VAN LEER CONTAINERS, INC. IS A MANUFACTURER OF STEEL DRUMS . IN ITS CLEVELAND FACILITY, IT OPERATES TWO COATING LINES, FOR APPLYING PAINTS AND OTHER COATINGS TO THE DRUM SHELLS AND OTHER PARTS. BOTH LINES APPLY INTERIOR AND EXTERIOR COATINGS, WHICH ARE SUBJECT TO DIFFERENT EMISSION LIMITATION S. PURSUANT TO APPLICABLE SECTIONS OF THE FEDERALLY-APPROVE D OHIO STATE IMPLEMENTATION PLAN, INTERIOR COATINGS MUST NOT CONTAIN MORE THAN 5.0 LBS./GALLON OF VOLATILE ORGANIC COM- POUNDS (VOC'S), AND EXTERIOR COATINGS MUST NOT CONTAIN MORE THAN 3.5 LBS./GALLON OF VOC'S. VAN LEER IS A POTENTIAL MAJOR SOURCE OF VOC'S. U.S. EPA ISSUED A NOTICE OF VIOLATION (NOV) TO INLAND STEEL CONTAINERS, INC., THE PREVIOUS OWNER OF THE FACILITY, ON JULY 29, 1983. NINE INTERIOR COATINGS, AND ONE EXTERIOR COATING, EXCEEDED THE ABOVE-STATED LIMITATIONS. PRIOR TO THAT TIME, THE COMPANY OBJECTED TO THE LIMITS PROPOSED BY THE STATE TO BE INCLUDED IN THE REGULATION (THOUGH NOT AT TH E FEDERAL LEVEL). FAILING THAT, THE COMPANY SOUGHT A VARIANCE FROM THE STATE. THAT VARIANCE WAS RECENTLY GRANTED , BUT HAS NOT BEEN SUBMITTED AS A PROPOSED SIP REVISION. U.S. EPA DEFERRED TO THE STATE FOLLOWING ISSUANCE OF THE NOV. SINCE SATISFACTORY PROGRESS WAS NOT BEING MADE, U.S. EPA RESUMED ITS ENFORCEMENT ACTIVITY. THUS FAR, THE COMPANY'S EFFORTS TO OBTAIN LOW SOLVENT COATINGS HAVE ONLY BEEN SUCCESSFUL WIT