<NATURE OF THE CASE> AMOCO OIL COMPANY OWNS AND OPERATES A PETROLEUM RE- FINERY IN YORKTOWN, VA. THE FACILITY USES EQUIPMENT THAT PRODUCES GREATER THAN 1000 MEGAGRAMS OF BENZENE PER YEAR. THE PLANT IS SUBJECT TO THE NATIONAL EMISSION STANDARD FOR EQUIPMENT LEAKS OF BENZENE (40CFR/SUBPART J), AND THE NATIONAL EMISSION STANDARD FOR EQUIPMENT LEAKS (SUBPART V). . <CAUSE OF ACTION> AMOCO HAS VIOLATED SEVERAL PROVISION OF SUBPARTS J & V OF THE NESHAP REGULATIONS, AS FOLLOWS: . 1/ COMPANY FAILED TO SUBMIT AN INITIAL SOURCE REPORT WITHIN 90 DAYS AFTER PROMULGATION OF THE APPLICABLE REGS, IN VIOLATION OF 40CFR/61.10 AND 61.247. THE REPORT WAS RECEIVED NEARLY 2 MONTHS LATE AND WAS INCOMPLETE. 2/ COMPANY FAILED TO MARK CERTAIN PIECES OF EQUIPMENT IN BENZENE SERVICE, IN VIOLATION OF 40CFR/61.242-1(D). 3/ AMOCO FAILED TO CERTIFY IN ITS INITIAL REPORT THAT IT WAS IMPLEMENTING THE REQUIRED TESTING, RECORDKEEPING, AND REPORTING REQ'S, IN VIOLATION OF 40CFR/61.247(A). 4/ AMOCO SUBMITTED ITS FIRST SEMIANNUAL REPORT- DUE MARCH85- OVER ONE MONTH LATE AND ITS SECOND SEMIANNUAL REPORT- DUE SEPT85- OVER ONE MONTH LATE, IN VIOL. OF 40CFR/61.247(B). BOTH REPORTS WERE SUBMITTED ONLY