THIS ADMINISTRATIVE PENALTY ORDER IS ISSUED TO THE CITY OF GREAT FALLS FOR FAILURE TO ISSUE OR REISSUE A DISCHARGE PERMIT TO MONTANA SPECIALTY MILLS, ONE OF SEVEN SIGNIFICANT INDUSTRIAL USERS DISCHARGING INTO GREAT FALLS POTW; FAILURE TO INSPECT EACH SIU EVERY YEAR; FAILURE TO RECEIVE AND ANALYZE SIU SELF-MONITORING REPORTS; FAILURE TO INVESTIGATE AND ENFORCE NONCOMPLIANCE AND FAILURE TO IMPLEMENT AN ENFORCEMENT RESPONSE PLAN; FAILURE TO COMPLY WITH PUBLIC PARTICIPATION REQUIREMENTS; AND FAILURE TO HAVE SUFFICIENT RESOURCES AND QUALIFIED PERSONNEL. THE PROPOSED PENALTY FOR THESE VIOLATIONS IS $134,000.