THIS QUANEX FACILITY MANUFACTURERS STEEL RODS AND BARS FROM RECYCLED STEEL. ITS NPDES PERMIT ALLOWS THE DISCHARGE OF THE FACILITY'S WASTEWATER TO AN UNNAMED WETLAND CONTIGUOUS TO ACKERMAN DRAIN AND THE GRAND RIVER. IN 9/97, USEPA INSPECTED THE FACILITY AND FOUND MONITORING DEFICIENCIES. PCS DATA ALSO SHOWED EFFLUENT VIOLATIONS. CONSEQUENTLY, USEPA SENT QUANEX A FINDING OF VIOLATIONS AND REQUEST FOR INFORMATION ORDER. A REVIEW OF THE QUANEX RESPONSE TO THIS ORDER ESTABLISHED ADDITIONAL EFFLUENT VIO- LATIONS. THE QUANEX RESPONSE INCLUDED A SCHEDULE OF COMPLI- ANCE. AFTER TWO EXTENSIONS BY USEPA OF THE COMPLIANCE DATE (AT QUANEX'S REQUEST), QUANEX APPEARS TO HAVE COME TO COM- PLIANCE SINCE 6/00. THE PENALTY ORDER AIMS TO RECOVER BOTH THE ECONOMIC BENE- FIT AND THE GRAVITY COMPONENT ASSOCIATED WITH QUANEX'S NON- COMPLIANCE WITH ITS NPDES PERMIT.