DEFENDANT IN VIOLATION OF FEDERALLY ENFORCEABLE STATE EMISSIONS LIMITS FOR VOLATILE ORGANIC COMPOUNDS IN INDUS- TRIAL SURFACE-COATING OPERATION (LARGE APPLIANCE TOPCOATING) DEFENDANT CLAIMS COMPLIANCE WITH STATE REGULATION THROUGH USE OF CREDITS FOR TRANSFER EFFICIENCY, AS APPROVED BY ST. LOUIS COUNTY AND TACITLY APPROVED BY MDNR. HOWEVER, MO SIP FOR VOC DOES NOT PROVIDE FOR USE OF CREDITS FOR TRANS- FER EFFICIENCY IN DETERMINING COMPLIANCE WITH REGULATION. REGION PROPOSES TO ATTEMPT TO SETTLE CASE THROUGH PRE-REFER- RAL NEGOTIATION PROCESS, THROUGH ENTRY OF CONSENT DECREE REQUIRING DEFENDANT TO REDUCE ITS VOC EMISSIONS SO AS TO COME INTO COMPLIANCE WITH REGULATION, ENJOINING DEFENDANT FROM FUTURE VIOLATIONS OF THE REGULATION, AND REQUIRING DEFENDANT TO PAY A MINIMUM CIVIL PENALTY OF $75,592.