NATURE OF THE CASE SMURFIT DIAMOND OPERATES A PLANT OUTSIDE OF CINCINNATI, OHIO, FOR THE MANUFACTURE AND DISTRIBUTION OF PRINTED LABELS AND CARDBOARD PACKAGING PRODUCTS, PRIMARILY FOLDING CARTONS. THE MANUFACTURING PROCESS INVOLVES PACKAGING ROTOGRAVURE PRINTING OPERATIONS WHICH ENTAIL THE USE OF SOLVENT BASED INKS AND LACQUERS. THE INK DRYING OPERATION GENERATES HEATED AIR CONTAINING VOLATILE ORGANIC COMPOUNDS (VOC'S) WHICH ARE VENTED INTO THE ATMOSPHERE. OH OCTOBER 3, 1983, REGION V ISSUED A NOTICE OF VIOLATION TO SMURFIT DIAMOND FOR GENERATING VOC'S IN EXCESS OF THE LIMITS PERMISSIBLE IN THE OHIO SIP. SMURFIT DIAMOND ACTUALLY EMITS APPROXIMATELY 657 TONS OF VOC'S PER YEAR, IN CONTRAST TO THE 243.2 TONS PER YEAR PERMITTED UNDER THE APPLICABLE OHIO RULE. THE CINCINNATI AREA IS DESIGNATED AS A PRIMARY NONATTAINMENT AREA FOR OZONE. CAUSE OF ACTION SMURFIT DIAMOND'S EMISSIONS ARE IN VIOLATION OF THE OHIO SIP AND, BECAUSE SMURFIT DIAMOND 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 OHIO SIP, SMURFIT DIAMOND MUST EITHER INSTALL CO