THE LITIGATION REPORT CITES THE VIOLATION OF CERTAIN EFFLUENT LIMITATIONS, INCLUDING PROHIBITIONS ON SPILLS AND SHEENS, AS WELL AS A NUMBER OF REPORTING VIOLATIONS COMMITTED BY THE COMPANY. SPECIFICALLY, AT THE COMPANY'S VANDERGRIFT FACILITY, ALC HAS VIOLATED, INTER ALIA, THE EFFLUENT LIMITATIONS IN BOTH ITS INDUSTRIAL USER PERMIT ISSUED BY THE KISKI VALLEY WATER POLLUTION CONTROL AUTHORITY) AND ITS NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM ( NPDES ) PERMIT. THE VIOLATIONS OCCURRING AT ALC'S BRACKENRIDGE AND WEST LEECHBURG PLANTS WERE PRIMARILY VIOLATIONS OF THE NPDES PERMIT LIMITATIONS ON DISCHARGE OF OIL CAUSING A VISIBLE SHEEN ON THE WATERS AND OTHER EFFLUENT DISCHARGES IN EXCESS OF THE AMOUNTS ALLOWED IUNDESE THOSE PERMITS. FOR THESE VIOLATIONS, EPA HAS REQUESTED THAT DOJ OBTAIN BOTH SUBSTANTIAL PENALTIES AND INJUNCTIVE RELIEF, INCLUDING REQUIRING ALC TO STUDY THE CAUSE OF ITS VIOLATIONS TO ADDRESS THE VARIOUS SYSTEMIC PROBLEMS. *****SUPPLEMENTAL REFERRAL CITES ADDITIONAL VIOLATIONS (OIL SPILLS) AT ALLEGHENY'S FACILITIES; THESE SPILLS ARE VIOLATIONS OF CWA SECTIONS 301 AND 311.