NATURE OF CASE ON 06/17/82, REGN 2 ISSUED A NOTICE OF VIOLATION TO SHULTZ FOR EMITTING VOLATILE ORGANIC COMPOUNDS IN EXCESS OF MAX PERMITTED UNDER APPLICABLE N.Y. STATE REGULATION, SECTION 228.1, TITLE 6, OFFICIAL COMPILATION OF CODES, RULES & REGULATIONS OF THE STATE OF N.Y.( NYCRR ). SHULTZ OPERATES A MANUFACTURING PLANT IN MANHATTAN AT WHICH COATINGS ARE APPLIED TO METAL FURNITURE. THE PLANT IS A MAJOR SOURCE OF VOLATILE ORGANIC COMPOUNDS (VOC). VOC EMMISIONS ARE PRECURSORS TO CREATION OF PHOTO- CHEMICAL OXIDANTS & OZONE. NEW YORK COUNTY IS NOT ATTAIN- ING THE PRIMARY HEALTH-RELATED STANDARD FOR OZONE(40 CFR SEC.81.333), SO THERE IS PARTICULAR CONCERN ABT VOC COM- PLIANCE HERE & IN N.Y. METROPOLITAN AREA GENERALLY. COATINGS USED CONTAIN CERTAIN ORGANIC SOLVENTS; PRO- CESS IS THEREFORE SUBJECT TO 6 NYCRR PART 228, A PORTION OF THE N.Y. STATE IMPLEMENTATION PLAN (SIP). THE MAX PER- MISSABLE SOLVENT CONTENT OF COATINGS, TABLE I OF REGULA- TION, MAY NOT EXCEED 3.0 LBS PER GALLON OF COATING AT AP- PLICATION. EMISSIONS OF VOC FROM THIS PLANT HAVE BEEN CALCULATED AT NEARLY 2.21 TIMES THE LEVEL ALLOWED-APPROX. 6.64 LBS. VS THE ALLOWED 3.0-THOUGH COMPLIANCE WAS RE- QUIRED BY NO LATER THAN 7/1/80, MORE THAN 2 YRS. AGO. THE ESTIMATED ANNUAL POTENTIAL EMISSIONS OF VOC FROM THIS FACILITY ARE 181 TONS/YR, OF WHICH 55%