IN MARCH 1991, EPA BEGAN THE FIELD PORTION OF A RULE EFFECTIVENESS STUDY IN THE IDAHO PANHANDLE. THE PURPOSE OF THE STUDY WAS TO EVALUATE THE STATE OF IDAHO'S COMPLIANCE AND PERMITTING PROGRAM. TWENTY-SIX SOURCES WERE SELECTED FOR EVALUATION. THE LUMBER MILL OWNED BY DAW FOREST PRODUCTS (DAW), IN HUETTER (PRONOUNCED HUTTER ), IDAHO, WAS ONE OF THE SOURCES INCLUDED IN THE STUDY. AS A RESULT OF THE STUDY EPA HAS DETERMINED THAT THIS MILL (THE HUETTER FACILITY) OPERATED IN VIOLATION OF THE APPLICABLE EMISSION LIMITS FOR A NUMBER OF MONTHS AND THEREBY OBTAINED AN ECONOMIC BENEFIT NOT AVAILABLE TO NEIGHBORING FACILITIES. THE DAW HUETTER FACILITY IS LOCATED ALONG THE SPOKANE RIVER AND SELTICE WAY, A ROAD WHICH PARALLELS INTERSTATE 90, ABOUT TWO MILES WEST OF COEUR D'ALENE, IDAHO.