THIS REPORT SUMMARIZES THE BASIS FOR RECOMMENDED CIVIL LIT- IGATION AGAINST CELANESE ENGINEERING RESINS, INC. ( CER OR DEFENDANT ) FOR VIOLATIONS OF THE NATIONAL EMISSION STAND- ARDS FOR BENZENE EMISSIONS FOR EQUIPMENT LEAKS (FUGITIVE E- MISSION SOURCES) OF BENZENE, 40 C.F.R. PART 61, SUBPARTS J AND V. THE VIOLATIONS OCCURRED AT CER'S FACILITY, LOCATED IN BISHOP, NUECES COUNTY, TEXAS (HEREINAFTER THE BISHOP PLANT ). THE BENZENE NESHAP FOR EQUIPMENT LEAKS IS APPLICABLE TO THE BISHOP PLANT BECAUSE THE PROCESS AT THE PLANT INCORPOR- ATES EQUIPMENT IN BENZENE SERVICE AS DEFINED AT 40 C.F.R. SEC. 61.111 AND THE PLANT SITE IS DESIGNED TO USE AT LEAST 1,000 MEGAGRAMS (MG) OF BENZENE PER YEAR. CER HAS VIOLATED THE FOLLOWING REGULATIONS WHICH ARE MORE FULLY DISCUSSED IN SECTION IV: 40 C.F.R. SEC. 61.10(A), 61.112(A), 61.242, 61. 246, AND 61.247. CER IS A SUBSIDIARY OF HOECHST CELANESE CORPORATION ( HCC ). CER IS BASED IN SOMERVILLE, NEW JERSEY AND IS INCORPORATED UNDER THE LAWS OF THE STATE OF DELAWARE. HCC, THE PARENT COMPANY OF CER, OWNS AND OPERATES SEVERAL PLANTS IN THE UNITED STATES, INCLUDING PLANTS IN ROCK HILL, SOUTH CAROLINA , PAMPA, TEXAS, AND NARROWS, VIRIGINA. BENZENE IS USED AT THE BISHOP PLANT IN THE PRODUCTION OF TRIOXANE. BENZENE IS USED AS AN AGENT TO EXTRACT TRIOXANE FROM AN AQUEOUS STREAM AND IS RECYCLED THROUGH THE PROCESS OVER AND OVER AGAIN WITH SOME BENZEN