REFERRAL PROPOSES THE FILING OF A CIVIL ACTION AGAINST LEE BRASS COMPANY, INC., A DIVISION OF AMCAST, FOR ITS BRASS FOUNDRY OPERATIONS LOCATED IN MONTGOMERY COUNTY, ANNISTON, AL, BASED ON SECTION 3008(A) AND SECTION 7003 OF RCRA. THE MAJOR 3008(A) VIOLATIONS ALLEGED IN THIS LITIGATION REPORT ARE TREATMENT OF A HAZARDOUS WASTE WITHOUT A PERMIT OR INTERIM STATUS IN THE BOILER OR INDUSTRIAL FURNACE (BIF) PORTION OF THE FACILITY'S SAND RECLAMATION UNIT (SRU); PRODUCING PRODUCTS THAT ARE APPLIED TO THE LAND THAT FAIL TO MEET LAND DISPOSAL RESTRICTIONS (LDR) TREATMENT STANDARDS; AND DISPOSING OF THESE PRODUCTS ON THE GROUND OUTSIDE OF THE FACILITY. THE RCRA 7003(A) VIOLATIONS IN THIS REFERRAL ARE BASED ON THE POTENTIAL IMMINENT AND SUBSTANTIAL ENDANGERMENT POSED BY LEE BRASS' HANDLING OF ITS WASTES WITH HIGH LEAD LEVELS, WHICH INCLUDES SELLING THEM AS FILL AND DONATING THE WASTE FOR USE AS PLAYGROUND SAND.