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: COPPERWELD STEEL COMPANY, 400 MAHONING AVENUE, WARREN TOWNSHIP, WARREN, OHIO 44482. ALLEGED VIOLATIONS: COPPERWELD HAS OPERATED AND CONTINUES TO OPERATED TWO DISTINCT HAZARDOUS WASTE STORAGE FACILITIES, SPECIFICALLY A WASTE PILE AND A SURFACE IMPOUNDMENT, WITHOUT OBTAINING A RCRA PERMIT AND WITHOUT ACHIEVING INTERIM STATUS FOR EITHER UNIT. IN ADDITION, COPPERWELD HAS VIOLATED SEVERAL REGULATIONS APPLICABLE TO ITS INTERIM STATUS LANDFILL AND DRUM STORAGE FACILITY. PROPOSED RELIEF: A PERMANENT INJUNCTION WHICH WOULD PRO- HIBIT COPPERWELD FROM STORING HAZARDOUS WASTE IN AN UNPER- MITTED WASTE PILE AND REQUIRE CLOSURE OF THE WASTE PILE, AND WHICH WOULD PROHIBIT COPPERWELD FROM STORING WASTE IN AN UN- PERMITTED SURFACE IMPOUNDMENT AND REQUIRE CLOSURE OF ITS ON- SITE SURFACE IMPOUNDMENT. PERMANENT INJUNCTIVE RELIEFF IS REQUESTED TO COMPEL COMPLIANCE WITH REGULATIONS APPLICABLE TO COPPERWELD'S INTERIM STATUS LANDFILL AND DRUM STORAGE FA- CILITY. IN ADDITION, THE AGENCY RECOMMENDS THAT A CIVIL PE- NALTY BE ASSESSED AGAINST COPPERWELD IN THE AMOUNT UP TO $25 000 PER DAY PURSUANT TO RCRA SECTION 3008G. RECENT CONTACTS WITH DEFENDANT: INSPECTORS FROM OHIO EPA HAVE CONDUCTED INSPECTIONS OF COPPERWE