I. CASE SYNOPSIS THE GLIDDEN COMPANY ( GLIDDEN ) LOCATED IN HURON, OHIO OWNS AND OPERATES A MANUFACTURING FACILITY. AS EXPLAINED IN GREATER DETAIL IN SECTION III.A. BELOW, GLIDDEN MANUFACTURES OIL AND LATEX WATER-BASED PAINTS, RESINS, CAN COATINGS, AND POWDER NAVIGABLE WATER OF THE UNITED STATES. SINCE DECEMBER 1988, GLIDDEN HAS BEEN VIOLATING CERTAIN FINAL EFFLUENT LIMITATIONS ( FELS ), TERMS AND CONDITIONS CONTAINED IN ITES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM ( NPDES ) PERMIT NO OH0000621 ( PERMIT ). SEE ATTACHMENT 4. THESE VIOLATIONS ARE SUPPORTED BY THE FOLLOWING DOCUMENTATION: THE TABLE OF VIOLATIONS PREPARED BY GLIDDEN, LETTERS FROM GLIDDEN TO OHIO ENVIRONMENTAL PROTECTION AGENCY ( OEPA ) , OEPA NOTICES OF VIOLATIONS ( NOVS ), AND U.S. EPA'S PERMIT COMPLIANCE SYSTEM ( PCS ) DOCUMENT VIOLATIONS OF FELS FOR OIL AND GREASE ( O&G ) ; PH; TOTAL ZINC ( ZN-T ); TOTAL SUSPENDED SOLIDS ( TSS ) ; TOTAL COPPER ( CU-T ); CARBONACEOUS BIOCHEMICAL OXYGEN DEMAND - FIVE DAY ( CBOD5 ) ; BIOCHEMICAL OXYGEM DEMAND - FIVE DAY ( BOD5 ); TOTAL RESIDUAL CHLORINE ( TRC ) ; AND FECAL COLIFORM ( FEC. COL. ). ATTACHMENT 1, 8 AND 9. AS A RESULT OF THE ABOVE VIOLATIONSL U.S. WPA ISSUED AN ADMINISTRATIVE ORDER ( AO TO GLIDDEN ON MAY R, 1993 REQUIRING THE FACILITY TO COMPLY WITH ITS PERMIT BY JULY 9, 1993. IN THE RESPONSE TO THE AO, GLIDDE