UNION OIL COMPANY OF CALIFORNIA OWNS AND OPERATES TWO PETROLEUM REFINERIES IN CARSON AND WILMINGTON, CALIFORNIA. THE FACILITIES REFINE CRUDE OIL BY VARIOUS PROCESSES INTO PRODUCTS SUCH AS GASOLINE. UNOCAL SUBMITTED AN INITIAL APPLICATION TO SCAQMD FOR PTCS FOR THE RFG PROJECT EQUIPMENT IN MARCH 1993. IN SEPTEMBER 1993, BEFORE UNOCAL RECEIVED A PTC, UNOCAL BEGAN POURING CONCRETE FOUNDATIONS FOR THE RFG PROJECT EQUIPMENT AT THE FACILITIES. UNOCAL REVIEWED PTCS FOR THE RFG PROJECT EQUIPMENT ON NOVEMBER 3 AND 4, 1993. EPA HAS DETERMINED THAT UNOCAL VIOLATED SCAQMD RULES 201 AND 1303 BY COMMENCING ACTUAL CONSTRUCTION ON THE RFG PROJECT AT THE FACILITIES WITHOUT FIRST OBTAINING A PTC FROM SCAQMD. REGION IX WILL ATTEMPT TO RESOLVE THIS CASE AGAINST UNOCAL BY PREREFERRAL NEGOTIATIONS AND HAS PROPOSED A BOTTOM LINE CIVIL PENALTY OF $232,400. SINCE NO INJUNCTIVE RELIEF APPEARS NECESSARY, IT MAY BE POSSIBLE TO NEGOTIATE A CIVIL PENALTY AND A STIPULATED PENALTY IN THIS CASE.