AN EPA INSPECTION WAS FIRST CONDUCTED AT GD CONVAIR ON AUGUST 13, 1985. DURING THIS INSPECTION, TWO CAMOUFLAGE TOPCOAT COATINGS WERE FOUND TO EXCEED THE VOC CONTENT LIMIT ON SAN DIEGO 67.3. THESE PAINTS WERE APPLIED WITH AIR- ASSISTED SPRAY GUNS. NO ENFORCEMENT ACTION WAS TAKEN AGAINST GD CONVAIR BY EPA AT THAT TIME. ON JULY 11, 1986, EPA AND SDAPCD CONDUCTED ANOTHER INSPEC- TION OF GD CONVAIR'S PACIFIC HIGHWAY (LINDBERG FIELD) PLANT. BASED ON COATING MANUFACTURER INFORMATION SUPPLIED BY GD CONVAIR DURING THAT INSPECTION, ALL OF THE CAMOUFLAGE CHEMICAL RESISTANT TOP COATS USED AT THE FACILITY EXCEEDED THE VOC LIMIT OF 340 GPL IN RULE 67.3. AN NOV WAS ISSUED ON DECEMBER 3, 1986. ON MAY 29, 1987, EPA ISSUED A SECTION 114 REQUEST FOR INFORMATION TO GD CONVAIR. THIS LETTER REQUIRED GD CONVAIR TO HAVE SAMPLES OF THEIR METAL PART COATINGS TESTED AT AN INDEPENDENT LABORATORY FOR VOC CONTENT AND TO PROVIDE THE RESULTS TO EPA BY JULY 1, 1987. GD CONVAIR'S RESPONSE JULY 7, 1987 REPORTED MISCELLANEOUS METAL PART COATINGS USAGE AT THE FACILITY IN JUNE 1987 AND IDENTIFIED MULTIPLE VIOLATIONS OF RULE 67.3.