NATURE OF THE CASE: TWO COKE OVEN BATTERIES, A BASIC OXYGEN FURNACE SHOP & 2 BLAST FURNACES HAVE BEEN CITED FOR OPACITY & MASS EMISSION VIOL'S UNDER SEC 113 OF THE CAA THESE FACILITIES ARE LOCATED IN A NONATTAINMENT AREA FOR PARTICULATES (AREA IS UNDESIGNATED). CAUSE OF ACTION: THE IRON & STEEL MAKING PROCESSES WERE CITED IN NOVS AS IN VIOL OF THE OPACITY & MASS EMISSION REG'S UNDER THE STATE IMPLEMENTATION PLAN. NUMEROUS READINGS TAKEN AT THE PLANT INDICATE CONTINUING VIOL'S OVER MORE THAN A THREE YR PERIOD. PROPOSED REMEDY: EPA IS SEEKING INJUNCTIVE RELIEF & CIVIL PLTY'S OF $25K PER DAY OF VIOL. CONTROL TECH EXISTS FOR POLLUTION ABATEMENT. EPA IS SEEKING INSTALLATION OF THIS CONTROL TECHNOLOGY. NATIONALLY SIGNIFICANT ISSUES: THE OPACITY REGULATION IN THE FED SIP WAS VIEWED BY BETHLEHEM AS AN INVALID REGULATION. HOWEVER, THE 7TH CIR RECENTLY UPHELD THE VALIDITY OF THE REGULATION. LEAD ATTY:PETER KELLY