ATLANTIC RICHFIELD COMPANY OWNS AND OPERATES A PETROLEUM REFINERY IN CARSON, CALIFORNIA. THE PETROLEUM STORAGE VESSELS AT THE REFINERY CONTAIN PETROLEUM LIQUIDS IN VARIOUS FORMS SUCH AS GASOLINE AND CRUDE OIL. TWO OF THE VESSELS, WHICH STORAGE GASOLINE, ARE SUBJECT TO NEW SOURCE PERFORMANCE STANDARDS SET FORTH IN 40 C.F.R. PART 60, SUBPART KA WHICH REQUIRE THAT CERTAIN TANKS EQUIPPED WITH EXTERNAL FLOATING ROOFS BE EQUIPPED WITH A COVER, SEAL OR LID WHICH IS TO BE MAINTAINED IN A CLOSED POSITION AT ALL TIMES (I.E. NO VISIBLE GAP) EXCEPT WHEN THE DEVICE IS IN ACTUAL USE. THESE THREE STORAGE VESSELS HAVE SLOTTED GUIDE-POLES THAT EXTEND THROUGH AN OPENING IN THE ROOFS OF THE VESSELS. THE SLOTS IN THE GUIDE-POLES ARE VISIBLE GAPS THAT VIOLATE NSPS SUBPART KA. REGION 9 HAS PROPOSED A BOTTOM LINE PENALTY OF $179,200. THE REGION WILL ALSO SEEK INJUNCTIVE RELIEF REQUIRING ARCO TO REMEDY THE VISIBLE GAP PROBLEMS AT ITS THREE STORAGE VESSELS SUBJECT TO NSPS SUBPART KA. ADDITIONALLY, THE REGION WILL SEEK TO HAVE ARCO RETROFIT TANKS EQUIPPED WITH SLOTTED GUIDE-POLES THAT ARE NOT SUBJECT TO NSPS SUBPART KA WITH EMISSION CONTROL DEVICES, EITHER AS A PART OF A COMPREHENSIVE INJUNCTIVE RELIEF PACKAGE (SUCH RETROFITTING COULD COMPENSATE FOR PHASED-IN COMPLIANCE WITH SUBPART KA AT THESE THREE VESSELS, AND THUS BE JUSTIFIED AS PART OF INJUNCTIVE RELIEF) OR AS A