GEORGIA-PACIFIC CORP CONSTRUCTED SKIPPERS, VA, ORIENTED STRAND BOARD FACILITY IN 1984 WITH MINOR STACK OPERATING PERMIT. TESTING IN 1989 AND SUBSEQUENTLY DEMONSTRATES THAT THEY WERE SUBJECT TO FEDERAL PSD REGULATIONS FROM CONSTRUC- TION. THEY APPLIED FOR A PSD PERMIT IN OCTOBER 1990 PURSUANT TO A CONSENT AGREEMENT AND ORDER WITH VIRGINIA. HOWEVER, APPLICATION WAS DEEMED INCOMPLETE BECAUSE OF, AMONG OTHER THINGS, FAILURE TO PROPERLY ANALYZE AND PROPOSE BEST AVAILABLE CONTROL TECHNOLOGY ( BACT ). FACILITY REMAINS UNPERMITTED TO DATE. SUIT SEEKS ACTIONS TO COMPLETE PERMIT AND INSTALL BACT. ALSO SEEKS PENALTIES FOR FAILURE TO OBTAIN PSD PERMIT.