EPA AND SDAPCD INSPECTED SOLAR ON NOVEMBER 5, 1986. SAMPLES OF TWO METAL PART COATINGS WERE TAKEN BY A SDAPCD INSPECTOR AND DELIVERED TO THE SDAPCD LABORATORY FOR VOC ANALYSIS. THE LABORATORY RESULTS SHOW THAT BOTH COATINGS EXCEEDED THE VOC LIMIT OF 340 GPL IN RULE 67.3. SOLAR APPLIED THE COATING WITH A CONVENTIONAL ATOMIZED SPRAY GUN. SUCH SPRAY APPLICATION IS NOT A METHOD PREQUALIFIED BY RULE 67.3 TO MEET THE 65% TE REQUIREMENT AND, BASED ON INFORMATION AVAILABLE TO EPA, DOES NOT MEET THE 65% REQUIRE- MENT. AN NOV WAS ISSUED TO SOLAR ON MAY 22, 1987. EPA REINSPECTED SOLAR ON AUGUST 18,1987. ONLY ONE COAT- ING SAMPLE WAS TAKEN AT THAT TIME AND SENT TO EPA'S CON- TRACTED LABORATORY, ENGINEERING SCIENCE, FOR VOC ANALYSIS. THE LABORATORY REPORT SHOWS THAT THE COATING'S VOC CONTENT OF 256 GPL MET THE 340 GPL LIMIT OF THE RULE. THE INSPEC- TORS OBSERVED CONVENTIONAL ATOMIZED SPRAY GUNS BEING USED TO APPLY THE COATINGS. EPA HAND-DELIVERED A SECTION 114 REQUEST FOR INFORMATION TO SOLAR ON AUGUST 21, 1987. IN THIS REQUEST, SOLAR WAS ASKED TO HAVE SAMPLES OF ANY METAL PARTS COATINGS USED DURING THE WEEK OF AUGUST 24 THOUGH AUGUST 28, 1987 TESTED AT AN INDEPENDENT LABORATORY FOR VOC CONTENT. BY MUTUAL AGREEMENT, IN LIEU OF A RESPONSE TO THIS SECTION 114 LETTER, SOLAR HAS PROVIDED EPA WITH A LETTER STIPULATED TO ITS CONTINUING VIOLATIONS OF RULE 67.3.