I. SYNOPSIS OF CASE AMERICAN STEEL FOUNDRIES, DIVISION OF AMSTED INDUSTRIES, INC. (ASF) OWNS AND OPERATES A GREEN SAND STEEL CASTING FOUN DRY OPERATION IN ALLIANCE, OHIO. SINCE 1967 ASF OWNED THE OPERATED A DISPOSAL SITE IN NEARBY SEBRING TOWNSHIP FOR DIS- POSAL OF PRODUCTION WASTES. ON AUGUST 4, 1980, ASF SUBMIT- TED A NOTIFICATION OF HAZARDOUS WASTE ACTIVITY, AND ON NOVEM BER 18, 1980, IT SUBMITTED A RCRA PART A PERMIT APPLICATION (ATTACHMENT C). THE APPLICATION WAS ONLY FOR THE SEBRING TOWNSHIP DISPOSAL FACILITY. ON JUNE 25, 1982, THE COMPANY REQUESTED THAT ITS PERMIT APPLICATION BE WITHDRAWN ON THE BA SIS THAT IT ...HAS NOT AND DOES NOT TREAT, STORE OR DISPOSE OF ANY HAZARDOUS WASTES AS DEFINED BY EPA. ON APRIL 19, 19 83, USEPA, REGION V SENT A LETTER TO ASF STATING THAT, BASED UPON THE INFORMATION CONTAINED IN ITS PERMIT APPLICATION AND JUNE 25, 1982, LETTER, ASF WOULD NOT BE REQUIRED TO OBTAIN A PERMIT UNDER SECTION 3005 OF RCRA (ATTACHMENT D). THE OHIO ENVIRONMENTAL PROTECTION AGENCY (OEPA) SAMPLED PRODUCTION WASTE AT THE ALLIANCE, OHIO FACILITY ON FEBRUARY 12, 1985, AUGUST 14, 1985. USEPA SAMPLED WASTES AT THE PRO- DUCTION AND DISPOSAL FACILITIES ON AUGUST 6 AND 7, 1986 (AT- TACHMENT B). RESULTS OF ANALYSES OF SUCH SAMPLES INDICATED THAT FACILITY'S ELECTRIC ARC FURNACE DIUST IS A HAZARDOUS WA STE BECAUSE IT EXCEEDS THE 1.0 MG/L CONCENTRATION LEVEL OF CADMIUM AND THE 5.0 MG/L CONCENTRATI