THE LITIGATION REPORT IS IN SUPPORT OF A REQUEST FOR A CIVIL ACTION AGAINST TENNESSEE GAS PIPEINE COMPANY (TGPL) TO ENFORCE SECT 301 OF THE CLEAN WTR AIR, 33 U.S.C. 1311. THIS LITIGATION REPORT CONCERNS VIOLATIONS OF TGPL'S NPDES PERMIT INCLUDING THE UNAUTHORIZED DISCHARGE OF PCB'S FROM TGPL'S NATCHITOCHES TRANSMISSION STATION #40, IN NATCHITOCHE S, LA. INTO SIBLEY LAKE. EPA ISSUED A NPDES PERMIT (LA00056 31) TO TGPL ON APRIL 24, 1974 AUTHORIZING THE DISCHARGE FROM OUTFALL 001 INTO SIBLEY LAKE. ON THE FORM 2C FOR RENEWAL OF THE PERMIT, TGPL IN AUGUST OF 1985 INDICATED THAT INFORMATIO N REQUIRED FOR PRIORITY POLLUTANTS INCLUDING PCB'S WAS NOT APPLICABLE. THE NPDES PERMIT WAS REISSUED WITH AN EFFECTIVE DATE OF JULY 12, 1986. TG?; CONDUCTED A SAMPLING PROGRAM IN 1987 AND 1988 WHICH INDICATED THE PRESENCE OF PCB CONTAMINAT ION IN THE SOILS AT THE FACILITY, IN THE SEDIMENT IN THE DRAINAGE SYSTEM, AND IN THE SEDIMENT OF LAKE SIBLEY NEAR THE AREA OF THE DISCHARGE PIPES. THE DISCHARGE OF PCBS INTO LAKE SIBLEY, THE DRINKING WTR SUPPLY FOR THE CITY OF NATCHITOCHES, LOUISIANA IS UNAUTHORIZED AND A VIOLATION OF SECTION 301 OF THE CLEAN WTR ACT. TGPL ALSO REPORTED DISCHARGES OF OIL AND GREASE IN EXCESS OF THE DAILY MAX- IMUM LIMIT AND FAILED TO REPORT ON SEVERAL OCCASSIONS. EPA REGION 6 SEEKS A PENALTY OF 166,400.