NATURE OF THE CASE: DIAMOND SHAMROCK IS A DIVERSIFIED INTERNATIONAL CORP MINISTRATIVE, MARKETING & PRODUCTION FACILITIES THROUGH- OUT THE US & IN APPROX 30 OTHER NATIONS. THE CO'S DEER PARK WORKS CONSISTS OF THE SEVERAL FACILITIES WHICH MANU- FACTURE & PROCESS ORGANIC & INORGANIC CHEMICALS. CAUSE OF ACTION: THIS ASE INVOLVES A DISCHARGE OF APPROX 19,400 PDS CHLORINATED HYDROCARBONS OVER A 48 HR PD FROM DIAMOND SHAMROCKS DEER PARK WORKS IN VIOL OF SEC 301 & 311 OF THE CWA. THE CO STATED IN ITS COMPLIANCE REPORT THAT THE CAUSE OF THE DISCHARGE WAS ALEAK IN AN ETHLYENE DICHLOR- IDE(EDC) REACTOR COOLING COIL. AT THE RELEVANT OUTFALL (003), THE DAILY MAXIMUM EFFLUENT LIMITATION FOR CHLORIN- ATED HYDROCARBONS IS 900 PDS/DAY. ON 12/26/80, APPROX 18,366 PDS OF CHLORINATED HYDROCARBONS WERE DISCHARGED FROM 003, & ON 12/27/80, APPROX 1,162 PDS WERE DISCHARGED . IN ADDITION TO CONSTITUTING 2 DAILY MAXIMUM PERMIT VIOL'S, THE DISCHARGE ALSO CONSTITUTED A VIOL OF THE 12/80 DAILY AVERAGE LIMITATION FOR CHLORINATED HYDRO- CARBONS AT 003. ALTERNATIVELY, THE 12/6/80 CHLORINATED HYDROCARBON DISCHARGE( IN THE FORM OF EDC) MAY HAVE CONSTITUTED A VIOL OF SEC 311 OF THE CWA BECAUSE IT WAS OF AN EPISODIC NATURE & WAS IN EXCESS OF THE REPORTA