PENNTECH PAPERS, INC. OPERATES AN INTEGRATED PULP & PAPER MILL USING THE KRAFT PROCESS LOCATED IN JOHNSONBURG, PA ON THE EAST BRANCH OF THE CLAIRTON RIVER. THE PLANT HAS BEEN IN OPERATION SINCE 1889 WHEN OPERATIONS BEGAN UNDER THE NAME OF THE CLAIRTON PULP & PAPER COMPANY. THE PLANT WAS LATER AQUIRED BY THE NY & PA COMPANY IN 1901 WHICH SUBSEQUENTLY CHANGED NAMES TO PENNTECH PAPERS, INC. IN 1979. THE JOHNSON- BURG FACILITY DISCHARGES INDUSTRIAL WASTEWATER TO THE CLAR- ION RIVER, & TO RILEY RUN A TRIBUTARY OF THE CLARION RIVER, THROUGH 2 PERMITTED OUTFALLS. THE EPA ISSUED THE JOHNSONBURG FACILITY ITS 1ST NPDES PERMIT ON 6/28/74; THIS PERMIT WAS ADMINISTRATIVELY EXTENDED UNTIL 9/29/85 WHEN THE PADER ISSUED PENNTECH ITS 2ND 5 YEAR PERMIT. BETWEEN 8/81 & 8/86, PENNTECH HAS VIOLATED THE EF- EFFLUENT LIMITATIONS CONTAINED IN ITS PERMITS ON AT LEAST 169 OCCASIONS. PENNTECH HAS FREQUENTLY VIOLATED THE BOD5 & TSS LIMITATIONS IN ADDITION TO SPORADIC VIOLATIONS OF THE PH & FECAL COLIFORM LIMITATIONS. THE FACILITY HAS BEEN IN SIG- NIFICANT NON-COMPLIANCE W/THE PERMIT II LIMITATIONS SINCE ITS ISSUANCE & HAS BEEN ON EVERY REGIONAL EXPECTATIONS LIST. THE POLLUTANTS DISCHARGED THROUGH THE 2 PERMITTED INDUS- TRIAL WASTEWATER OUTFALLS OPERATED BY PENNTECH PAPERS HAS PRODUCED SOME VERY NOTICEABLE CHANGES TO THE RECEIVING WA- TERS, WHICH INCLUDE DISCOLORATION & ORDOR. IT IS ALSO BE- LIEVED THAT THE JOHNSONBURG FACILITY IS