IN 1981, THERE WAS A SPILL OF VINYLIDINE CHLORIDE (VCL2) AT DU PONT'S CIRCLEVILLE, OHIO PLANT. DUPONT, WITH THE CONCURRENCE OF OHIO EPA, RESPONDED TO THE SPILL BY PUMPING CONTAMINATED GROUNDWATER INTO THE PLANT'S WASTE WATER TREATMENT SYSTEM. OHIO EPA AND U.S. EPA CONDUCTED SEVERAL INSPECTIONS OF THE DU PONT FACILITY IN 1986 AND 1987. THESE INSPECTIONS REVEALED VIOLATIONS OF GROUNDWATER MONI- TORING AND CLOSURE REQUIREMENTS. ON MARCH 30, 1988, U.S. EPA ISSUED A COMPLAINT, FINDINGS OF VIOLATION AND COMPLI- ANCE ORDER.