NATURE OF CASE AND VIOLATIONS UPON WHICH CASE IS BASED - THE CLAIMS BEING REFERRED ARE BASED UPON THE FOLLOWING VIOLATIONS OF LAW AND OTHER CAUSES OF ACTION: 1) NUMEROUS VIOLATIONS OF A CONSENT DECREE THAT WAS ENTERED IN FEBRUARY 1983 BETWEEN EPA, SRSNE, AND TWO INTERVENING PARTIES, WHICH REQUIRED THE COMPANY TO TAKE SPECIFIED MEASURES TO CONTAIN AND ABATE POLLUTION OF SOIL AND GROUND- WATER AT AND AND IN THE VICINITY OF THE SITE; 2) VIOLATIONS OF RCRA SECTION 3005 BY VIOLATING SRSNE'S STATE-ISSUED RCRA PERMIT, MOST NOTABLY THE COMPANY'S FAILURE TO CONSTRUCT SECONDARY CONTAINMENT FACILITIES FOR ITS WASTE HANDLING AREAS, AND ITS FAILURE TO INSTALL A FIRE PROTECTION SYSTEM; 3) ADDITIONAL VIOLATIONS OF RCRA SECTION 3005 BY VIOLATING SRSNE'S EPA-ISSUED HSWA PERMIT, MOST NOTABLE THE COMPANY'S FAILURE TO SUBMIT AN APPROVABLE PLAN FOR REMEDIATING SOIL CONTAMINATION AT THE SITE; 4) VIOLATIONS OF RCRA SECTION 3004 BY VIOLATING THE LAND DISPOSAL RESTRICTION REGULATIONS PROMULGATED UNDER THE AUTHORITY OF THE HAZARDOUS AND SOLID WASTE AMENDMENTS (HSWA) TO RCRA; 5) A CLAIM UNDER SECTION 107 OF CERCLA FOR RECOVERY OF ALL COSTS INCURRED BY THE EPA IN RESPONDING TO THE RELEASE OF HAZARDOUS SUBSTANCES AT THE SRSNE FACILITY. PROPOSED RELIEF: