WE ARE SEEKING THE FILING OF A COMPLAINT AGAINST SILVERTONE PLATING COMPANY, INC., AN ELECTROPLATING COMPANY IN YPSILANTI, MI WHICH GENERATES SPENT STRIPPING AND CLEANING BATH SOLUTIONS CONTAINING CHROMIC ACID AND CYANIDE, ALONG WITH OTHER RCRA HAZARDOUS WASTES. AN INSPECTION IN 1987 REVEALED MANY GENARATOR AND TSDF REGULATION VIOLATIONS. THE COMPANY ENTERED INTO A CAFO IN APRIL 1988 WITH USEPA UNDER WHICH THE COMPANY AGREED TO SUBMIT AND IMPLEMENT A CLOSURE PLAN FOR THE FACILITY, TO REMOVE ALL HAZARDOUS WASTE STORED ON SITE OVER 90 DAYS AND TO COMPLY WITH ALL APPLICABLE HAZARDOUS WASTE STORAGE AND GENERATOR REGULATIONS. SILVER- TONE HAS REPEATEDLY FAILED TO HONOR ITS CAFO OBLIGATIONS. BY FILING THIS ACTION, USEPA SEEKS AN ORDER REQUIRING SUB- MITTAL AND IMPLEMENTATION OF A CLOSURE PLAN; COMPLIANCE WITH ALL APPLICABLE GENERATOR AND STORAGE REGULATIONS AND PAYMENT OF A CIVIL PENALTY, ATTORNEY'S FEES AND COSTS.