PROPOSED CIVIL ACTION TO ENFORCE THE TERMS OF AN INTERIM STATUS CORRECTIVE ACTION ORDER ENTERED INTO BY CONSENT ON DECEMBER 11, 1986. THE ORDER WAS ISSUED PURSUANT TO SECTION 3008(H) OF RCRA, 42 U.S.C. S6928(H). THE ORDER REQUIRED THE COMPANY TO CONDUCT A SITE ASSESSMENT UNDER EPA OVERSIGHT. THE COMPANY WAS REQUIRED TO OBTAIN EPA APPROVAL OF A WORKPLAN AND SCHEDULE. THE COMPANY HAS FAILED TO CONDUCT THE ASSESSMENT ON SCHEDULE AND HAS FAILED TO SUBMIT ON INTERIM RFI REPORT ON SCHEDULE. THE ORDER REQUIRED PAYMENT OF STIPULATED PENALTIES OF $5000 PER DAY FOR VIOLATIONS OF THE ORDER. A DEMAND FOR PAYMENT WAS MADE BY EPA ON APRIL 2, 1990. THE COMPANY HAS FAILED TO PAY ANY OF THE ACCRUED PENALTIES. EPA WANTS THE FOLOWING RELIEF (1) COMPLETION OF THE SITE ASSESSMSNT, SUBJECT TO EPA APPROVAL, AS EXPEDITIOUSLY AS POSSIBLE; & (2) PAYMENT OF PENALTIES FOR NONCOMPLIANCE WITH THE TERMS OF THE ORDER.