CAMPBELL SOUP COMPANY OWNS AND OPERATES A FACILITY IN SACRAMENTO, CALIFORNIA THAT MANUFACTURES THREE-PIECE CANS FOR THE PACKAGING OF VARIOUS FOOD PRODUCSTS SUCH AS SOUPS AND VEGETABLE JUICES. THE CAN MANUFACTURING PROCESS CONSISTS OF TWO OPERATIONSK, SHEET COATING AND CAN ASSEMBLY. ENAMEL COATING AND SEALING COMPOUNDS ARE APPLIED DURING THE CAN ASSEMBLY. APPLICATION AND CURING OF THE ENAMEL COATING AND SEALING COMPOUNDS CAUSE THE EMISSION TO THE ATMOSPHERE OF VOLATILE ORGANIC COMPOUNDS ( VOCS, ALSO KNOWN AS REACTIVE ORGANIC COUMPOUNDS, ROCS ), WHICH ARE PRECURSORS TO GROUND LEVEL OZONE. BETWEEN 1980 AND 1988, CAMPBELL SOUP COMMENCED AND COMPLETED CONSTRUCTION OR MODIFICATION AND BEGAN OPERATION OF THE FOLLOWING EQUIPMENT AT THE FACILITY: COMPOUND APPLICATOR; THE ULTRAVIOLET COATING LINE; AND CAN ASSEMBLY LINES. CAMPBELL SOUP MODIFIED THE CAN ASSEMBLY PROCESS AT ITS FACILITY BETWEEN 1980 AND 1988 WITHOUT OBTAINING ATCS FROM SMAQMD. THE MODIFICATIONS RESULTED IN VOC EMISSION INCREASES AT THE FACILITY THAT EXCEEDED THE NSR THRESHOLD. SMAQMD ISSUED AN ATC FOR THE MODIFICATIONS IN 1992. HOWEVER, ATC DID NOT REQUIRE CAMPBELL SOUP TO INSTALL EQUIPMENT THAT COMPLIED WITH BACT, OR TO OBTAIN OFFSETS. EPA HAS DETERMINED THAT CAMPBELL SOUP VIOLATED SMAQMD RULES 50 AND 201 BY CONSTRUCTING AND OPERATING THE UV COATING LINE AND BODYMAKERS WITHOUT FI