CHEMICAL WASTE MANAGEMENT, INC., 3003 BUTTERFIELD ROAD, OAK BROOK, IL 60521(OFFICE) AND 3956 STATE ROUTE 412, VICKERY, OHIO 43464(FACILITY). CWM HAS OPERATED AND CONTINUES TO OPERATE A HAZARDOUS WASTE MANAGMENT FACILITY WHICH INCLUDES SEVERAL SURFACE IMPOUND- MENTS THAT DO NOT HAVE INTERIM STATUS AND ARE NOT INCLUDED IN IN CWM'S RCRA PERMIT. IN ADDITION, CWM HAS VIOLATED TWO PROVISIONS OF THE CONSEN AGREEMENT AND FINAL ORDER(CAFO) OF APRIL 5, 1985, BETWEEN CWM AND U.S. EPA. PRELIMINARY AND PERMANENT INJUNCTIONS WHICH WOULD PROHIBIT CWM FORM MANAGING HAZARDOUS WASTE IN LAND DISPOSAL UNITS AT THE VICKERY FACILITY THAT LACK INTERIM STATUS OR HAVE NOT OBTAINED A RCRA PERMIT, AND WOULD REQUIRE CWM TO CLOSE THESE UNITS. IN ADDITION, THE AGENCY RECOMMENDS THAT A CIVIL PENALTY BE SOUGHT AGAINST CWM IN THE AMOUNT OF UP TO $25,000 PER DAY PER VIOALTION, PURSUANT TO SECTION 3008(G) OF RCRA. IN REGARD TO THE CAFO VIOLAITONS, THE AGENCY RECOMMENDS JUDI CIAL ENFORCEMENT OF THE CAFO AND DECLARATORY RELIEF. AS A RESULT OF ITS INSPECTIONS DURING THE WEEKS OF APRIL 6 AND APRIL 13, 1987, U.S. EPA UNCOVERED NUMEROUS VIOLATIONS OF FEDERAL REGULATIONS AT CWM'S VICKERY FACILITY. U.S. EPA NOTIFIED CWM OF THESE VIOLATIONS VERBALLY DURING THE INSPEC- TIONS AND BY MAIL ON BOTHE JUNE 18 AND AUGUST 27, 1987. ON JULY 10 AND SEPTEMBER 4, 1987, CWM RESPONDED TO THESE NOTI- FICATION LETTERS AND DISPUTED U.S. E