MEMORANDUM OPINION AND ORDER
JOSEPH F. ANDERSON, Jr., District Judge.
Introduction
The question presented in this case is whether Hoechst Celanese Corporation's Celriver Plant in Rock Hill, South Carolina, was required to comply with the National Emission Standard for Equipment Leaks (Fugitive Emission Sources) of Benzene (Benzene NESHAP), 40 C.F.R. Part 61, subpart J, during the period 1984 to 1991. The Company implemented the NESHAP in...
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