DEFENDANT OPERATES PAINT MFTG. PLANT EMPLOYING MORE THAN 20 PEOPLE IN HEART OF DENSELY POPULATED CITY. IGNITABLE HAZ- ARDOUS WASTES ARE STORED IN CARELESS MANNER, ALLOWING VOLA- TILE ORGANIC WASTES TO ESCAPE INTO THE AIR, AND OTHER HAZ- ARDOUS WASTES TO FLOW INTO SEWER; THERE IS OPEN SEWER DRAIN ADJACENT TO HAZARDOUS WASTE STORAGE AREA. DEFENDANT WAS FOUND FLAGRANTLY VIOLATING RCRA REGULATIONS, ISSUED ADMINISTRATIVE COMPLAINT. DEFENDANT NEGOTIATED CON- SENT AGREEMENT WHICH IT THEN WILLFULLY AND REPEATEDLY VIO- LATED. THIS ACTION SEEKS A PERMANENT INJUNCTION IN ADDITION TO CIVIL PENALTY. HAD MADE VIRTUALLY NO ATTEMPT TO COMPLY WITH THE MANAGEMENT REQUIREMENTS OF THE RCRA REGULATIONS. FOR EXAMPLE, DEBE- VOISE HAD NO SCHEDULE OF INSPECTIONS, NO CONTINGENCY PLAN FOR EMERGENCIES, NO RECORD OF PERSONNEL TRAINING, AND NO CLOSURE PLAN. AN ADMINISTRATIVE COMPLAINT WAS ISSUED, AND FOLLOWING NEGOTIATIONS, A CONSENT AGREEMENT AND CONSENT ORDER WAS SIGNED MARCH 21, 1983. THE ORDER REQUIRED DEBEVOISE TO TAKE ACTION, AS AGREED IN THE CONSENT AGREEMENT, TO COME INTO COMPLIANCE WITH THE RCRA REGULATIONS. A SECOND INSPECTION OF THE DEBEVOISE FACILITY WAS CONDUCTED AFTER THE COMPLIANCE PERIOD, ON MAY 31, 1983, BY THE SAME EPA EMPLOYEE WHO CON- DUCTED THE EARLIER INSPECTION. THE SUMMARY OF THE REPORT OF THE SECOND INSPECTION RECOMMENDED F