NATURE OF THE CASE VANGUARD OPERATES A MANUFACTURING PLANT IN BROOKLYN, NYC, AT WHICH COATINGS ARE APPLIED TO METAL FURNITURE. THE FACILITY IS LOCATED IN AN AREA WHICH DOES NOT ATTAIN THE PRIMARY AMBIENT STANDARD FOR OZONE AND WHICH HAS AN EXTENDED ATTAINMENT DEADLINE OF 12/31/87. CAUSE OF ACTION THE NY SIP REQUIRES THE OWNER OR OPERATOR OF PROCESSES IN- VOLVING CERTAIN TYPES OF COATING LINES TO SUBMIT A CONTROL PLAN TO THE STATE BY 1/1/80, AND TO ACHEIVE COMPLIANCE BY 7/1/80 WITH A LIMITATION OF 3.0 LBS PER GALLON OF VOLATILE ORGANIC COMPOUND (VOC). VANGUARD HAS NOT SUBMITTED A CONTROL PLAN, AND THE COATINGS CURRENTLY USED AT THE PLANT HAVE AN AVERAGE VOC CONTENT OF 4.8 LBS/GAL. PROPOSED REMEDY VANGUARD IS CURRENTLY INVESTIGATING THE AVAILIBILITY AND FEASIBILITY OF REFORMULATION OF ITS COATINGS AS A COMPLIANCE OPTION. REGION II IS SEEKING TO PLACE THE COMPANY ON AN EXPEDITIOUS COMPLIANCE SCHEDULE AS WELL AS TO REQUIRE PAY- MENT OF $15K-$30K IN CIVIL PENALTIES. NO ISSUES OF NATIONAL OR PRECEDENTIAL SIGNIFICANCE ***** ON 7/24/84, VANGUARD CORPORATION PURCHASED THE ENTIRE 10 JAVA ST. OFFICE FURNITURE MANUFACTURING FACILITY FROM VANGUARD DIVERSIFIED, INC.