NATURE OF THE CASE THIS ACTION IS BROUGHT PURSUANT TO THE CAA, SECTION 113(B) FOR VIOLATIONS OF REGULATION #7, OF THE NASHVILLE & DAVIDSON COUNTYAIR POLLUTION CONTROL ORDINANCE. DEFENDANT OWNS & OPERATES TWO AEROSPACE MFG FACILITIES IN NASHVILLE, TN. . DEFENDANT HAS OPERATED IN VIOLATION OF REG- ULATION #7 SINCE AT LEAST JANURARY 1, 1985. DEFENDANT HAS VI OLATED REGULATION 7 BECAUSE IT HAS USED, & CONTINUES TO USE, PRIME COAT PAINTS WHICH EXCEED THE APPLICABLE REGULATORY E- MISSION LIMIT OF 2.9 LBS OF VOLATILE ORGANIC COMPOUNDS PER GALLON OF COATING APPLIED. EPA SEEKS CIVIL PENALITIES OF $905,250.00 IN THIS ACTION. IN JUNCTIVE RELIEF IS REQUESTED, BUT A SETTLEMENT W/DEFENDANT IS IMMINENT. THIS CASE MAY BE SIGNIFICANT AS IT IS ONE OF EPA'S FIRST ACT IONS AGAINST A DOD CONTRACTOR. NEGOTIONS, ON-GOING MEETING TO BE SCHEDULED FOR END OF JUNE OR EARLY JULY. THE COMPLAINT HAS NOT BEEN FILED YET. WE EXPECT IT TO BE FILED BY THE END OF THIS WEEK. WE HAD A MEETING WITH AVCO ON 06/30/87. ROSEZELLA & RUSSELL HARMS ARE IN THE PROCESS OF DRAFTING A CONSENT DECREE. THE PENALTIES CAN NOW CLOSE TO 1 1/2 MILLION DOLLARS.