RESPONDENT SUN REFINING AND MARKETING CO., OPERATES A RE- FINERY IN THE TOLEDO, OHIO SUBURB OF OREGON. THE COMPLAINT ALLEGED VIOLATION IN ONE COUNT OF THE OHIO STATE IMPLE- MENTATION PLAN (SIP) FOR LIMITATION OF SULPHUR DIOXIDE EMMISSIONS A VIOLATION IN FOUR COUNTS OF THE NATIONAL EMISS- ION STANDARDS FOR HAZARD AIR POLLUTANTS (NESHAP) FOR BENZENE. DURING 1993 AND 1994, FUEL-FIRED STEAM GENERATING UNITS AND TWO HEATERS THAT WERE OPERATED AT THE PLANT EMITTED AMOUNTS OF SULFUR DIOXIDE (S02) EXCESS OF THAT ESTABLISHED BY THE OHIO SIP, IN VIOLATION OF 42 C.F.R. 1881(B)(39)(XIV)(D). (SEE S-8)