DEF FAILED TO SUBMIT A COMPLIANCE PLAN FOR LIMITING EMISSIONS OF VOC BY 1/1/80 IN ORDER TO ACHIEVE COMPLIANCE BY 6/1/80. AFTER EPA AND NYDEC NOTIFICATION THAT CO. WAS SUB- JECT TO PART 228, CO. CONTINUES TO CONTEND THAT IT IS NOT A COIL COATER. EPA ISSUED NOV ON 1/6/84. CO. CLAIMS LITH- OGRAPHIC PLATE MANUFACTURING PROCESS WAS NOT CONSIDERED IN DEVELOPMENT OF NSPS FOR COIL COATER, THEREFORE CO. IS NOT SUBJECT TO COIL COATING STD. EPA SEEKS CIVIL ENFORCEMENT FOR INJUNCTION TO CEASE NONCOMPLIANCE WITH SIP/PART 228 AND IMPOSE CIVIL PENALTIES UNDER CAA.