THIS REFERRAL IS A REQUEST THAT THE DEPARTMENT OF JUSTICE ( DOJ ) TAKE ACTION TO ENFORCE AN ADMINISTRATIVE CONSENT AGREEMENT AND ORDER ENTERED IN THE ABOVE-REFERENCED EMERGEN- CY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT (EPCRA) CASE INVOLVING M & V ELECTROPLATING CORP.(RESPONDENT). SPECIFI- CALLY, EPA RECOMMENDS THAT DOJ FILE A MOTION TO OBTAIN INJUNCTIVE RELIEF ORDERING RESPONDENT TO PAY THE CIVIL PENALTY AND ALL OTHER AMOUNTS OWED UNDER CONSENT AGREEMENT AND ORDER (THE AGREEMENT ). RESPONDENT OWNS AND OPERATES TWO ELECTROPLATING FACILITIES RESPONDENT IS OR WAS, AT THE TIME IT EXECUTED THE AGREEMENT, A MASSACHUSETTS CORPORATION WITH ITS PRINCIPAL PLACE OF BUSINESS IN NEWBURYPORT, MASSACHUSETTS. RESPONDENT APPEARS TO HAVE SUFFICIENT FUNDS TO PAY THE CIVIL PENALTY. AFTER AN ENVIRONMENTAL PROTECTION AGENCY ( EPA ) INSPEC- TION OF RESPONDENT'S FACILITIES, EPA FILED AN ADMINISTRATIVE COMPLAINT AGAINST RESPONDENT (THE COMPLAINT ). THE COMPLAINT ALLEGED THAT RESPONDENT VIOLATED SECTION 313 OF EPCRA AND 40 C.F.R. PART 372 BY NOT SUBMITTING TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORMS FOR CERTAIN CHEMICALS. TO SETTLE THE CASE, RESPONDENT ENTERED INTO THE AGREEMENT. EPA FILED THE AGREEMENT WITH THE REGIONAL HEARING CLERK ON JANUARY 27, 1992. PURSUANT TO THE AGREEMENT, RESPONDENT AGREED TO PERFORM A SUPPLEMENTAL ENVIR