NATURE OF THE CASE THIS CIVIL LITIGATION REPORT REQUESTS THE INITIATION OF A CIVIL ACTION FOR VIOLATIONS OF SECTION 3005(A), 42 U.S.C. SECTION 6925(A), AND IMPLEMENTING REGULATIONS. THIS REPORT ALSO SUPPLEMENTS THE REGION'S PREVIOUS LITIGATION REPORT OF JUNE 30, 1985.
RELIEF SOUGHT: IT IS REQUESTED THAT INJUNCTIVE RELIEF BE OBTAINED TO REQUIRE THE DEFENDANT TO IMMEDIATELY (1) CEASE OPERATION OF ITS LAND DISPOSAL UNITS; (2) SUBMIT CLOSURE AND POST-CLOSURE PLANS; (3) COMPLY WITH THE INTERIM STATUS STANDARDS PENDING COMPLETION OF CLOSURE; (4) COMPLETE AND CERTIFY CLOSURE IN ACCORDANCE W/40 C.F.R. SECTION 264.114; & (5) APPLY FOR A POSTCLOSURE PERMIT.