SUN RECEIVED A WAIVER, FROM EPA, OF COMPLIANCE WITH THE NESHAP FOR BENZENE EMISSIONS FROM BENZENE TRANSFER OPERATION WHICH EXPIRED ON 2/28/92. BEFORE THE EXPIRATION OF THE WAI- VER, SUN APPROACHED EPA AND SAID THAT THE COMPANY WOULD BE UNABLE TO MEET THE FINAL COMPLIANCE DEADLINE BECAUSE THE COAST GUARD (WHO MUST CERIFY SUN'S BENZENE SYSTEM BECAUSE IT INVOLVES LOADING ONTO MARINE VESSELS) WOULD NOT APPROVE THE SYSTEM. SUN ANTICIPATED THAT IT WOULD NEED UNTIL 1/93 IN ORDER TO DEMONSTRATE FINAL COMPLIANCE WITH THE NESHAP. THIS ACTION IS EXPECTED TO RESULT IN A CONSENT DECREE THAT PRO- VIDES A SCHEDULE OF COMPLIANCE AND THE PAYMENT OF A PENALTY. PRN SENT TO DOJ ON 3/23/92. AGREEMENT IN PRINCIPLE REACHED 5/15/92; HOWEVER, PARTIES HAVE NOT BEEN ABLE TO FINALIZE CONSENT AGREEMENT.