NATURE OF THE CASE - BASED UPON INFORMATION AVAILABLE TO EPA & A JOINT EPA/DHEC INSPECTION CONDUCTED ON 12/12/85, IT HAS BEEN DETERMINED THAT T & S BRASS IS OPERATING IN VIOLA- TION OF CERTAIN REQUIREMENTS OF RCRA. T & S BRASS HAS NOT ACHIEVED INTERIM STATUS BECAUSE IT FAILED TO SUBMIT PART A OF THE RCRA HAZARDOUS WASTE FACILITY PERMIT APPLICATION BY 11/19/80. RELIEF REQUESTED: INJUNCTION REQUI- RING THE DEFENDANT TO IMMEDIATELY (1) COMPLY W/APPLICABLE FINANCIAL RESPONSIBILITY REQUIREMENTS THROUGH CLOSURE & (2) THROUGH CLOSURE & POST-CLOSURE. ADDITIONALLY, CIVIL PENALITIES IN THE AMOUNT OF $25,000 PER DAY FOR EACH DAY OF VIOLATION OF THE INTERIM STATUS REQUIREMENTS