THIS CASE CONCERNS THE DEFENDANT'S FAILURE TO COMPLY WITH THE REQUIREMENTS OF THE CLEAN AIR ACT'S BENZENE NESHAP FOR EQUIPMENT LEAKS FOUND AT 40 C.F.R. PART 61, SUBPARTS J AND V APPLICABLE TO THE ACID RECOVERY AND ACETIC ANHYDRIDE MANUFACTURING PROCESSES AT ITS CELLULOSE ACETATE FIBER PRODUCTION FACILITY KNOWN AS THE CELRIVER PLANT IN ROCK HILL, SOUTH CAROLINA. THE HOECHEST CELANESE CELRIVER PLANT HAS CERTAIN TYPES OF PROCESS EQUIPMENT (PUMPS, COMPRESSORS, VALVES, ETC.) IN BENZENE SERVICE SUBJECT TO THE REQUIREMENTS OF 40 C.F.R. PART 61, SUBPART J. THE CELRIVER PLANT IS DESIGNED TO PRODUCE OR USE 1000 MEGAGRAMS OR MORE OF BENZENE PER YEAR AND THEREFORE MUST INSTITUTE A LEAK DETECTION AND REPAIR PROGRAM AS SPECIFIED IN 40 D.F.R. PART 61 SUBPART V. BASED UPON INFORMATION SUBMITTED BY CELANESE IN RESPONSE TO EPA'S REQUESTS FOR INFORMATION PURSUANT TO SECTION 114 OF THE ACT, EPA DETERMINED THAT THE CELRIVER PLANT HAD BEEN IN OPERATION AND HAD EQUIPMENT IN BENZENE SERVICE SUBJECT TO THE REQUIRE- MENTS OF SUBPART J SINCE ITS PROMULGATION ON JUNE 6, 1984. THE VIOLATIONS ALLEGED INCLUDE THE COMPANY'S FAILURE TO SUBMIT AN INITIAL REPORT REQUIRED BY 40 C.F.R. SECTIONS 61.10 AND 61.247; ITS FAILURE TO IMPLEMENT A BENZENE LEAK DETECTION AND REPAIR PROGRAM IN ACCORDANCE WITH THE REQUIRE- MENTS OF SUBJARTS J AND V; AND ITS FAILURE TO COMPLY WITH SEMIANNUAL REPORTING REQUIREMENTS. EPA IS SEEKING INJUNCTIVE RELIEF AND PENALTIES FOR THE PAST VIOLATIONS.