NATURE OF THE CASE SANCAP, A DELAWARE CORPORATION, OWNS AND OPERATES A PLANT IN ALLIANCE, STARK COUNTY, OHIO, WHICH MANUFACTURES TWO MAJOR PRODUCT LINES: SANDPAPER AND BOTTLE CAPLINERS. BOTH MANUFACTURING PROCESSES INCLUDE PAPER COATING OPERA- TIONS INVOLVING THE USE OF ORGANIC SOLVENTS. AFTER THE COATING IS APPLIED, HEATED AIR IS USED TO DRY THE PAPER AND EVAPORATE THE SOLVENTS. THE HEAED AIR, CONTAINING VOLATILE ORGANIC COMPOUNDS (VOC'S) IS VENTED, UNCONTROLLED, TO THE ATMOSPHERE. ON JUNE 24, 1984, REGION V ISSUED A NOTICE OF VIOLATION TO SANCAP FOR GENERATING VOC'S IN EXCESS OF THE LIMIT PERMISSIBLE IN THE FEDERALLY APPROVED OHIO SIP REGULA- TION 3745-21-09(F), COVERING PAPER COATING LINES. SANCAP ACTUALLY EMITS APPROXIMATELY 119 TONS OF VOC'S PER YEAR, IN CONTRAST TO THE 20 TONS PER YEAR PERMITTED UNDER THE OHIO RULE. STARK COUNTY IS DESIGNATED AS A PRIMARY NONATTAINMENT AREA FOR OZONE. CAUSE OF ACTION SANCAP'S EMISSIONS ARE IN VIOALTION OF THE OHIO SIP AND, BECAUSE SANCAP 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 WI