NATURE OF THE CASE GLENMORE OWNS AND OPERATES A PLANT IN BROOKLYN, NY, WHICH APPLIES COATINGS TO VINYL FABRICS. THE SOURCE IS LOCATED IN A PRIMARY NON-ATTAINMENT AREA FOR OZONE. CAUSE OF ACTION THE NY STATE IMPLEMENTATION PLAN REQUIRES AN OWNER OR OPERATOR OF PROCESSES INVOLVING CERTAIN TYPES OF COATING LINES TO SUBMIT A CONTROL PLAN TO THE STATE BY 1/1/80, AND TO ACHIEVE COMPLIANCE BY 7/1/80 WITH THE LIMITATION ON VOLATILE ORGANIC COMPOUNDS (VOC). ON 6/29/82, EPA ISSUED A NOV TO GLENMORE. THE APPLICABLE REGULATION SETS A LIMIT OF 3.8 LBS OV VOC PER GALLON OF COATING, BUT THE COMPANY USES COATINGS CONTAINING 5.6 LBS/GAL. PROPOSED REMEDY REGION II SEEKS TO PLACE THE COMPANY ON A SCHEDULE TO RE- FORMULATE ITS COATINGS OR INSTALL EQUIPMENT TO BRING ITS COATING LINES INTO COMPLIANCE. THE REGION IS ALSO SEEKING CIVIL PENALTIES OF $40K-$50K. THE PLANT IS LOCATED IN AN AREA WHICH HAS AN EXTENSION OF ITS ATTAINMENT DEADLINE FOR OZONE UNTIL 1987, SO THE POST-1982 ENFORCEMENT POLICY DOES NOT APPLY. NO ISSUES OF NATIONAL OR PRECEDENTIAL SIGNIFICANCE