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production system, the carbonation system, the sugar drying and cooling system, the product finishing and storage facilities, and the beet pulp drying and storage facilities. On October 7, 1973 a Federal Environmental Protection Agency inspector observed emissions in violation of the District's Rule. 401 (Visible Emissions) emanating from Spreckels beet pulp drier. The violation was forwarded to the District for enforcement action. The District informed Spreckels that air pollution law provided for variances to provide time extensions for sources to achieve compliance. Spreckels applied for a variance which was granted by the Rearing Board on December 27, 1973. Subsequently, Spreckels installed particulate scrubbers on the beet pulp drier stacks. The scrubbers were tested on September 24, 1974 and shown to comply with the District's particulate matter emission standards. In 1974 the District's Regulation II became effective. Regulation II requires the owna= or operator of any equipment, process, or other source which has a potential to emit air contaminants into the air to obtain a Permit to Overate from the District. Therefore, Spreckels was requested to file the ap=or—riate permit applications with the District. Each process and article of eoui=ent was evaluated to determine that tha resultant emissions did not violate the District's emission standards. Subsequently, the District issced the required Permits to Operate the various sources of emissions. In conjunction with the permit regulation, the District instituted a program of scheduled inspections to determine that equipment and processes were being operated as specified in the applications submitted by the sources and to assure that proper maintenance was being performed to prevent viola— tions of the District's emission standards from occurring. Inspections and (7)