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: ALCHEM-TRON INC, (SERVICE OF PROCESS) C/O INDERJIT S. SONI, 2516 TRAIN AVENUE, CLEVELAND, OHIO, 44113 AND 7415 BESSEMER AVENUE, CLEVELAND, OHIO 44127 (FACILITY). ALLEGED VIOLATIONS: ALCHEM-TRON, INC. HAS OPERATED AND CONTINUES TO OPERATE A HAZARDOUS WASTE TREATMENT FACILITY WITHOUT OBTAINING INTERIM STATUS AND WITHOUT OBTAINING A RCRA PERMIT. ALCHEM-TRON, INC. HAS DISREGARDED REQUESTS AND ORDERS OF THE STATE AND FEDERAL GOVERNMENT TO DISCONTINUE TREATMENT, STORAGE AND DISPOSAL OF HAZARDOUS WASTE IN ITS TWO WASTE PILES. PROPOSED RELIEF: A PERMANENT INJUNCTION WHICH WOULD PRO- HIBIT ALCHEM-TRON, INC. FROM TREATING, STORING, OR DISPOSING OF ANY WASTE AT ITS FACILITY AND WHICH WOULD REQUIRE ALCHEM- TRON, INC. TO CLOSE ITS TWO OPERATING WASTE PILES. IN ADDITION, THE AGENCY RECOMMENDS THAT A CIVIL PENALTY BE SOUGHT AGAINST ALCHEM-TRON IN THE AMOUNT OF UP TO $25,000 PER DAY PURSUANT TO RCRA SECTION 3008(G). RECENT CONTACTS WITH DEFENDANT: U.S. EPA FILED A RCRA SECTION 3008(A) ADMINISTRATIVE ACTION AGAINST ALCHEM-TRON, INC. ON JANUARY 12, 1982 FOR OPERATING A HAZARDOUS WASTE FACILITY WITHOUT A PERMIT OR INTERIM S