GREAT LAKES CHEMICAL CORPORATION (HEREINAFTER 'GLCC') OWNS AND OPERATES A FACILITY IN EL DORADO, AR WHICH EXTRACTS BROMINE FROM SUBSURFACE BRINE AND PRODUCES BROMINE AND BRO- MINATED COMPOUNDS SUCH AS ETHYLENE DIBROMIDE (EDB) FOR COM- MERCIAL USE. GLCC HAS BEEN DISCHARGING PROCESS WASTEWATER FROM THE SODIUM HYDROGEN SULFIDE UNIT THROUGH OUTFALL 001 WHICH IS PERMITTED FOR UNONTAMINATED ONCE-THROUGH COOLING. 40 CFR 415.292 PROHIBITS THE DISCHARGE OF PROCESS WASTEWATERS TO NAVIGABLE WATERS AS WELL. A SAMPLE TAKEN BY THE ADPCE, INDICATED DIMETHYL DISULFIDE, MOLECULAR SULFUR, 2,4,6 - TRIBROMOPHENOL, AND 3,4 - DIBROMOPHENOL WERE BEING DIS- CHARGED. IN ADDITION, SAMPLES TAKEN BY GLCC, EPA AND ADPCE VERIFIED THAT THE DISCHARGE WAS CONTAMINATED BY VARIOUS ORGANICS AND EDB. ON MAY 2, 1988, A BREAK IN THE 001 DISCHARGE LINE OC- CURRED AND WAS NOT REPAIRED BY GLCC UNTIL MAY 4, 1988. THIS INCIDENT RESULTED IN A DISCHARGE TO BAYOU D'LOUTRE FROM AN UNAUTHORIZED POINT AND WAS OBSERVED BY EPA PERSONNEL. SAMPLES WERE ALSO TAKEN AND ANALYZED FOR ORGANICS, PESTI- CIDES, PCB AND EDB. SINCE 1983, GLCC HAS BEEN IN THE PROCESS OF CONTESTING CERTAIN TERMS OF ITS PERMIT WHICH WAS REISSUED ON SEPT 23, 1983 (EXHIBIT A) TO REPLACE A PRIOR PERMIT EXPIRED MARCH 31, 1981. PURSUANT TO THE JUDICIAL REVIE