THIS IS A CIVIL ACTION AGAINST RUSSELL-STANLEY CORPORATION PURSUANT TO SECTION 113 OF THE CAA, 42 USC 7413 FOR EMISSION OF VOLATILE ORGANIC SUBSTANCES IN EXCESS OF LIMITS ALLOWED BY N.J.A.C. 7:27-16.5 (PART OF THE SIP FOR N.J.). ON 11/20/85, AN EPA ENGINEER INSPECTED THE RUSSELL-STANLEY CORP. (RS) IN WOODBRIDGE, NJ AND DISCOVERED THAT RS HAD AP- PLIED IN 1982 TO THE NJDEP FOR APPROVAL OF A BUBBLE APPLI- CATION WHICH HAS NEVER BEEN APPROVED. RS MANUFACTURES STEEL DRUMS AND PLASTICCONTAINERS. SAM- PLES OF THE VARIOUS LINER COATINGS APPLIED TO METAL BARRELS WERE COLLECTED BY THE ENGINEER TO DETERMINE WHETHER RS WAS IN COMPLIANCE WITH THE N.J. REGULATION LIMITING EMISSIONS OF VOS (N.J.A.C. 7:27-16.5 - PART OF THE SIP FOR N.J.) SHORTLY AFTER THE INITIAL INSPECTION, EPA REQUESTED, BY A SECTION 114 LETTER DATED 12/17/85, A COMPLETE DESCRIPTION OF THE RS COATINGS, VOS CONTENT, EQUIPMENT, ETC. UPON REVIEW OF THE LABORATORY ANALYSIS OF THE SAMPLES COL- LECTED ON 11/20/85 AND THE 1/29/86 RESPONSE BY RS TO THE 114 LETTER, IT WAS DETERMINED THAT RS WAS IN VIOLATION OF NJAC 7:27-16.5. A NOV (INDEX NO. 60105) WAS ISSUED ON 3/24/86. A CONFER- ENCE REGARDING THE NOV WAS HELD ON 5/9/86, AT WHICH REPRE- SENTATIVES OF RS: 1) CONCEDED THAT RS HAS BEEN IN VIOLATION OF THE REG'S. 2) CLAIMED THAT AN APPROVABLE REVISED BUBBLE APPLICATION WOULD SOON BE SUBMITTED TO