WITCO CORPORATION (FORMERLY WITCO CHEMICAL CORPORATIONS, WITCO ) IS A LARGE CHEMICAL MANUFACTURER BASED IN NEW YORK, NEW YORK AND OWNS AND OPERATES AN OIL REFINERY IN OILDALE, CALIFORNIA A TOWN IN THE SAN JOAQUIN VALLEY NEAR BAKERSFIELD WITCO OPERATES A GAS TURBINE COGENERATION SYSTEM (THE FACILITY ) TO SUPPLY BOTH STEAM AND ELECTRIC POWER AT THE REFINERY. WITCO ALSO SELLS ELECTRIC POWER TO PACIFIC GAS AND ELECTRIC COMPANY. WITCO APPLIED FOR A PREVENTION OF SIGNIFICANT DETERIORA- TION ( PSD ) PERMIT FOR THE GAS FIRED TURBINE COGENERATION SYSTEM ON APRIL 6, 1983. THE EPA ISSUED THE PERMIT ON NOVEMBER 2, 1983. THE QUARTERLY OPERATION REPORT SUBMITTED BY WITCO FOR THE MONTHS OF JULY 1989 THROUGH SEPTEMBER 1989, JANUARY 1990 THROUGH MARCH 1990 AND JANUARY 1991 THROUGH MARCH 1991, DOCUMENT THAT WITCO VIOLATED THE OXIDES OF NITROGEN EMISSION LIMIT BASED ON A 24 HOUR AVERAGE TWENTY EIGHT TIMES DURING THOSE THREE QUARTERS. WITCO'S REPEATED EXCESS EMISSIONS WERE CAUSED BY THE WATER INJECTION SYSTEM (THE NOX POLLUTINO CONTROLS) CONTINUALLY BREAKING DOWN. THIS PATTERN OF REPEATED BREAKDOWN AND WITCO'S OPERATING THE TURBINE WITHOUT AIR POLLUTION CONTROLS FOR AS LONG AS 15 DAYS BECAUSE OF THE BREAKDOWNS IS ALSO A VIOLATION OF THE REQUIREMENT OF THE NEW SOURCE PERFORMANCE STANDARD CO