MEMORANDUM OPINION
CINDRICH, District Judge.
I. Introduction
This is an action by the United States for civil penalties for violations of the Clean Water Act, 33 U.S.C. §§ 1311, 1317 ("the Act"). The case covers five western Pennsylvania steel plants owned and operated by defendant Allegheny Ludlum Corporation ("ALC"), one of the few remaining steelmakers in the area. The plants are grouped for compliance purposes as the...
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