IMPACT: ON SEPTEMBER 18, 1985, A CONSENT AGREEMENT AND FINAL ORDER (CAFO) WAS ISSUED IN THE CLOW CORPORATION CASE WHEREBY THE COMPANY AGREED TO RECTIFY THE VIOLATIONS WHICH HAD BEEN FOUND IN THE COMPLAINT AND TO PAY A CIVIL PENALTY IN THE AMOUNT OF $85,000. <<< PENALTY OF $85,000 WAS COLLECTED ON 10/23/85. >>> BACKGROUND: ON DECEMBER 16, 1983, CLOW CORPORATION WAS SERVED WITH A COPY OF A COMPLAINT ALLEGING VIOLATIONS OF THE RCRA REGULATIONS PERTAINING TO RECORD KEEPING, FINANCIAL ASSURANCE, CLOSURE PLANS, AND GROUNDWATER MONITORING. ON NOVEMBER 20, 1984, THE COMPLAINT WAS AMENDED TO INCLUDE VIOLATIONS WHICH WERE DISCOVERED PURSUANT TO AN INSPECTION WHICH TOOK PLACE AFTER THE ORIGINAL ISSUANCE OF THE COM- PLAINT. I. SYNOPSIS OF CASE CLOW COPORATION OWNS AND OPERATES A FACILITY LOCATED IN COSHOCTON, OHIO WHICH MANUFACTURES PIPES AND PIPE FITTINGS. ON NOVEMBER 20, 1984, AN ADMINISTRATIVE COMPLAINT WAS FILED BY USEPA, REGION V PURSUANT TO SECTION 3008 OF RCRA, ALLEG- ING VIOLATIONS OF THE REGULATIONS WHICH HAVE BEEN PROMULGA- TED PURSUANT TO SUBTITLE C OF THE ACT. ON SEPTEMBER 18, 198 5, THE MATTER WAS RESOLVED PURSUANT TO A CONSENT AGREEMENT AND FINAL ORDER (CAFO). CLOW, PURSUANT TO THE TERMS OF THE CAFO, WAS REQUIRED IN- TER ALIA TO: