SHARON STEEL CORPORATION IS A PUBLICALY HELD PA CORPORATION HEADQUARTERED IN SHARON, PA. IT HAS 6 PRINCIPAL SUBSIDIARIES INVOLVED IN FINISHING STRIP STEEL & OTHER UNRELATED MANUFACTURING & METALS MINING & PROCESSING INDUSTRIES. THE VIC POSNER WORKS(VPW) FACILITY IS THE SUBJECT OF THIS ACTION. VPW IS SHARON'S MAIN PLANT &THE ONLY PLANT THAT PRODUCES & FINISHES STRIP STEEL. IT DISCHARGES TO THE SHENANGO RIVER THRU 4 OUTFALLS. EPA ISSUED THE VPW FACILITY ITS 1ST NPDES PERMIT IN 12/74 (PERMIT I); THIS PERMIT WAS ADMINISTRATIVELY EXTENDED UNTIL 9/85. BETWEEN 1/81 & 9/85, SHARON VIOLATED THE EFFLUENT LIMITATIONS CONTAINED IN ITS PERMIT AT LEAST 1,121 OCCASIONS. DURING PART OF THIS PERIOD SHARON WAS COVERED BY A STATE JUDICIAL CD, WHICH DELAYED VARIOUS FINAL COMPLIANCE DATES W/OUT CONCURRENTLY ESTABLISHING INTERIM LIMITS; THIS CD MAY REDUCE SHARON'S ACTIONABLE VIOLATIONS TO 965. PA DEPT OF ENVIRONMENTAL RESOURCES(PADER) REISSUED A MORE STRINGENT BAT PERMIT IN 9/85(PERMIT II). UPON REISSUANCE, THE FREQUENCY OF VIOLATIONS, WHICH HAD STARTED TO IMPROVE IN EARLY 1985, DRA- MATICALLY INCREASED. SHARON HAS APPEALED PERMIT II, BUT SINCE PERMIT II REMAINS IN FULL FORCE & EFFECT UNDER STATE LAW IT IS FEDERALLY ENFORCEABLE. AVAILABLE WATER QUALITY DATA INDICATES THAT SHARON VPW IS CONTRIBUTING TO VIOLATIONS OF WATER QUALITY STANDARDS FOR FE & MAY BE CAUSING OTHER SUCH VIOLATIONS FOR FREE CYANIDE & OTHER TOXIC POLLUTANTS. HOWEVER, THERE IS NO EVIDENCE THAT SHARON'S DISCHARGES ARE