DEFENDANT HAS BEEN VIOLATING REQUIREMENTS OF ALLEGHENY COUNTY SIP RELATING TO EMISSIONS FROM COKE OVEN BATTERIES FOR SEVERAL YEARS. DEFENDANT WAS SUBJECT OF PRIOR COMPLAINT AND CONSENT DECREES FOR SUCH VIOLATIONS. PAST COMPLAINTS/ DECREES HAVE ONLY ADDRESSED PENALTIES TO 02/01/85. VIOLA- TIONS ARE MOST PROBABLY EXCLUSIVELY THE RESULT OF DEFICIENT OPERATIONS AND MAINTENANCE PROCEDURE. ALLEGHENY COUNTY WISHES TO JOIN EPA IN ENFORCING THE SIP, SEEKING PENATLIES FOR PAST VIOLATIONS, AND INJUNCTIVE RELIEF.