KENNAMETAL, INC. OWNS AND OPERATES A FACILITY NEAR FALLON, NEVADA, WHICH USES A UNIQUE THERMIT KILN TO REFINE TUNGSTEN MONOCARBIDE POWDER. KENNAMETAL CHARGES THE KILN WITH TUNGSTEN AND ALUMINUM BULLETS, RESULTING IN AN EXOTHERMIC REACTION REACHING OVER 4000 DEGREES FAHRENHEIT AND LASTING SOMEWHAT MORE THAN 1 HOUR. DURING THE CHARGING, KENNAMETAL'S THERMIT KILN HAS VISIBLE EMISSIONS OF 100% OPACITY AND EMITS SUBSTANTIAL LEVELS OF TOTAL SUSPENDED PARTICULATE ( TSP ). UNTIL LATE 1993, KENNAMETAL CHARGED THE THERMIT KILN TWO TO FIVE TIMES PER MONTH. IN EARLY 1994, KENNAMETAL REDUCED THE SIZE OF THE KILN BY 75% BUT CHARGES IT MORE FREQUENTLY TO MAINTAIN PAST PRODUCTION LEVELS. KENNAMETAL CONDUCTED SOURCE TESTING IN FEBRUARY 1994. BASED ON THESE RESULTS, EPA HAS CALCULATED THAT KENNAMETAL'S FULL SIZED THERMIT KILN (PRIOR TO SIZE REDUCTION IN 1994) WAS EMITTING TSP AT A RATE OF 938 LBS/HR DURING CHARGING. THUS, KENNAMETAL HAS ALSO VIOLATED THE SIP'S TSP EMISSION LIMIT. ON APRIL 13 AND 26, AND JULY 9, 1993, EPA RECEIVED WRITTEN RESPONSES TO SECTION 114 LETTERS. ON AUGUST 24, 1993, REPRESENTATIVES FROM EPA AND KENNAMETAL MET TO DISCUSS EPA'S NOTICE OF VIOLATION. SHORTLY AFTER THE NOV CONFERENCE KENNAMETAL CONTACTED REGION 9 TO DISCUSS ITS PROPOSAL TO TEST THE THERMIT KILN'S EXHAUST STREAM