GUAM POWER AUTHORITY (GPA), AN AGENCY OF THE GOVERNMENT OF GUAM, CREATED IN 1968, OWNSS AND OPERATES THE CABRAS STEAM PLANT, A POWER GENERATING FACILITY WHICH CONSISTS OF TWO 66-MEGAWATT FUEL OIL-FIRED UNITS. THEY SUPPLY ELECTRI- CAL POWER TO THE ISLAND OF GUAM. THIS IS A CASE WITH A 12 YEAR HISTORY . IN 1972 EPA NOTIFIED GPA THAT THE NEW CABRAS PLANT WOULD HAVE TO COMPLY WITH THE SULFUR DIOXIDE NSPS FOR FOSSIL-FUEL-FIRED STEAM GENERATORS (40CFR PART 60, SUBPART D). SINCE THEN THE FOL- LOWING ACTIONS HAVE BEEN TAKEN: - EPA DENIED A GPA REQUEST FOR A 'VARIANCE' - EPA ISUED A NOTICE OF VIOLATION (NOV) AND ORDER - GPA FILED AN ACTION SEEKING AN INJUNCTION AGAINST ENFORCEMENT OF THE ORDER - EPA FILED AN ENFORCEMENT ACTION - A CONSENT ORDER WAS ISSUED - THE ORDER WAS AMENDED THREE TIMES - A DELAYED COMPLIANCE ORDER (DCO) WAS ISSUED GPA IS NOW IN VIOLATION OF THE EXISTING CONSENT ORDER AND DCO AND IS LISTED IN CDS AS A SIGNIFICANT VIOLATOR WITHIN THE MEANING OF SPMS. SPECIFICALLY, GPA IS IN VIOLATION OF PAR 6(A) & 6(B) OF THE CONSENT ORDER IN THE FOLLOWING WAYS: - GPA FAILED TO ADVISE EPA BY 8/15/82 WHETHER IT HAD ENTERED INTO A FIRM UNDERTAKING FOR THE INSTALLATION OF A SEAWATER SCRUBBER. IN FACT, GPA H