THE REFERRAL PROPOSES THE FILING OF A CIVIL ACTION PUR- SUANT TO 3008(A) OF RCRA, AS AMENDED BY HSWA, AGAINST NATION AL ROLLING MILLS, INC. FOR VIOLATIONS OF THE LAND DISPOSAL RESTRICTIONS SET FORTH AT 40 C.F.R. PART 268. THE REGION RECOMMENDS THAT THE COMPLAINT SEEK INJUNCTIVE RELIEF AND CIVIL PENALTY FOR THE FOLLOWING VIOLATIONS; 1) FAILURE TO COMPLY WITH THE BINNIAL REPORTING REQUIREMENTS OF PARTS 262 AND 265. 2) FAILURE TO FURNISH NOTIFICATION/CERTIFICATION FORMS FOR OFF-SITE SHIPMENTS OF LAND DISPOSAL RESTRICTED WASTE, AS REQUIRED BY PART 268. 3) FAILURE TO RETAIN COM- PLETE COPIES OF NOTIFICATION/CERTIFICATION FORMS ON SITE AS REQUIRED BY PART 268. 4) STORAGE OF LAND DISPOSAL RESTRICTED WASTE FOR A PURPOSE OTHER THAN THAT ALLOWED BY PART 268.