NATURE OF THE CASE: THE AMERICAN CYANAMID CO HAD A SPILL OF SULFURIC ACID AT ITS WARNERS PLANT IN LINDEN, NJ ON 7/11/82. APP- ROX 8.3 TONS OF 99% PURE SULFURIC ACID WERE DISCHARGED FROM AN OVERFLOW LINE DURING THE FILLING OF AN ACID STOR- AGE TANK. THE ACID SOAKED INTO THE GROUND & SEEPED INTO THE ARTHUR KILL. ALTHOUGH THE CO DID SPREAD SOME SODA LIME ON THE GROUND WHERE THE SPILL TOOK PLACE, THE AMOUNT USED WAS LESS THAN 2% OF THE AMOUNT NEEDED TO NEUTRALIZE THE ACID. THE CO REPORTED THE SPILL ON 7/12. EPA IS TAKING THE LEAD IN SEEKING PENALTIES FOR THIS SPILL UNDER SECTION 311(B)(6) OF THE CWA. THE CO SAID 8.3 TONS WERE SPILLED IN ITS NOTIFICA- TION OF THE SPILL, IN STATEMENTS TO EPA & COAST GUARD IN- VESTIGATORS, & IN A FOLLOW-UP LTR. HOWEVER, THE AMOUNT WAS CALCULATED THROUGH AN INVENTORY CHECK THE DAY AFTER THE SPILL. THE AMOUNT WAS NOT ESTIMATED THROUGH AN OBSER- VATION OF THE SPILL DIRECTLY SINCE THE ACID SIMPLY SOAKED INTO THE VERY PERMEABLE GROUND AROUND THE STORAGE TANK. THE CO HAS INDICATED THAT ITS CALCULATION MAY BE SUSPECT & MAY BE OFF BY AS MUCH AS 8 TONS. THIS REGN SUGGESTS THIS INDICATES THE SPILL MAY BE LARGER OR SMALLER THAN THE ESTIMATED 8.3 TONS REPORTED. SINCE THE AMOUNT OF SULFURIC ACID THAT WOULD BE HARMFUL IF SPILLED IS .5 TONS BY REGULATION, THE POSSIBILITY OF THE