NATURE OF CASE CONTINENTAL CAN COMPANY, USA, PLANT #77 MANUFACTURES AND COATS TWO-PIECE AND THREE-PIECE CANS FOR USE IN THE FOOD AND BEVERAGE INDUSTRIES. PLANT #77 HAS 3 DEPARTMENTS THAT CONTAIN CAN SURFACE COATING PROCESS LINES THAT EMIT VOLATILE ORGANIC COMPOUNDS ( VOC'S ) INTO THE AMBIENT AIR IN VIOLA- TION OF THE APPLICABLE WISCONSIN SIP. ON OCTOBER 28, 1983, REGION V ISSUED A NOTICE OF VIOLATION TO CONTINENTAL FOR GENERATING VOC EMISSIONS IN EXCESS OF THE LIMITS PERMISSIBLE UNDER THE WISCONSIN SIP. ACTUAL UNCONTROLLED VOC EMISSIONS FROM PLANT #77 WERE APPROXIMATELY 1316 TONS IN 1983, IN CONTRAST TO THE 821 TONS OF ALLOWABLE EMISSIONS PERMITTED UNDER THE WISCONSIN SIP. THE MILWAUKEE AREA IS DESIGNATED AS A PRIMARY NON-ATTAINMENT AREA FOR OZONE. CAUSE OF ACTION CONTINENTAL IS EMITTING VOC'S IN VIOLATION OF THE WISCONSIN SIP, AND BECAUSE CONTINENTAL IS A MAJOR SOURCE, U.S. EPA IS REQUIRED TO BRING SUIT TO ABATE THE VIOLATIONS AND RECOVER CIVIL PENALTIES, UNDER SECTION 113 OF THE CLEAN AIR ACT, 42 U.S.C. SECTION 7413. PROPOSED REMEDY IN ORDER TO ACHIEVE COMPLIANCE WITH THE WISCONSIN SIP, CONTINENTAL MUST EITHER INSTALL CONTROL EQUIPMENT SUCH AS AFTERBURNERS OR CARBON ADSORPTION EQUIPMENT, OR REDUCE THE AMOUNT OF VOC EMITTED BY REFORMULATING