SYNOPSIS OF THE CASE PENNWALT CORPORATION ( THE COMPANY ) OPERATES A FAC- ILITY IN CALVERT CITY, KENTUCKY INVOLVED IN THE MANUFACTURE OF A VARIETY OF INDUSTRIAL CHEMICALS. THE FACILITY'S NPDES PERMIT NO. KY0003603 BECAME EFFECTIVE ON AUGUST 27, 1976 AND EXPIRED ON AUGUST 27, 1981. THE REQUIREMENTS OF THE AUGUST 27, 1976 PERMIT REMAINED IN EFFECT UNTIL THE PERMIT WAS RE- ISSUED AND BECAME EFFECTIVE ON APRIL 28, 1983. THE RE- ISSUED PERMIT EXPIRES ON APRIL 27, 1988. THE CALVERT CITY FACILITY IS A DIVERSIFIED INDUSTRIAL CHEMICAL PLANT PRODUCING HYDROFLOURIC ACID (HF), ISOTRON (PROPRIETARY FLUOROCARBON), SODIUM AND POTASSIUM CHLORATE, SODIUM AND POTASSIUM HYDROXIDE, ALSO VINYLIDINE FLUORIDE (KYNAR MONOMER) AND POLYVINYLIDENE FLUORIDE (KYNAR POLYMER). THE COMPANY HAS HAD A HISTORY OF NON-COMPLIANCE PRO- BLEMS AT THE FACILITY. THE VIOLATIONS RESULTED MAINLY FROM POOR HOUSEKEEPING OR POOR OPERATION AND MAINTENANCE OF TREATMENT SYSTEMS. PARAMETERS INVOLVED IN THESE PAST VIO- LATIONS WERE PH, FLUORIDE AND MERCURY. VIOLATIONS OF PH LIMITS WERE CAUSED BY BYPASSING OF TREATMENT STEPS OR SPILLS. FLUORIDE VIOLATIONS WERE CAUSED BY POOR OPERATION OF PH CONTROL AND POOR OPERATION AND MAINTENANCE OF THE CHLOR-CAUSTIC TREATMENT SYSTEM. AS A RESULT OF THESE PRO- BLEMS THE AGENCY ENTERED A CONSENT ADMINISTRATIVE ORDER WITH THE COMPANY IN MARCH 1982 TO CO