ON JULY 9, 1985 EPA, REGION 9 ISSUED A NOTICE OF VIOLATION TO GENERAL MOTORS FOR VIOLATIONS THE CAA OCCURRING AT ITS PLANT IN VAN NUYS, CA ( THE PLANT ). THE NOV ALLEGES THAT TWO PAINT COATINGS UTILIZED IN THE PLANT'S AUTO COATING OPERATION WERE SAMPLED APRIL 17, 1985 AND FOUND TO CONTAIN EXCESSIVE LEVELS OF VOLATILE ORGANIC COMPOUNDS IN VIOLATION OF APPLICABLE LIMITS. THOSE APPLICABLE LIMITS ARE CONTAINED IN THE SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT SCAQMD STANDARDS, WHICH BECAME EFFECTIVE ON JANUARY 1, 1985 AS PART OF THE APPROVED CALIFORNIA STATE IMPLEMENTATION PLAN ( SIP ) AN SCAQMD PROPOSED SIP REVISION THAT WOULD LOWER THOSE STANDARDS AND, PRESUMABLY, RESULT IN THE PLANT'S COMPLIANCE HAS BEEN PENDING BEFORE EPA SINCE JULY, 1984. EPA IS IN THE PROCESS OF PREPARING A FEDERAL REGISTER NOTICE PROPOSING TO DISAPPROVE THAT REVISION. VIOLATIONS AT THE PLANT ARE CONTINUING AND HAVE BEEN EXACERBATED BY ITS CONVERSION FROM WATERBORNE COATINGS TO BASECOAT/CLEARCOAT TECHNOLOGY IN AUGUST OF 1985 TO MEET FOREIGN COMPETITION. GENERAL MOTORS CONTENDS THAT IT WILL NOT SURVIVE SUCH FOREIGN COMPETITION IF IT RETURNS TO WATERBORNE COATS OR, APPLIES EXPENSIVE ADD-ON TECHNOLOGY TO CONTROL EXCESSIVE VOC EMMISSIONS. GENERAL MOTORS URGES RELAXATION OF EXISTING VOC STANDARDS THROUGH EPA'S APPROVAL OF THE PROPOSED REVISION OR THROUGH SOME OTHER PROCEDU