NATURE OF THE CASE: THIS ACTION INVOLVES A FACILITY LOCATED IN A RURAL AMISH AREA OF NORTHEAST OHIO. THE STREET ADDRESS IS 17030 PETERS ROADS, MIDDLEFIELD,OHIO. THE FIRM ORIGINALL Y BEGAN HANDLING HAZARDOUS WASTES IN THE EARLY PART OF 1980, AT ABOUT THE TIME THAT THE RCRA REGULATIONS WERE PROMUGATED. THE SITE INCLUDES ABOUT TWO ACRES, AND IS BORDERED ALONG I TS LONGER, EAST AND WEST FACES BY FARMLAND THAT IS USED FOR BOTH GRAZING AND CROP PRODUCTION. CATTLE WERE OBSERVED GRAZI NG RIGHT UP TO THE PROPERTY LINE, W/I A FEW A FEET OF BARREL S OF WASTE LOCATED ON THE SITE. THE SOUTH BOUNDARY IS A STAT E ROAD USED BY AMISH CHILDREN TO WALK TO SCHOOL,AND A WOODED WETLAND IS AT THE NORTH. THE SITE WAS ORIGINALLY LEASED, WITH AN OPTION TO PURCHASE , BY ONE DAVID SHILLMAN, A HARVARD LAW SCHOOL GRADUATE WHOSE LICENSE TO PRACTICE LAW IN OHIO HAS BEEN SUSPENDED BY THAT S TATE'S SUPREME COURT. HE OPERATED ORIGINALLY IN THE FORM OF A PARTNERSHIP, IN WHICH HE WAS THE GENERAL PARTNER. HE FILED A RCRA NOTIFICATION AND PART A APPLICATION IN JULY 1980, ACH IEVING INTERIM STATUS THEREBY, AND SIGNED THOSE DOCUMENTS AS SECRETARY-TREASURER OF J.V. PETERS AND CO. HE INCORPORATED IN LATE JANUARY,1981, SHORTLY AFTER THE S TATE OF OHIO BEGAN TO TAKE AN ACTIVE INTEREST IN THE SITE DU E TO GROSS VIOLATIONS OF THE INTERIM STATUS STANDARDS UNDER RCRA. THE FACILITY WAS NEVER FENCED, AND IT WAS NOT UNTIL MO NTHS AFTER RECEIPT OF THE COMPLIANCE