This action addresses violations of the New York State Implementation Plan, specifically, the New York Reasonably Available Control Technology provision, 6 N.Y.C.R.R. section 212-3, for failure to install control technology or take federally enforceable emission limits in the facility's permit, resulting in excess emissions of volatile organic compounds, a primary precursor to the formation of ground-level ozone. EPA seeks injunctive relief in the form of pollution controls and a civil monetary penalty.