NATURE OF THE CASE ON JULY 1, 1983, IN THE NORTHERN DISTRICT OF INDIANA, INLAND STEEL COMPANY MOVED FOR (AND THE UNITED STATES DID NOT OPPOSE) ENTRY OF A COMPREHENSIVE JUDGMENT ORDER WHICH PROVIDED FOR CONTROL OF ALL THEN KNOWN VIOLATING PARTICULATE MATTER SOURCES AT INLAND STEEL COMPANY'S PLANT IN EAST CHICAGO, INDIANA. THAT ORDER REQUIRES INSTALLATION OF CON- TROLS AND IMPLEMENTATION OF OPERATING AND MAINTENANCE PRAC- TICES AT, INTER ALIA, SIX COKE-OVEN BATTERIES AND AN OPEN HEARTH SHOP ESP STACK. IN ADDITION, INLAND STEEL COMPANY HAS FAILED TO SUBMIT REPORTS DOCUMENTING COMPLIANCE WITH RELEVANT OPERATING AND MAINTENANCE PRACTICES. INLAND'S PLANT IS LOCATED IN A DESIGNATED NONATTAINMENT AREA FOR TOTAL SUSPENDED PARTICULATE MATTER. CAUSE OF ACTION INLAND'S EMISSIONS ARE IN VIOLATION OF THE FEDERAL COURT ORDER AND THE INDIANA STATE IMPLEMENTATION PLAN. ACTION AGAINST INLAND IS PREMISED ON RULE 65 OF THE FEDERAL RULES OF CIVIL PROCEDURE, SECTION 113 OF THE CLEAN AIR ACT, 42 U.S.C. SECTION 7413, AND SPECIFIC PROVISIONS OF THE JUDGMENT ORDER REQUIRING PAYMENT OF STIPULATED PENALTIES IN THE EVENT OF NONCOMPLIANCE. TO DATE PENALTIES TOTAL $124,000. PROPOSED REMEDY IN ORDER TO ACHIEVE COMPLIANCE WI