THE LOCAL REGULATORY AGENCY, HAMILTON COUNTY DEPARTMENT OF ENVIRONMENTAL SERVICES, INFORMED U.S. EPA OF POSSIBLE VIOLATIONS OF THE CHROME PLATING NESHAP AT LUCAS IN THE SUMMER OF 1998. AN INITIAL REQUEST FOR INFORMATION WAS SENT TO LUCAS IN THE FALL OF 1998 TO GATHER EVIDENCE OF THESE SUSPECTED VIOLATIONS. VIOLATIONS OF VARIOUS MONITOR- ING, RECORDKEEPING, REPORTING, AND WORKPRACTICE STANDARDS WERE IDENTIFIED IN THE REAPONSE TO THIS REQUEST. U.S. EPA ISSUED A FINDING OF VIOLATION TO LUCAS FOR THESE VIOLATIONS ON DECEMBER 31, 1998. A SUBSEQUENT REQUEST FOR INFORMATION WAS SENT WITH THE FINDING OF VIOLATION. THIS REQUEST REQUIRED LUCAS TO CONDUCT A PERFORMANCE TEST. THE GOAL OF THE TEST WAS TO ASSIST LUCAS IN COMING INTO COMPLIANCE WITH THE CHROME PLATING NESHAP. AT A MARCH 1999 SECTION 113 CONFERENCE, LUCAS PRESENTED TO U.S. EPA THE RESULTS OF THIS TEST AND OTHER ACTIONS IT HAS TAKEN TO COME INTO COMPLIANCE AND INSURE FUTURE COMPLIANCE WITH THE CHROME PLATING NESHAP. LUCAS WAS THEN GIVEN THE OPPORTUNITY TO DISCUSS SETTLEMENT TERMS WITH U.S. EPA PRIOR TO ISSURANCE OF AN ADMINISTRATIVE PENALTY ORDER. LUCAS AND U.S. EPA AGREED TO A PENALTY OF $30,000. LUCAS SIGNED A CONSENT AGREEMENT/CONSENT ORDER IN JUNE OF 1999. U.S. EPA WILL NOW FILE THE CONSENT AGREEMENT/ CONSENT ORDER CONCURRENTLY WITH THE ADMINISTRATIVE PENALTY ORDER BY JUNE 30, 1999.