BACKGROUND: ON SPETEMBER 30, 1998, USEPA FILED AN ADMINI- STRATIVE PENALTY COMPLAINT (APO) AGAINST ORMET'S ROLLING MILL 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 FACILITY ARE LOCATED IN HANNIBAL, OHIO. CLEAN WATER ACT VIOLATIONS OF NPDES EFFLUENT DISCHARGE LIMITS, MONITORING REQUIREMENTS AND REPORTING REQUIREMENTS. THIS CASE IS ONE OF TWO ADMINISTRATIVE PENALTY ORDERS BROUGHT BY U.S. EPA AGAINST ORMET CORPORATION. HOWEVER, THE OTHER ADMINISTRATIVE ACTION IS BROUGHT AGAINST AN ADJACENT FACILITY KNOWN AS THE ORMET PRIMARY ALUMINUM CORPORATION. THE CASE NUMBER FOR THAT FACILITY IS VW-97-AO-37.