AS EXPLAINED IN GREATER DETAIL IN THE ACCOMPANYING REPORT, AMERICAN HAS HAD A LONG SERIES OF CWA VIOLATIONS. SPECIFI- CALLY, AMERICAN HAS VIOLATED NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT CONDITIONS PROHIBITING THE DISCHARGE OF POLLUTANTS ABOVE CERTAIN LEVELS. UNFORTUNATELY , THE POLLUTANTS INVOLVED ARE SUCH DANGEROUS SUBSTANCES AS CYANIDE, HEXAVALENT AND TRIVALENT CHROMIUN, COPPER, AND ALU- MINUM, AS WELL AS THE MORE COMMONLY ENCOUNTERED SUSPENDED SOLIDS, OIL AND GREASE, AND PH. WHILE AMERICAN WAS FINED BY THE ILLINOIS POLLUTION CONTROL BOARD (IPCB) FOR THESE TYPES OF VIOLATIONS IN 1979, THE VIOL ATIONS CONTINUE. THE STATE OF ILLINOIS, THROUGH THE IEPA, HAS EXHAUSTED ALL ITS ADMINISTRATIVE REMEDIES, AND HAS SPECI FICALLY REQUESTED THAT U.S. EPA BRING FEDERAL ENFORCEMENT ACTION.