PHELPS DODGE CORPORATION IS THE LARGEST DOMESTIC PRODUCER OF COPPER. IN 1985 IT PRODUCED ABOUT ONE THIRD OF THE COPPER MINED IN THE U.S. PHELPS IS VERTICALLY INTEGRATED; IT MINES COPPER; SMELTS COPPER; PRODUCES CONTINUOUS CAST COPPER ROD, THE BASIC FEED FOR THE ELECTRICAL WIRE AND CABLE INDUSTRY; AND IS A MAJOR PRODUCER OF MAGNETIC WIRE. IN 1985 PHELPS DODGE REPORTED EARNINGS OF 29.5 MILLION. AS A RESULT PHELPS DODGE'S TOTAL DEBT DECLINED OVER $100 MILLION TO JUST UNDER $500 MILLION. DOUGLAS SMELTER DISCHARGES TWO KINDS OF POLLUTANTS REGU- LATED BY THE CAA AND ARIZONA SIP: PARTICULATE MATTER AND SULFUR DIOXIDE. THE SMELTER OPERATES IN CHRONIC AND GROSS VIOLATION OF THE APPLICABLE ARIZONA SIP EMISSION LIMITATION FOR PARTIC MATTER, & IS LISTED IN CDS AS SIGNIFICANT VIOLA- TOR. RECENT STACK TESTS BY NEIC IN SEPTEMBER, 1985 SHOW THAT THE SMELTERS TWO STACKS EMIT 1018 POUNDS PER HOUR OF PARTICULATE MATTER AS COMPARED TO AN ALLOWABLE LEVEL OF 148 POUNDS PER HOUR. THE SMELTER EMITS SULFUR DIOXIDE AT LEVELS FAR IN EXCESS OF THE ARIZONA SULFUR DIOXIDE SIP EMISSIONS LIMITATIONS. RECENT STATE DATA INDICATES THAT THE SMELTER EMITS 319,884 TONS PER YEAR OF SULFUR DIOXIDE COMPARED TO A COMPLIANCE LIMIT OF 68,657 TONS PER YEAR. THE SULFUR DIOXIDE EMISSIONS LIMITATIONS COMPLIANCE DEADLINE OF JANUARY 14, 1986 HAS BEEN SUSPENDED BY EPA FOR FEDERAL ENFORCEME