AS OF 11/8/85, NO GROUNDWATER MONITORING PROGRAM HAD BEEN IMPLEMENTED FOR THE SURFACE IMPOUNDMENT AND RESPONDENT WAS THEREFORE IN VIOLATION OF RULE 804(A)(1). RESPONDENT HAS FAILED TO SUBMIT TIMELY AND COMPLETE IN- FORMATION ON ITS ACTIVITIES AND IS, THEREFORE, IN VIOLATION OF 40 CFR 270.10(E)(4).