LEGAL BASIS FOR PROPOSED ACTION: SECTION 3005 AND 3008 OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976, AS AMENDED, 42 U.S.C. SECTION 6901 ET. SEQ. IDENTITY OF DEFENDANT: PRODUCTION PLATED PLASTICS, INC., (DEFENDANT), 9899 EAST D AVENUE, RICHLAND, MICHIGAN, 49083. ALLEGED VIOLATIONS: DEFENDANT CONTINUES TO STORE AND DISPOSE OF HAZARDOUS WASTE IN TWO LAND DISPOSAL UNITS AT ITS RICHLAND, MICHIGAN, FACILITY WITHOUT MAINTAINING INTERIM STATUS OR OBTAINING A RCRA PERMIT. DEFENDANT LOST INTERIM STATUS BECAUSE IT FAILED TO CERTIFY BY NOVEMBER 8, 1985, THAT ITS FACILITY WAS IN COMPLIANCE WITH ALL APPLICA- BLE FINANCIAL RESPONSIBILITY REQUIREMENTS AS REQUIRED BY SECTION 3005(E)(2) OF RCRA. PROPOSED RELIEF: A PERMANENT INJUNCTION WHICH WOULD PROHIBIT DEFENDANT FROM STORING OR DISPOSING OF HAZARDOUS WASTE IN LAND DISPOSAL UNITS AT ITS FACILITY, AND WHICH WOULD REQUIRE DEFENDANT TO CLOSE ITS ON-SITE LAND DISPOSAL UNITS. IN ADDITION, THE AGENCY RECOMMENDS THAT A CIVIL PENALTY BE ASSESSED PURSUANT TO RCRA SECTION 3008(G). RECENT CONTACTS WITH DEFENDANT: ON MAY 14, 1986, THE MICHIGAN DEPARTMENT OF NATURAL RESOURCES AND THE U.S. ENVIRONMENTAL PROTECTION AGENCY VISITED AT THE DEFENDANT'S FACILITY, AND OBSERVED DEFENDANT STORING HAZARDOUS WASTE IN ITS ON-SITE WASTE PILE, AND TREATING AND STORING HAZARDOUS WASTES IN ITS ON-SITE SURFACE IMPOUNDM