THIS IS A PROPOSED CIVIL ACTION UNDER SECTION 113 OF THE CLEAN AIR ACT FOR VIOLATIONS OF 1) VOC EMISSION RESTRICTIONS AT 310 CMR SECTION 7.18(14) AND (15), WHICH ARE PART OF MASSACHUSETTS' FEDERALLY ENFORCEABLE STATE IMPLEMENTATION PLAN (SIP). 2) NONATTAINMENT NEW SOURCE REVIEW AND PLAN APPROVAL (PERMITTING) REQUIREMENTS IN THE SIP AT 310 CMR SECTION 7.00 AND 7.02. AVON TAPE INC. OWNS AND OPERATES SIX PAPER AND FABRIC SURFACE COATING LINES AT ITS FACILITY IN AVON, MA. FROM 1990 THROUGH 1993, THESE COATING LINES EMITTED VOLATILE ORGANIC COMPOUNDS (VOC) AT A RATE ABOVE THE ALLOWABLE VOC EMISSON LIMITS FOR PAPER AND FABRIC COATING LINES AT 310 CMR SECTION 7.18(14) AND (15). IN 1982 AND 1986, AVON TAPE CONSTRUCTED AND OPERATED NEW COATING LINES WITHOUT APPLYING FOR AND RECEIVING PLAN APPROVALS FROM THE MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP), AS REQUIRED BY 310 CMR SECTION 7.02 AND WITHOUT UNDERGOING NONATTAINMENT NEW SOURCE REVIEW UNDER 310 CMR 7.00, APPENDIX A. PROPOSED RELIEF: THE COMPLAINT ASKS FOR CIVIL PENALTIES OF UP TO $25,000 PER DAY OF VIOLATION COMMENCING FIVE YEARS PRIOR TO THE DATE OF FILING. (THE APPLICABLE STATUTE OF LIMITATIONS LIMITS THE ASSESSMENT OF PENALTIES IN THIS ACTION TO VIOLATIONS WITHING THE PAST FIVE YEARS.) THE REGION HAS CALCULATED A PROPOSED MINIMUM PENALTY OF APPROXI- MATELY $581,000.