ALLEGHENY LUDLUM CORPORATION (ALC) VOLUNTARILY DISCLOSED RCRA AND OPA SPCC VIOLATIONS TO EPA BY LETTERS DATED 2/28/01, 6/21/01, AND 8/7/01, AS PART OF EPA'S MINI-MILL SELF-DISCLOSURE INCENTIVES INITIATIVE. THESE VIOLATIONS OCCURRED AT THE COMPANY'S HOUSTON, PA, AND BRECKENRIDGE, PA FACILITIES. SPECIFICALLY ALC DISCOVERED, THROUGH A VOLUNTARY ENVIRONMENTAL AUDIT OF THESE FACILITES A TOTAL OF 3 OPA AND 1 RCRA VIOLATION. THE SPCC VIOLATIONS WERE 1) FAILURE TO SECURELY CAP OR BLANK-FLANGE WHEN NOT IN SERVICE, THE LOADING/UNLOADING OF CONNECTIONS OF OIL AT AN AST, 2) FAILURE TO ENSURE THAT THE MEANS OF CONTAINMENT IN A SECONDARY CONTAINMENT AREA SURROUNDING AN AST AREA COULD PROVIDE FOR THE ENTIRE CONTENTS OF THE LARGEST SINGLE TANK, AND 3) FAILURE TO HAVE THE FACILITY'S SPCC PLAN CERTIFIED BY AN INDEPENDENT PE. THE RCRA VIOLATION ENTAILED FAILURE TO ENSURE THAT THE FACILITY'S CONTAINMENT SYSTEMS CONTAINING ITS HAZARDOUS WAST CONTAINER STORAGE AREA, WAS FREE OF CRACK OR GAPS SO AS TO CONTAIN LEAKES. RESPONDENT SATISFIED ALL NINE CONDITIONS OF THE A/P, AND EPA ELECTED TO WAIVE 100% OF THE GBP. THE NOD WS ISSUED ON 9/25/01.