SIMPLOT SILICA OPERATES A COAL FIRED WETSAND DRYER IN CLARK COUNTY, NV. IN 1988 SIMPLOT REMOVED A WET SCRUBBER REQUIRED AS BACT UNDER A PSD PERMIT ISSUED 1982, USED TO CONTROL S02 EMISIONS. SIMPLOT ASSUMED A MINOR EMISSIONS INCREASE WOULD OCCUR BASED ON AN ESTIMATE THAT 80% OF THE S02 WOULD BE REMOVED BY THE BAGHOUSE. A SOURCE TEST PERFORMED IN 4/96 SHOWED THAT ONLY 26% OF THE S02 WAS ACTUALLY REMOVED. SIMPLOT SILICA IS OPERATED BY THE MINERALS AND CHEMICALS GROUP, A DIVISION OF J.R. SIMPLOT COMPANY, A PRIVATELY HELD COMPANY ENGATED IN AGRICULTURE AND THE PRODUCTION AND DELIVERY A AGRUCULTURAL CHEMICALS. THE SIMPLOT FACILITY HAS OPERATED A MAJOR SOURCE WITHOUT BACT AND WITHOUT A PROPER PSD PERMIT FOR LONGER THAN 5 YEARS THIS CIVIL REFERRAL SEEKS INJUCTIVE RELIEF AND A PENALTY INCLUDING BOTH ECONOMIC BENEFIT AND GRAVITY COMPONENTS. THE INJUNCTIVE RELIEF WOULD BE THE INSTALLATION OF A SCRUBBER, PREVIOUSLY INDENTIFIED AS BACT FOR S0Z CONTROL.