THIS IS A PROPOSED CIVIL ACTION AGAINST OLIN CORPORATION TO OBTAIN CIVIL PENALTIES FOR SEVERAL VIOLATONS OF THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP), 40 C.F.R. PART 61, SUBPART A - GENERAL PROVISIONS AND SUBPART E-NATIONAL EMISSION STANDARD FOR MERCURY. THIS CASE INVOLVES THE CHARLESTON, BRADLEY COUNTY, TENNESSEE, CHLORINE PRODUCTION FACILITY OWNED AND OPERATED BY OLIN. BASED ON INSPECTIONS CONDUCTED BY EPA AND INFORMA- TION GAINED FROM THE DEFENDANT, IT WAS DETERMINED THAT OLIN CORPORATION FAILED TO ABIDE BY THE GOOD-HOUSEKEEPING PRACTICES REFERENCED IN 40 C.F.R. SECTION 61.53. THE NESHAP MERCURY STANDARDS REGULATE THE AMOUNT OF MERCURY EMISSIONS ALLOWABLE FROM THE CHLOR-ALKALI CELL ROOM PROCESS USED IN THE MANUFACTURE OF CHLORINE. THE SPECIFIC VIOLATIONS WERE: 1) ON AUGUST 22, 1988, OLIN FAILED TO CONTAIN ELEMENTAL MERCURY SPILLS DURING THE MAINTENANCE PROJECT IN ITS E-182 CELL ROOM; 2) AN EPA DECEMBER 13, 1988, INSPECTION OF THE CELL ROOM FOUND THE CELL FLOOR BADLY CRACKED AND MERCURY DROPLETS WERE FOUND IN SEVERAL OF THE CRACKS AND FLOOR SEAMS; 3) OLIN CORPORATION FAILED TO RECORD THE AUGUST 22, 1988 MERCURY SPILL; 4) OLIN CORPORATION FAILED TO MAKE TIMELY LEAK REPAIRS IN THE CELL ROOM BUILDING; AND 5) OLIN CAUSTIC HEADER PIPE IN THE CELL ROOM. EPA IS SEEKING INJUNCTIVE RELEIF AND PENALTIES FOR THE PAST VIOLATIONS. THIS IS THE INITIAL NESHAP MERCURY C