THE ACTION WAS TAKEN BECAUSE THE FACILITY HAD INSTALLED AN INADEQUATE GROUNDWATER MONITORING SYSTEM, HAD NOT CON- DUCTED AN ADEQUATE GROUNDWATER ASSESSMENT PROGRAM UNDER 40 CFR 265.93 AND HAD NOT COMPLETED ITS CERTIFICATE OF INSURANCE PROPERLY. THE GROUNDWATER MONITORING FACILITY ORIGINALLY DID NOT HAVE SUFFICIENT NUMBER OF WELLS AT THE LIMIT OF THE WASTE MANAGEMENT AREA AND THERE WAS NOT ADEQUATE DOCUMENTATION TO DETERMINE IF THE WELLS HAD BEEN PROPERLY CONSTRUCTED. ALSO THE RESPONDENT HAD NOT PUT ANY WELLS IN A GROUNDWATER BEARING FORMATION WHICH WAS HYDRAULICALLY CONNECTED TO THE AQUIFER BENEATH IT.