FLEXCON USES PAPER & VINYL SURFACE COATINGS WHICH CONTAIN MORE VOLATILE ORGANIC COMPOUNDS (VOC) THAN THE EMISSION LI- MITS FOR PAPER & VINYL SURFACE COATING IN MASS' SIP ALLOW. MASS' SIP LIMITS VOC EMISSIONS FROM PAPER COATING LINES TO 2.9 LBS VOC PER GAL. OF COATING, LESS WATER, & VINYL COATING LINES TO 3.8 LBS OF VOC PERL. FLEXCON USES PAPER COATINGS WHICH EMIT, ON AVERAGE, 4.4 LBS OF VOC PER GAL., VINYL COAT- INGS WHICH EMIT, ON AVERAGE, 5.9 LBS OF VOC PER GAL. THESE COATING LINES DO NOT HAVE POLLUTION CONTROL EQUIPMENT TO CONTROL THE VOC EMISSIONS. THE SOURCE HAS PROPOSED A REMEDY WHICH ACHIEVES A LARGE REDUCTION IN VOC EMISSIONS, AND MEETS THE PAPER COATING EMISSION LIMIT PLANTWIDE. ALSO, FLEXCON HAS A STRONG EQUITABLE DEFENSE AGAINST PENALTIES, BASED ON THE COMPANY'S GOOD FAITH RELIANCE ON DEQE'S CLASSIFICATION. THEREFORE, REG I RECOMMENDS THAT EPA SETTLE CASE FOR THE BENEFIT COMPONENT OF THE CAA CIVIL PENALTY POLICY ALONE.