NATIONAL ALFALFA DEHYDRATING AND MILLING COMPANY OWNS AN ALFALFA PROCESSING PLANT APPROXIMATELY ONE MILE WEST OF GAYVILLE, S.D. SOUTH DAKOTA SIP REGULATION ARSD74:26:03:05 PROHIBITS ANY PERSON OPERATING AN ALFALFA PELLETIZING OR DE- HYDRATING FACILITY FROM DISCHARGING INTO THE AMBIENT AIR ANY AIR CONTAMINANT OF A SHADE OR DENSITYEQUAL TO OR GREATER THAN... A THIRTY PERCENT OPACITY. TWO VIOLATIONS WERE OBSERVED BY THE S.D. DEPT. OFENVT. PROTECTION: JUNE 1, 1983-- 59% OPACITY JULY 18, 1983-- 86% OPACITY. REGION-VIII ISSUED A SECTION-120 NON ON 6/11/84. ON FEBRUARY 28, 1985, MIKE RISNER OF REG-VIII SENT EPA HQ A SAMPLE CONSENT AGREEMENT WHICH HE PROPOSED WOULD AD- EQUATELY SETTLE ALL FIVE OF THE REG-VIII ALFALFA CASES: JENSEN BROS., NAT'L ALFALFA, SIOUX ALFALFA, BARNES HAY&FEED, AND MILBANK ALFALFA. HQ RESPONDED AT THE END OF MARCH, 1985, STATING THAT THERE WERE ONLY 2 EXPLICIT WAYS OF SETTLING A SECTION/120PROCEEDING SHORT OF OBTAINING THE FULL ECONOMIC BENEFIT PENALTY: WITHDRAWAL, OR MODIFICATION OF THE NON. (BECAUSE THE SOURCE IS EITHER NOT IN VIOLATION, OR IS ENTITLED TO AN EXEMPTION UNDER 40CFR SECTIONS 66.31-66.33.) HQ RESPONDED THAT THE PROPOSED CONSENT ORDER WAS INADEQUATE. REGION-VII, AED, AND SSCD PARTICIPATED IN A CONFERENCE CALL (5/7/85) IN WHICH A RESOLUTION OF THE PROBLEMS WITH THE PROPOSED GENERIC CONSENT AGREEMENT WERE R