THE FOX PAPER DIVISION OF ERVING PAPER MILLS OPERATES TWO BOILERS FOR SPACE HEATING AND FOR THE DRYING PHASE OF ITS PAPERMAKING PROCESS. WITHOUT CONTROLS, NEITHER BOILER COULD MEET THE REQUIREMENTS OF THE AP3-11, THE APPLICABLE SECTION OF THE OHIO STATE IMPLEMENTATION PLAN FOR TOTAL SUSPENDED PARTICULATES (TSP). IN ABSENCE OF CONTROLS, ERVING PAPER IS A MAJOR SOURCE. PURSUANT TO A STATE-ISSUED DELAYED COMPLIANCE ORDER (DCO), ERVING INSTALLED AN ELECTROSTATIC PRECIPITATOR ON ONE BOILER AND MULTICLONES ON THE OTHER. THE DCO WAS APPROVED BY THE U.S. EPA AND REQUIRED COMPLIANCE WITH AP-3-11 BY JULY 1, 1979. THE BOILER ASSOCIATED WITH THE MULTICLONES HAS NOT COME INTO COMPLIANCE. THEREFORE, OPERATION OF THAT UNIT VIOLATES THE DCO AS WELL AS AP-3-11. ERVING'S EFFORTS TO- WARD RESOLUTION OF THE PROBLEM HAVE FOCUSED AN ATTEMPT TO ACQUIRE A VARIANCE WHICH WOULD ALLOW THE COMPANY TO AVERAGE THE EMISSION FROM THE TWO BOILERS. OHIO EPA HAS GRANTED THE VARIANCE AT THE STATE LEVEL, EFFECTIVE ON APPROVAL BY U.S. EPA. THE STATE HAS SUBMITTED THE VARIANCE AS A PROPOSED SIP REVISION, BUT IT HAS BEEN LEARNED FROM REGION V REGULATORY PERSONNEL THAT A RECOMMENDATION TO DENY THE REVISION WILL BE MADE. IN ANY EVENT, IT WAS EXPLAINED TO ERVING THAT REGULA- TORY ACTION CANNOT RESOLVE THE ENFORCEMENT CASE. TO REMEDY THE VIOLATIONS, U.S. EPA SEEKS AN INJUNCTION TO FORCE ERVING TO COMPLY WITH THE SIP.