IN JANUARY 2001, EPA CONDUCTED AN INSPECTION OF ALLEGHENY'S FACILITY IN WATERBURY, CT. THE INSPECTION AND SUBSEQUENT CONTACTS REVEALED THAT ALLEGHENY FAILED TO FILE FORM R'S FOR THE FACILITY FOR CALENDAR YEARS 1996 THRU 1999. THE FACILITY PROCESSED MANGANESE, CHROMIUM, AND NICKEL IN QUANTITIES ABOVE THE REPORTING THRESHOLDS.