NATURE OF THE CASE: CITY WATER, LIGHT & POWER CO, THE MUNICIPAL UTILITY FOR SPRINGFIELD, IL, OWNS & OPERATES 2 ELECTRICITY GENERATING PLANTS, THE LAKESIDE PLANT & THE DALLMAN PLANT. THE DALLMAN PLANT IS THE NEWER OF THE 2. IT HAS 3 BOILERS, OF WHICH BOILER #3 IS THE LARGEST, W/A DESIGN CAPACITY FOR PRODUCING 192 MEGAWATTS OF ELECTRIC POWER. DALLMAN BOILER #3 IS SUB- JECT TO THE NPDS FOR SULFER DIOXIDE, 40 CFR PART 60 ET SEQ. CAUSE OF ACTION: IN 1976 EPA BROUGHT A CIVIL ACTION AGAINST THE CITY OF SPRINGFIELD TO COMPEL IT TO BRING BOILER #3 INTO COMPLIANCE W/THE SULFUR DIOXIDE NSPS. ON 9/13/77, THE CITY OF SPRING- FIELD & EPA AGREED TO A CD IN THE CASE. THE DECREE REQUIRED AMONG OTHER THINGS, THAT THE CITY INSTALL & OPERATE DESUL- FURIZATION EQUIPMENT & EMISSION MONITORING EQUIPMENT ON BOILER #3. THE CITY INSTALLED THE POLLUTION CONTROL EQUIPMENT & CERTIFIED ITS CAPABILITY IN 1/81. THE CITY HAS HOWEVER, OPERATED THE EQUIPMENT IN A THROUGHLY UNRELIABLE MANNER SINCE THE CERTIFICATION TEST. AS A DIRECT CONSEQUENCE OF THE CITY'S FAILURE, DURING THE PERIOD 1/81 THROUGH 2/82 APPROX 12,000 TONS OF SULFUR DIOXIDE HAVE BEEN EMITTED INTO THE ATMOSPHERE IN EXCESS OF ALLOWABLE EMISSIONS. IN ADDITION, THE CITY HAS FAILED TO CERTIFY & OPERATE THE EMISSION MONI- TORING EQUIPMENT REQUIRED BY THE CD &