FORD MOTOR COMPANY, AT ITS MT. CLEMENS VINYL PLANT, IS A M AJOR SOURCE OF VOLATILE ORGANIC COMPMUNDS, IN VIOLATION OF APPLICABLE MICHIGAN REGULATIONS APPROVED AND ENFORCEABLE UNDER THE CLEAN AIR ACT. BACKGROUND AND NATURE OF THE CASE ON APRIL 19, 1984, REGION V ISSUED A NOTICE OF VIOLATIO N TO FORD MOTOR COMPANY FOR VIOLATION OF MICHIGAN AIR POL- LUTION CONTROL COMMISSION RULE R336.1610 AT ITS MOUNT CLEMENS VINYL PLANT. RULE R336.1610 IS PART OF THE FEDERAL- LY ENFORCEABLE MICHIGAN SIP AND LIMITS THE EMISSION OF VOC F ROM VINYL COATING LINES. BASED UPON THEIR OWN PRODUCTION DATA, FORD OPERATES EIGHT VINYL COATING LINES IN VIOLATION OF THE RULE R336.1610 LIMITS. MOUNT CLEMENS IS LOCATED IN MACOMB COUNTY, PART OF THE THREE-COUNTY DETROIT URBAN AREA, WHICH HAS BEEN CLASSIFIED AS PRIMARY NON-ATTAINMENT FOR OZONE. CAUSE OF ACTION FORD'S EMISSIONS ARE IN VIOLATION OF THE MICHIGAN SIP AND, BECAUSE FORD IS A MAJOR SOURCE (881 TPY), U.S. EPA IS REQUIRED TO BRING SUIT TO ABATE THE VIOLATIONS AND RECOVER CIVIL PENALTIES UNDER SECTION 113 OF THE CLEAN AIR ACT, 42 U.S.C. SECTION 7413. PROPOSED REMEDY IN ORDER TO ACHIEVE COMPLIANCE WITH THE MICHIGAN SIP, FORD MUST INSTALL CONTROLS, SUCH AS AN