THIS CASE INVOLVES MULTIPLE VIOLATIONS OF THE CAA, CWA AND RCRA BY LTV STEEL CO., INC. ( LTV ) AT ITS STEEL MILL FACILITY LOCATED AT 3100 E. 45TH ST., CLEVELAND, CUYAHOGA COUNTY, OHIO. THESE VIOLATIONS WERE DISCOVERED DURING THE COURSE OF A MULTIMEDIA INSPECTION OF THE FACILITY CONDUCTED FROM MARCH 25, 1996, THROUGH APRIL 4, 1996, BY U.S. EPA. THE CAA VIOLATIONS CONSIST OF (1) EXCEEDANCES OF THE OPACITY (PARTICULATE MATTER) LIMITS PERTAINING TO TWO OF LTV'S BLAST FURNACES AND ONE OF ITS BASIC OXYGEN FURNACE SHOPS; AND (2) EXCEEDANCES OF THE SULFUR DIOXIDE (SO2) LIMITATIONS SET FORTH IN THE FEDERAL IMPLEMENTATION PLAN ( FIP ) FOR THE FACILITY, 40 C.F.R. SEC. 52.1881 (B)(15)(XI)(A). THE CWA VIOLATIONS CONSIST PRIMARILY OF (1) NUMEROUS UNAUTHORIZED DISCHARGES; (2) EXCEEDANCES OF THE EFFLUENT LIMITS SET FORTH IN LTV'S NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM ( NPDES ) PERMIT; AND (3) THE FAILURE TO TIMELY COMPLY WITH A REQUEST FOR INFORMATION ISSUED TO LTV BY U.S. EPA. THE RCRA VIOLATIONS CONSIST OF (1) THE FAILURE TO CONDUCT ANNUAL TRAINING OF PERSONNEL INVOLVED IN THE MANAGEMENT OF HAZARDOU S WASTE; AND (2) THE FAILURE TO OPERATE THE FACILITY IN A MANNER SO AS TO MINIMIZE THE POSSIBILITY OF AN UNPLANNED RELEASE OF HAZARDOUS WASTE.