BACKGROUND: * COASTAL REFINING AND MARKETING, INC. HAS A CRUDE OIL REFINERY FACILITY IN CORPUS CHRISTI, TX, WHERE, BY THEIR OPERATIONS THEY GENERATE HAZ WASTES WHICH INCLUDES API SEPA- RATOR SLUDGE, SLOP OIL EMULSIONS AND DAF FLOAT. THEY TREAT, STORE OR DISPOSE OF THESE WASTE IN SURFACE IMPOUNDMENTS AND A LANDFILL. * THIS FACILITY WAS INSPECTED BY A REPRESENTATIVE OF THE EPA ON FEB 11, 1986, AND BY A REPRESENTATIVE OF THE TEXAS WATER COMMISSION ON FEB 26, 1987. THESE INSPECTION REPORTS SHOW THAT THE RESPONDENT MANAGES HAZARDOUS WASTES IN THE SURFACE IMPOUNDMENTS. RESPONDENT DID NOT CERTIFY COMPLIANCE WITH THE LOIS PROVISIONS FOR A LAND DISPOSAL FACILITY. * EPA WILL SHOW THAT THE RESPONDENT HAS VIOLATED THE FOLLOWING REGULATIONS: - OPERATION OF A LANDFILL AND SURFACE IMPOUNDMENTS WITH- OUT A PERMIT; - INADEQUATE GROUNDWATER MONITORING SYSTEM AT THE LAND- FILL AND SURFACE IMPOUNDMENT; - FAILURE TO PROVIDE AN ADEQUATE CLOSURE COST ESTIMATE; - FAILURE TO ESTABLISH FINANCIAL ASSURANCE FOR CLOSURE; - FAILURE TO DEMONSTRATE FINANCIA