULK TERMINALS IN THE AREA & IS LISTED IN CDS AS A SIGNIFICANT VIOLATOR. SPPL VIOLATED THE CALIFORNIA STATE IMPLEMENTATION PLAN AT ITS FRESNO FACILITY IN THAT ITS VAPOR RECOVERY SYSTEM WHICH CONTROLS VOLATILE ORGANIC COMPOUNDS EMISSIONS WAS OPERATING BELOW THE EFFICIENCY REQUIRED BY FRESNO COUNTY AIR POLLUTION CONTROL DISTRICT RULE 412. SPECIFICALLY, A SOURCE TEST IN AUGUST OF 1984 PERFORMED BY THE CALIFORNIA AIR RESOURCE BOARD SHOWED THAT SPPL'S VAPOR RECOVERY UNIT WAS OPERATING AT 84.7% EFFICIENCY, WHILE DISTRICT RULE 412 REQUIRES 80% EFFICIENCY. EPA ISSUED A NOTICE OF VIOLATION ON MARCH 29, 1985. SUB- SEQUENTLY, ON MAY 30, AN SPPL CONTRACTOR PERFORMED ANOTHER SOURCE TEST ON THE VAPOR RECOVERY UNIT WHICH SHOWED IT STILL TO BE IN VIOLATION, OPERATING AT 82.5% EFFICIENCY. IN ADDITION TO THE SIP VIOLATION, SP