CLARK OIL OPERATES A REFINERY IN GARYVILLE, LA. THE FACILITY HAS A NPDES PERMIT (# LA0051993), ISSUED BY REG VI. CLARK OIL HAS A LONG HISTORY OF SERIOUS EFFLUENT VIOLATIONS FOR VIRTUALLY EVERY LIMIT CONTAINED IN THE PERMIT. THESE VIOLATIONS HAVE BEEN THE SUBJECT OF ADMINISTRATIVE ENFORCE- MENT ACTIONS BY BOTH THE EPA AND THE STATE OF LA. A 1982 ADMIN ORDER AND ACCOMPANYING $45,000 PENALTY ASSESSMENT WAS ISSUED BY THE LA. STREAMCONTROL COMMISSION. IT ORDERED CLARK TO INSTALL ADDITIONAL WASTEWATER TREATMENT FACILITIES AT THE REFINERY. WHILE CONSTRUCTION OF THESE FACILITIES WAS ONGOING, THE CO. WAS FAILING TO MEET ITS EFFLUENT LIMIT- ATIONS. NEAR THE COMPLETION OF CONSTRUCTION IN JAN. 1983, AND CONTINUING UNTIL MAY 1983, CLARK OIL VIOLATED EFFLUENT PARAMETERS FOR ROD, TSS, COD, OIL & GREASE, PHENOL, AMONIA, AND SULFIDE. THESE VIOLATIONS ARE THE BASIS OF THIS ACTION. CLARK HAS A HISTORY OF SERIOUS EFFLUENT VIOLATIONS. THE COMPANY HAS FAILED TO OPERATE ITS PLANT IN SUCH A MANNER AS TO FORSEE & AVERT THE PROBLEMS WHICH LED TO THE VIOLATIONS. CLARK HAS ATTEMPTED TO RESPOND TO THESE PROBLEMS, BUT ONLY AFTER THEY HAVE DEVELOPED, AND EVEN THEN, NOT IN THE MOST EXPEDITIOUS OR SATISFACTORY MANNER. TO THIS POINT, CLARK HAS BEEN UNABLE TO UNWILLING TO PROVIDE ANY FIRM ASSURANCES THAT EFFLUENT VIOLATIONS WILL NOT CONTINUE. THE PLANT IS CURRENTLY SHUT DOWN, DUE TO THE UNFAVORABLE MARKET CONDITIONS IN THE AREA. IT IS