THIS CASE ARISES OUT OF VIOLATIONS OF THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTIONS (NESHAP) FOR BENZENE EMISSIONS FROM COKE BY-PRODUCT RECOVERY PLANTS, 40 C.F.R. PART 61, SUBPART L (BENZENE COKE NESHAP), BY BETHLEHEM STEEL CORPORATION (BSC). THE VIOLATIONS OCCURRED AT BSC'S SPARROW POINT PLANT, LOCATED IN SPARROWS POINT, MARYLAND. IN ADDITION TO THE ABOVE VIOLATIONS, BSC HAS ALSO VIOLATED THE TERMS AND CONDITIONS OF A MAY 4, 1990 WAIVER OF COMPLIANCE FROM SUBPART L, GRANTED BY THE REGIONAL ADMIN- ISTRATOR PURSUANT TO THE GENERAL PROVISIONS OF THE NESHAP, 40 C.F.R. PART 61, SUBPART A. ON NOVEMBER 14, 1989, BSC SUBMISSTED TO THE ENVIRONMEN- TAL PROTECTION AGENCY, REGION III ( EPA ) AN INITIAL SOURCE REPORT AND REQUEST FOR A WAIVER OF COMPLIANCE FROM SUBPART L PURSUANT TO 40 C.F.R. SECTION 61.10 OF THE NESHAP. SEE ATTACHMENT I. BSC REQUESTED A WAIVER IN ORDER TO INSTALL A GAS BLANKETING SYSTEM TO RECOVERY AND DESTROY BENZENE WITHIN ITS COKE BY-PRODUCT RECOVERY PROCESS, SO AS TO COMPLY WITH THE REQUIREMENTS OF SUBPART L. ON MAY 4, 1990, THE REGION- AL ADMINISTRATOR GRANTED BSC A WAIVER OF COMPLIANCE WITH THE BENEZENE.