THIS IS A MULTI-MEDIA ACTION INVOLVING CWA, CAA, AND RCRA. THE VIOLATIONS INVOLVE PERMIT EXCEEDENCES, DISCHARGING W/OUT A PERMIT, AND VARIOUS REGULATORY VIOLATIONS. THE CASE WAS ORIGINALLY PART OF A NESS INVESTIGATION; A CITIZEN SUIT WAS FILED IN FEDERAL COURT AGAINST THE DEFENDANT SO THIS FACILITY WAS SEPARATED OUT AND REFERRED INDIVIDUALLY. STATUTES INVOLVED ARE: CAA, CWA, RCRA, AND OPA. THE CAA VIOLATIONS INCLUDE FAILURE TO OPERATE A GAS BLANKETING SYSTEM USED TO CONTROL BENZENE EMISSIONS AND NUMEROUS MONITORING AND REPORTING REQUIREMENTS.