NATURE OF THE CASE: ITT RAYONIER INC., OWNS & OPERATES A PLANT IN FERNANDINA BEACH, FLORIDA, ENGAGED IN THE MANUFACT- URE OF CHEMICAL CELLULOSE FROM SOUTHERN PINE USING THE AM- MONIA-BASE SULFITE PROCESS. NPDES PERMIT ISSUED ON 04/05/79. NUMEROUS PROBLEMS WITH UNPERMITTED DISCHARGES CONTINUE-31 UNPERMITTED DISCHARGES IN PAST 6 YEARS. COMPANY INITIATED SOME MEASURES BUT THESE WERE MOSTLY UNSUCCESSFUL. COMPANY UNWILLING TO TAKE FURTHER PREVENTIVE MEASURES. ALSO NUMBEROUS EFFLUENT VIOLATIONS OF ITS NPDES PERMIT.