REGION II PROPOSES FILING OF A CIVIL ACTION PURSUANT TO CAA/113(B), 42 USC 7413(B), AGAINST AMPCO FOR ITS VIOLATION 6 NYCRR PART 212. AMPCO OWNS & OPERATES A PRINTING PLANT IN BRONX, NY. AMPCO'S PRINTING PROCESS IS A PROCESS SYSTEM WITHIN THE MEANING OF 6 NYCRR PART 212. THERE ARE SEVERAL EMISSION POINTS AT THE PLANT WHICH CONSTITUTE VENTILATION SYSTEMS WITHIN THE MEANING OF THE REGULATION. ON 10/30/84, AN INSPECTION WAS PERFORMED AT AMPCO'S PLANT BY AN ENVIRON- MENTAL SCIENTIST OF THE US EPA, REGION II. BASED UPON THIS INSPECTION, EPA ISSUED A NOV, INDEX NO. 50201, TO AMPCO PUR- SUANT TO CAA/113(A). THE NOTICE CITED THE CO. FOR VIOLATING 6 NYCRR 212.7(A) FOR ALLOWING SMOKE EMISSIONS SIGNIFICANTLY EXCEEDING 20% OPACITY TO EMANATE FROM THE PLANT. AMPCO HAS A LONG HISTORY OF OPACITY VIOLATIONS. THE CO. BEGAN OPERATIONS AT ITS PRESENT LOCATION IN THE BRONX IN MARCH, 1984. PRIOR TO THAT, AMPCO OPERATED A PRINTING PLANT IN MANHATTAN. EPA RECEIVED NUMEROUS CITIZEN COMPLAINTS OVER THE YEARS ABOUT THE EMISSIONS FROM THIS MANHATTAN PLANT. ON 12/28/84, EPA MET W/ AMPCO & PPG, ITS INK SUPPLIER, IN RESPONSE TO THE CO.'S REQUEST FOR A CONFERENCE PURSUANT TO CAA/113(A)(4). THE CO. CLAIMS THAT IT IS STILL TESTING ITS INKS UNDER A VARIETY OF CONDITIONS (IE. DIFFERENT PRESS SPEEDS, VARYING INK COVERAGE OF THE WEB, DIFFERENT WEATHER CONDITIONS). IT HAS CHOSEN TO TEST INKS FOR THE LAST SEVEN YEARS IN LIEU OF INSTALLING ANY CONTRO