NATURE OF THE CASE: THIS IS A PROPOSED ACTION FOR A CIVIL PENALTY & PERMANENT INJUNCTION AGAINST PACKAGE PRODUCTS FLEX IBLE, A DIVISION OF ENGRAPH, INC., FOR VIOLATIONS OF THE NC SIP PURSUANT TO SECTION 113(B)(2) OF THE CAA. DEFENDANT OWNS & OPERATES IN CHARLOTTE, MECKLENBURG COUNTY, NC, A PRINTING & LAMINATING OPERATION TO PRODUCE PRINTED PACKAGING FOR VARIOUS INDUSTRIES. RELIEF REQUESTED: THE RELIEF REQUESTED CONSISTS OF AN IN- JUNCTION REQUIRING COMPLIANCE W/ALL APPLICABLE REQUIREMENTS OF THE NC SIP & A CIVIL PENALTY. THE PENALTY AMT TO BE SOUGHT AT SETTLEMENT IS $500,000.00. SIGNIFICANT LEGAL OR FACTUAL ISSUES: VALIDITY OF USE OF ALGORITHMS TO PROVE VIOLATIONS; EQUITABLE DEFENSES THAT DE- FENDANT MIGHT NOT BE IN VIOLATION OF NC SIP IF THE LOCAL AIR POLLUTION CONTROL AUTHORITY HAD SUBMITTED ALTERNATIVE COM- PLIANCE SCHEDULES & PERMITS LIMITING OPERATIONS TO EPA AS SIP REVISIONS.