I. SYNOPSIS OF THE CASE: A.O. SMITH MANUFACTURES AUTOMOBILE FRAMES, RAILROAD CAR COMPONENTS, AND SMALL AUTOMOTIVE PARTS AT ITS MILWAUKEE, WISCONSIN, FACILITY. THE COMPANY EMPLOYS NEARLY 5000 PEOPLE AT THE 2.5 SQUARE-MILE FACILITY. ATTACHMENT 1 IS A LOCATION MAP OF THE FACILITY. COIL AND SHEET METAL ARE RECEIVED, FROMED, FABRICATED, AND COATED AT THE FACILITY BEFORE THE FINAL PRODUCTS ARE SHIPPED TO SUCH BUYERS AS FORD MOTOR COMP AND NAVISTAR INTERNATIONAL. THERE ARE FOUR (4) COATING LINES AT THE FACILITY: PRO- CESS LINES 34, 35, 37, AND 38. PROCESS LINE 34 IS A FLOW COATING SYSTEM AT WHICH TRUCK FRAMES ARE COATED WITH A SOL- VENT-BASED PAINT. PROCESS LINE 35 IS A FLOW COATING SYSTEM FOR SMALL TRUCKS AND AUTO PARTS. THIS LINE CURRENTLY USES A SOLVENT-BASED ALKYL FOR A PRIMER COAT APPLICATION WHICH IS OVEN-DRIED. PROCESS LINE 37 IS A DIP TANK FOR MISCELLANEOUS AUTOMOTIVE PARTS. PROCESS LINE 38 IS A SPRAY COATING LINE FOR TRUCK SIDE BARS. AS DETAILED IN SECT IV OF THIS REPORT, WITHIN, PROCESS LINES 34, 35, 37, 38 USE VOLATILE ORGANIC COMPOUNDS ( VOCS ) THAT ARE SUBJECT OT THE REQUIREMENTS OF THE WISCONSIN IMPLE- MENTATION PLAN ( SIP ). SPECIFICALLY, NR 154.13(4)(M) REG- ULATES THE MAXIMUM LEVELS OF VOCS PERMITTED TO BE CONTAINED IN THE COATINGS USED AT A.O. SMITH'S MILWAUKEE FACILITY. ATTACHMENT 2 IS A COPY OF THE S