BACKGROUND: ON SEPTEMBER 30, 1998 USEPA FILED AN ADMINI- STRATIVE PENALTY COMPLAINT (APO) AGAINST ORMET'S ROLLING MILL FACILITY AND ITS PRIMARY FACILITY. THE VIOLATIONS IDENTIFIED AT THESE FACILITIES WERE DUE TO A MULTI-MEDIA INSPECTION CONDUCTED BY U.S. EPA IN OCTOBER OF 1997. BOTH FACILITIES ARE LOCATED IN HANNIBAL, OHIO. CLEAN WATER ACT VIOLATIONS OF NPDES EFFLUENT DISCHARGE LIMITS, MONITORING REQUIREMENTS AND REPORTING REQUIREMENTS. RESOURCE CONSERVATION AND RECOVERY ACT VIOLATIONS OF FAILURE TO PROPERLY LABEL HAZARDOUS WASTE DRUMS AND PERSONNEL TRAIN- ING. THIS CASE IS ONE OF TWO ADMINISTRATIVE PENALTY ORDERS BY U.S. EPA AGAINST ORMET CORPORATION. HOWEVER, THE OTHER ADMINISTRATIVE ACTION IS BROUGHT AGAINST AN ADJACENT FACILITY KNOWN AS THE ORMET ALUMINUM PRODUCTS CORPORATION OR THE ROLLING MILL. THE CASE NUMBER FOR THAT FACILITY IS CWA-5-98-017.