NATURE OF THE CASE: THIS IS A CIVIL ACTION AGAINST THE CITY OF ST. LOUIS , MO FOR VIOL OF THE MO SIP PARTICULATE EMISSION STANDARD AT ITS TWO MUNICIPAL INCINERATORS. THE CITY INCINERATORS HAVE BEEN LISTED AS SIGNIFICANT VIOLATORS IN CDS. CAUSE OF ACTION: THIS CASE INVOLVES VIOL'S OF THE MO INCINERATOR RE- GULATION FOR PARTICULATE EMISSIONS. THE NOTICE OF VIOL CITED VISIBLE EMISSION VIOL'S THAT WERE DOCUMENTED BY THE STATE OF MO. THE RESULTS OF A RECENT STACK TEST SHOULD PROVIDE ADDITIONAL EVIDENCE OF A VIOL. PROPOSED REMEDY: ATTEMPT TO NEG A CD W/THE CITY THAT WILL REQUIRE IT TO AGREE TO A SCHED FOR COMPLIANCE OF A PLANNED REPLACE- MENT FACILITY & TO STRINGENT INTERIM CONTROLS. IF THE CITY WILL NOT COME TO AN AGREEMENT, EPA SHOULD BE PRE- PARED TO GO FORWARD W/CIVIL LITIGATION REQUESTING AN IN- JUNCTION & PLTY'S. ISSUES OF NATIONAL SIGNIFICANCE: THE REPLACEMENT FACILITY WILL NOT BE COMPLETED UNTIL AT LEAST EARLY 1986. IT APPEARS UNLIKELY THAT THE CITY WILL BE ABLE TO MEET EMISSION STANDARDS EVEN USING STRINGENT INTERIM CONTROLS. THUS, A SETTLEMENT MAY INCLUDE AGREEMENT BY EPA TO EXTEND FINAL COMPLIANCE BEYOND 12/31/82.