A. DEFENDANT THE DEF IS ARMSTONG WORLD INDUSTRIES, INC., A PA. CORP. ENGAGED IN, AMONG OTHER THINGS, THE MANUFACTURE OF FLOOR COVERINGS AT A PLANT IN LANCASTER COUNTY, PA. THE MANUFAC- TURING PROCESS INVOVLES SURFACE COATING OPERATIONS WHICH GENERATE EMISSION OF VOLATILE ORGANIC COMPOUNDS (VOC), AN AIR POLLUTANT REGULATED UNDER PA.'S STATE IMPLEMENTATION PLAN FOR THE ATTAINMENT AND MAINTENANCE OF THE NAT'L AMBIENT AIR QUALITY STANDARD FOR OZONE (SEE 40 CFR SECTION 50.9). ARMSTORNG HAS BEEN IN VIOLATION OF THE STATE'S PLAN WITH RESPECT TO VOC EMISSIONS FROM CERTAIN SURFACE COATING LINES AT THE PLANT SINCE 4/9/82, THE APPLICABLE COMPLIANCE DEADLINE IN THE PENNSYLVANIA PLAN. B FACTUAL BASIS FOR CIVIL LITIGATION THE AGENCY ISSUED A REQUEST FOR INFORMATION TO ARMSTRONG UNDER THE CAA, 42 USC SECT 7401 (THE ACT), IN ORDER TO DETERMINE ARMSTRONG'S COMPLIANCE STATUS WITH RESPECT TO THE PA PLAN REQUIREMENTS GOVERNING VOC EMISSIONS FROM SURFACE COATING PROCESSES. ARMSTRONG'S RESPONSE INDICATED VIOLATIONS & THE AGENCY ISSUED AN N.O.V. DATED 12/5/82. ARMSTRONG CONTINUES TO BE IN VIOLATION. COMPLIANCE IS POSSIBLE THROUGH ONE OF THE FOLLWOING: 1. USE OF ALTERNATIVE COAT- INGS WITH LOWER VOC CONTENT OR 2. THE INSTALLATION OF CONTROL EQUIPMENT. C. ENVIRONMENTAL CONSEQUENCES OF VI