IT IS RECOMMENDED THAT A CIVIL COMPLAINT BE FILED AGAINST GREAT LAKES CASTING CORP. PURSUANT TO SECTION 3008 OF THE RCRA. LOCATED IN LUDINGTON, MI, GREAT LAKES IS PRESENTLY OPERATING 3 REGULATED SURFACE IMPOUNDMENTS WITHOUT INTERIM STATUS OR A PERMIT. - GREAT LAKES FAILED TO SUBMIT A TIMELY PART A PERMIT APPLI- CATION BY THE 9/25/90, DEADLINE FOR TOXICITY CHARACTERISTICS WASTES. THE SURFACE IMPOUNDMENTS TESTED TC FOR LEAD. AS PART OF THE LEAD INITIATIVE, THE USEPA FILED AN ADMINISTRA- TIVE COMPLAINT ON 7/31/91, AGAINST GREAT LAKES FOR OPERATING WITHOUT INTERIM STATUS. - BEFORE AN AGREEMENT WIT GREAT LAKES COULD BE REACHED, THE 9/25/91, LOSS OF INTERIM STATUS DEADLINE FOR TC WASTE ARRIVED. EVERY LAND DISPOSAL FACILITY WAS REQUIRED TO SUB- MIT ITS PART B PERMIT APPLICATION AND TO CERTIFY COMPLIANCE WITH GROUNDWATER MONITORING, FINANCIAL AND CLOSURE REQUIRE- MENTS. ON 9/25/91, GREAT LAKES SUBMITTED ITS PART B APPLICA TION AND CERTIFICATIONS FOR ITS GROUNDWATER MONITORING SYSTEM, CLOSURE AND FINANCIAL ASSURANCE. HOWEVER, GREAT LAKES FORMALLY INFORMED USEPA THAT IT WAS UNABLE TO OBTAIN LIABILITY INSURANCE FOR SUDDEN AND NONSUDDEN ACCIDENTAL OCCURRENCES, AS REQUIRED UNDER 40 CFR SECTION 265.147. -