A 1989 CONSENT ORDER REQUIRED THE COMPANIES (CONOCO, INC) TO DESIGN AND IMPLEMENT A GROUNDWATER INTERCEPTION AND TREAT- MENT SYSTEM THAT SHALL PREVENT THE OFFSITE MIGRATION OF HYDROCARBONS AND DISSOLVED HAZARDOUS CONSTITUENTS TAKING INTO ACCOUNT THE VARIATION IN WATER TABLE ELEVATIONS . BENZENE IS A HAZARDOUS CONSTITUENT. EPA HAS DETERMINED THAT THE PRESENCE OF BENZENE IN WELLS NSCMW-02A, NSCMW-03, NSCPZ-03 AND NSCMW-08, AT MULTIPLE TIMES, AT CONCENTRATIONS EXCEEDING 5 PARTS PER BILLION, DURING THE TIME FRAME OF 10/15/96 TO 8/7/98, CONSTITUTES VIOLATIONS OF THE 1989 CONSENT ORDER (SEE DOCKET #08-89-0048). A CASH PENALTY OF $72,500 IS ASSESSED. CONOCO, INC. SHALL ALSO PERFORM A SEP, WHICH WILL SIGNIFICANTLY REDUCE SULFUR EMISSIONS. A SIGNIFICANT SULFUR REDUCTION IS EQUIVALENT TO APPROXIMATELY 200 TONS PER YEAR.