THIS IS A PROPOSED CIVIL ACTION UNDER SECT 113 OF THE CAA FOR VIOLATIONS OF RHODE ISLAND POLLUTION CONTROL REGULATION NO. 19 OF THE RHODE ISLAND STATE IMPLEMENTATION PLAN WHICH EPA HAS APPROVED UNDER SECT 110 OF THE CAA. JAY USES PAPER SURFACE COATINGS WHICH CONTAIN MORE VOLATILE ORGANIC COM- POUNDS (VOC) THAN THE EMISSION LIMIT FOR PAPER SURFACE COAT- ING PROCESSES IN RI'S SIP ALLOWS. RH'S SIP LIMITS VOC EMIS- SIONS FROM PAPER COATING LINES TO 2.9 LBS. OF VOC PER GAL. OF COATING (MINUS WATER). JAY USES COATINGS WHICH CONTAIN BETWEEN 3.71 & 6.25 LBS. OF VOC. THE COATING LINES ON WHICH JAY USES THESE COATINGS DO NOT HAVE ANY POLLUTION CONTROL E- QUIPMENT TO CONTROL THE VOC EMISSIONS. IF THIS CASE DOES NOT SETTLE, THE REGION ANTICIPATES THAT LITIGATION WOULD CONSUME SUBSTANTIAL ATTORNEY AND TECHNICAL SUPPORT TIME.