STERLING CASKET HAS FAILED TO COMPLY WITH AN ADMINISTRA- TIVE CONSENT AGREEMENT AND ORDER ENTERED INTO BY THE COMPANY AND REGION III ON AUGUST 15, 1985, AND HAS FAILED TO COMPLY WITH CERTAIN RCRA SUBTITLE C CLOSURE REGULATIONS. IN THE CONSENT AGREEMENT THE COMPANY AGREED TO SUBMIT A PLAN AND SCHEDULE THE MODIFICATION OF ITS PLATING PROCESS TO ELIMINATE FURTHER TREATMENT, STORAGE, AND DISPOSAL OF HAZARD OUS WASTES AT ITS FACILITY; SUBMIT A CLOSURE PLAN FOR ALL HAZARDOUS WASTE FACILITIES OPERATED AT ITS FACILITY SINCE NOVEMBER 19, 1980 WITHOUT INTERIM STATUS OR A PERMIT; AND TO COMPLY WITH ALL APPLICABLE STATE AND FEDERAL REGULATIONS CONCERNING CLOSURE OF THE HAZRDOUS WASTE FACILITIES. TO DATE STERLING CASKET HAS NOT COMPLETED CLOSURE ACTIVITY PURSUANT TO A CLOSURE PLAN WHICH WAS APPROVED ON APRIL 7, 1987. THE APPLICABLE VIRGINIA CLOSURE REGULATION REQUIRED CLOSURE TO HAVE BEEN COMPLETED WITHIN 180 OF APPROVAL OF THE CLOSURE PLAN, BY OCTOBER 5, 1987. FURTHERMORE STERLING CASKET HAS FAILED TO COMPLY WITH THE APPLICABLE VIRGINIA CLOSURE REGU- LATION REQUIRING THE COMPANY TO PROVIDE FONANCIAL ASSURANCE TO COVER THE ESTIMATED COSTS OF THE CLOSURE ACTIVITIES. EPA THUS SEEKS INJUNCTIVE RELIEF AND STATUTORY PENALTIES