AUTO-ION CHEMICAL COMPANY COMMENCED OPERATIONS IN 1964 AS A PLATING WASTE TREATMENT FACILITY. THE PLANT WAS ORIGINALLY DESIGNED TO PRECIPITATE THE HEAVY METALS FROM CHROME AND CYANIDE WASTE. THE RESULTING SLUDGE WAS THEN TO BE DISPOSED OF AT A SUITABLE DUMP SITE AND THE SUPERNATANT, CREATED IN THE CYANIDE WASTE TREATMENT, WAS TO BE DISCHARGED INTO THE SANITARY SEWER SYSTEM. HOWEVER, INADEQUATE WASTE TREATMENT AND STORAGE LED TO A MULTITUDE OF SPILLS AND ILLIGAL DIS- CHARGES INTO THE KALMAZOO RIVER, AND STORM AND SANITARY SEW- ER SYSTEMS. - DURING THE PLANT'S OPERATIONS, SEVERAL VIOLATIONS WERE DIS- COVERED BY LOCAL GOVERNMENT OFFICIALS. THESE OFFICIALS RE- PORTED UNAPPROVED DISCHARGES INTO SANITARY LINES AND INTO THE KALAMAZOO RIVER DIRECTLY. IN ADDITION, OFFICIALS NOTED A LACK OF DIKING AROUND STORAGE TANKS AND THE PRESENCE OF UN LABELED, LEAKING DRUMS. - THE WATER RESOURCE HEARING COMMISSION MADE THE DETERMINATION THAT AUTO-ION HAD VIOLATED PROVISIONS OF THE LIQUID INDUSTRI AL WASTE ACT, MICH. STAT. ANN. SECTIONS 3.533(101) ET. SEQ., AND THE WATER RESOURCES ACT, MICH. STAT. ANN. SECTIONS 3.521 ET. SEQ. IN ADDITION, IT IS BELIEVED THAT ORGANIC FERTILI- ZER WASTE MAY HAVE BEEN LEFT ON SITE BY AN ORGANIC FERTILI- ZER COMPANY WHICH OPERATED OUT OF ON