DURING THE PERIOD 1/1/98 THROUGH 4/30/98, RESPONDENT DISPOSED ITS SEWAGE SLUDGE VIA SURFACE DISPOSAL. ON 5/1/98, RESPONDENT CLOSED IT SEWAGE SLUDGE UNIT. ON 2/12/99 RESPONDENT SUBMITTED AN ANNUAL SLUDGE REPORT. THE ANNUAL SLUDGE REPORT INDICATED THAT APPROX. 168 DRY METRIC TONS OF SEWAGE SLUDGE WERE DISPOSED VIA SURFACE DISPOSAL AND 1,070 DRY METRIC TONS OF SEWAGE SLUDGE WERE DISPOSED VIA LAND APPLICATION. DUE TO THE CLOSURE OF THE SEWAGE SLUDGE UNIT, RESPONDENT SHOULD HAVE SUBMITTED A CLOSURE AND POST CLOSURE PLAN TO EPA 180 DAYS PRIOR TO CLOSURE AS OUTLINED IN 40 CFR 503.22. EPA HAS NO RECORDS THAT RESPONDENT SUBMITTED SAID PLANS. BASED ON THESE FINDINGS, RESPONDENT VIOLATED THE GENERAL REQUIREMENTS FOR SURFACE DISPOSAL IN 40 CFR 503.22 AND THEREFORE SECTION 405(E) OF THE CWA. 10/22/01 - AO CLOSURE