THE CASE ALLEGES VIOLATIONS OF THE RHODE ISLAND STATE IMPLEMENTATION PLAN (SIP) UNDER THE CLEAN AIR ACT (CAA). EPA'S CLAIMS STEM FROM NONCOMPLIANCE AT THE SEVILLE PLANT LOCAED AT 229 FIRST AVENUE IN WOONSOCKET (THE FACILITY). THE VIOLATIONS RESULTED IN AN EPA NOTICE OF VIOLATION (NOV) AND REPORTING REQUIREMENT ISSUED TO SEVILLE ON AUGUST 15, 2001. THE RESULTS OF THAT INVESTIGATION SHOWED SEVILLE VIOLATED FEDERALLY-ENFORCABLE REQUIREMENTS WITHIN THE RHODE ISLAND STATE IMPLEMENTATION PLAN OR SIP . SPECIFICALLY, SEVILLE HAD VIOLATED THE FOLLOWING: RI REGULATION 9 (FOR FAILING TO OBTAIN A MAJOR NSR PERMIT WHEN SEVILLE CHANGED VOCS IN 1996 AND INCREASED POTENTIAL AND ACTUAL VOC USE, FAILINGTO MEET FUEL OIL USAGE LIMITS IN 1999 AND 2001 UNDER AN EXISTING DEM PERMIT FOR BOILERS, AND FAILING TO OBTAIN A MINOR PERMIT WHEN THE #4 PRINTER/FLOCKER WAS INSTALLED IN 1998) RI REGUALTION 15 (FOR FAILING TO COMPLY WITH VOC RACT (REASONABLY AVAILABLE CONTROL REQUIREMENTS) TRIGGERED BY THE 1996 VOC CHANGEOVER), AND RI REG 27 (FOR FAILURE TO COMPLY WITH NOX RACT RECORD KEEPING REQUIREMENTS FOR BOILER TUNE-UP AND FAILING TO NOTIFY DEM WHEN FUEL USE LIMITS WERE EXCEEDED.