THIS CASE INVOLVES VIOLATIONS OF THE MASS STATE IMPLE- MENTATION PLAN OF SECTION 110 OF THE CAA. THE UNIVERSITY OF MASSACHUSETTS AT AMHERST OPERATES 7 BITUMINOUS COAL-FIRED STOKER BOILERS. DESPITE NUMEROUS EN- FORCEMENT ACTIONS TAKEN BY THE MASS DEQE THAT INCLUDED STATE COURT CONSENT DECREES, THE UNIVERSITY HAS CONTINUALLY OPER- ATED THE BOILERS IN VIOLATION OF THE APPLICABLE EMISSION LIMITS FOR PARTICULATES. THESE LIMITS ARE CONTAINED IN THE MASS REGS PROMULGATED PURSUANT TO THE MASS STATE IMPLEMENTA- TION PLAN (SIP). THE UNIVERSITY IS PUBLICLY FUNDED, OWNED & OPERATED BY THE COMMONWEALTH OF MASS. IT IS REGISTERED AS A NONPROFIT CORPORATION W/THE MASS SECRETARY OF STATE. THE 7 BOILERS, W/AN OIL-FIRED UNIT, SUPPLY STEAM & ELEC TRICITY TO THE CAMPUS; SOME PORTION OF THE POWER PLANT MUST BE IN OPERATION AT ALL TIMES. THE UNIVERSITY OPERATED THESE BOILERS W/O CONTROLLING PARTICULATE EMISSIONS & IN VIOLATION OF THE MA SIP LIMIT FROM JAN 1974, THE COMPLIANCE DEADLINE SET IN THE MASS REGS, UNTIL MAR 1985. IN MAR 1985, THE UNI- VERSITY COMPLETED INSTALLATION OF POLLUTION CONTROL EQUIP- MENT & BEGAN CONTROLLING PARTICULATE EMISSIONS FROM 3 OF THE BOILERS. THE REMAINING 4 BOILERS ARE STILL W/O CONTROL EQUIPMENT; THEY ARE USED AS A BACK-UP SYSTEM & WHEN OPERATED ARE IN VIOLATION OF THE EMISSION LIMIT.IN JULY 1985, THE POLLUTION CONTROL EQUIPMENT BROKE DOWN. THE UNIVERSITY CON- TINUED TO OPERATE 3 OF THE BOILERS W/O C