COMPLAINT ISSUED JANUARY 31, 1986 FOR FAILURE TO SUBMIT AN APPROVED CLOSURE PLAN, SUBMIT/IMPLEMENT A GROUNDWATER MONITORING PROGRAM AND COMPLY WITH FINANCIAL RESPONSIBILITY REQUIREMENTS FOR CLOSURE. A PENALTY OF $53,000 WAS ALSO ASSESSED. CURRENTLY, IN NEGOTIATIONS WITH COMPANY. THEY HAVE REQUESTED AND HAVE BEEN GRANTED EXTENSIONS FOR TIME TO ANSWER/REQUEST A HEARING. IT IS NOT YET IN THE ADMINISTRA- TIVE PROCESS. ************************************************************ * FOR VIOLATIONS OF A 1987 CAFO AND ADDITIONAL NEWLY DISCOVER- ED VIOLATIONS OF RCRA, PLAINTIFF IS SEEKING RELIEF CONSIST- ING OF AN INJUNCTION REQUIRING SCIO TO: 1)CLOSE THE SURFACE INPOUNDMENT IN ACCORDANCE WITH OAC 3745 ET SEQ., AND 2)CEASE ALL SOTRAGE IF HAZARDOUS WASTE EXCEPT, DURING THE CLOSURE PERIOD, SUCH STORAGE TO BE IN COMPLIANCE WITH THE INTERIM STATUS STANDARDS AND LAND BAN REQUIREMENTS FOR HAZARDOUS WASTE TREATMENT FACILITIES, INCLUDING FINANCIAL ASSURANCES AND LIABILITY COVERAGE. IN ADDITION, PLAINTIFF IS SEEKING A CIVIL PENALTY UNDER RCRA SECTIONS 3008(C) AND 3008(G) OF $672,546 AND IMPOSTIOIN OF CIVIL PENALTIES, AS THE COURT DEEMS APPROPRIATE, UP TO $25,000 PER DAY FOR NON-COMPLIANCE WITH THE EFFECTIVE CAFO.