MACALLOY CORP. IS LOCATED AT 1800 PITTSBURGH AVENUE, CHARLESTON COUNTY, SC. SINCE ITS CONSTRUCTION IN 1941, FACILITY HAS MANUFACTURED FERROCHROMIUM. FERROCHROMIUM IS AN ALLOY OF IRON & CHROMIUM, USED TO MAKE STAINLESS STEEL & ALLOY STEELS. MACALLOY CORP., AS OF 9/30/94, HAD CURRENT ASSETS OF APPROX $9.3 MILLION. HOWEVER, DUE TO A LOSS OF ITS CONTRACT W/ THE U.S. DEPT OF DEFENSE, MACALLOY IS AT LIMITED PRODUCTION OF PERROCHROMIUM. MACALLOY OPERATES UNDER A SC NPDES PERMIT (NO. SC0004014). THE PERMIT AUTHORIZES 4 SURFACE WATER DISCHARGE POINTS INTO SHIPYARD CREEK. CURRENT NPDES PERMIT WAS ISSUED ON 9/11/95, & EXPIRES ON 1/31/2000. MACALLOY'S DMRS CHRONICLE NUMEROUS PERMIT EFFLUENT LIMITATION VIOLATIONS BETWEEN JAN 1993 (INITIAL DATE FOR PURPOSES OF THIS ACTION, & THE PRESENT. THESE VIOLATIONS INCLUDE SUCH SIGNIFICANT PARAMETERS AS TOTAL CHROMIUM, HEXAVALENT CHROMIUM, AND TOTAL SUSPENDED SOLIDS, AS WELL AS VIOLATIONS OF PH, TOTAL MANGANESE, FECAL COLIFORM, TOTAL CYANIDE, OIL & GREASE, & TOTAL RESIDUAL CHLORINE. IN ADDITION, EVIDENCE THAT UNPERMITTED CONTAMINATED STORMWATER DISCHARGES HAD OCCURRED, WAS OBSERVED DURING AN EPA MULTIMEDIA INSPECTION CONDUCTED ON MAY 7-8, 1996. IN TOTAL, EPA HAS IDENTIFIED 5,623 VIOLATIONS, INCLUDED THOSE DISCOVERED DURING THE 2-DAY MULTIMEDIA INSPECTION. AT $25,000 PER DAY PER VIOLATION, TOTAL STATUTORY MAXIMUM PENALTY IS: $140,575,000. WHILE THE STATE OF SC EXERCISES PRIMARY PROGRAM IMPLEMENTATION AUTHORITY, EPA RETAINS AUTHORITY TO AD