DEFENDANT PRODUCES SEVERAL LINES OF INSULATION PRO- DUCTS. THE KANSAS CITY, KANSAS/WYANDOTTE COUNTY HEALTH DEPT. (KCK-WCH) FOUND OPACITY VIOLATIONS AT A TIME WHEN ONE OF THOSE LINES (THE K-10 LINE, PRODUCING METAL BUILDING INSUL- ATION, OR MBI --FIBERGLASS--) WAS OPERATING. THE LINE HAD AN ELECTROSTATIC PRECIPITATOR (ESP) ON IT, WHICH WAS AP- PARENTLY NOT CAPABLE OF HANDLING THE EMISSIONS. THE KANSAS REGULATION, SECTION 2A-19, REQUIRED THAT OPACITY BE LESS THAN 20%, WHEREAS THE AVERAGE OF THE OPACITY READINGS WAS 34%. THE SOURCE IS IN A NON-ATTAINMENT AREA FOR HYDRO- CARBONS. THE OPACITY READINGS DONE BY KCK-WCH WHICH UNCOVERED VIOLATION OCCURED ON 7/19/84, AND KCK-WCH ISSUED AN NOV ON 7/20/85. THE STATE OF KANSAS (KANSAS DEPT. OF HEALTH AND ENVIRONMENT--KDHE) ISSUED AN NOV, BASED ON THE SAME READINGS , ON 7/27/84. ON 8/15/84, KCK-WCH AND KDHE MET WITH DEF- FENDANT TO DISCUSS THE VIOLATION. ON 11/29/84 EPA/REG-VII ISSUED A SECTION 114 LETTER, ASKING FOR PRODUCTION FIGURES, DEFENDANT'S RESPONSE WAS RECEIVED ON 12/13/84. ON 1/15/85, KDHE ISSUED A CORRECTIVE ORDER REQUIRING INSTALLATION OF A NEW ESP, WITH A FINAL COMPLIANCE DATE OF 2/1/86; THE ORDER DID NOT ASSESS ANY PENALTIES. REGION-VII ISSUED ITS NON ON 3/4/85. IN RESPONSE TO THE NON, DEFENDANT SUBMITTED A TIMELY PETITION FOR RECONSIDERATION ON 4/25/85.