CHEVRON U.S.A., INC. ( CHEVRON ), PERFORMS LOADING AND ASSOCIATED OPERATIONS AT ITS MARINE VESSEL LOADING FACILITY LOCATED APPROXIMATELY ONE AND ONE-HALF MILES OFF-SHORE OF THIS PETROLEUMN REFINERY LOCATED IN EL SEGUNDO, CA. THESE OPERATIONS AT THE FACILITY ARE SUBJECT TO THE REQUIREMENTS OF THE SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT RULE 1142 (MARINE TANK VESSEL OPERATIONS). RULE 1142 WAS INCORPORATED BY EPA INTO THE APPLICABLE STATE IMPLEMENTATION PLAN ON DECEMBER 14, 1994. RULE 1142 REQUIRES THAT FOR LOADING AND HOUSEKEEPING EVENTS DURING WHICH EMISSIONS WOULD EXCEED 2 POUNDS OF VOC PER THOUSAND BARRELS ( LBS VOC/10 BBLS ) LOADED, EMISSION MUST BE CONTROLLED BY 95%. ACCORDING TO INFORMATION THAT CHEVRON SUBMITTED IN RESPONSE TO AN EPA INFORMATION REQUEST, CHEVRON ENGAGED IN DOZENS OF LOADING AND CLEANING EVENTS WHICH WERE SUBJECT TO THE CONTROL REQUIREMENTS OF RULE 1142 BUT CHEVRON DID NOT CONTROL THE EMISSION FROM THOSE EVENTS. INSTEAD, CHEVRON RELIED ON AN EMISSIONS TRADING RULE, RULE 1610, WHICH ALLOWED CHEVRON TO PURCHASE EMISSIONS REDUCTION CREDITS ( ERCS ) IN LIEU OF INSTALLING CONTROLS. RULE 1610 HAS NOT BEEN APPROVED BY EPA INTO THE SIP. IN ADDITION, AN EMISSIONS TEST PERFORMED BY CHEVRON'S CONTRACTOR AT THE FACILITY S