IN 1980 AN INFORMATION REQUEST WAS SENT TO PS&G PURSUANT TO THE CWA. PS&G OMITTED IMPORTANT INFORMATION. IN 1986 AND 1990 INFORMATION REQUESTS WERE SENT TO PS&G PURSUANT TO RCRA AND CERCLA. PS&G AGAIN OMITTED IMPORTANT INFORMATION IN JULY 1992, IT WAS LEARNED THROUGH THE DEPOSITION OF A PS&G EMPLOYEE THAT INFORMATION WAS OMITTED IN RESPONSE TO THE 3 PRIOR INFORMATION REQUEST. THIS ACTION SEEKS INJUNCTIVE RELIEF FOR A COMPLETE RESPONSE AND PENALTIES FOR THE FAILURE TO PROVIDE THE INFORMATION. THE INFORMATION OMITTED WOULD HAVE BEEN RELEVENT IN CONDUCTING THE RI FOR THIS SITE, WHICH WAS ON THE NPL. IT HAS SINCE BEEN DELETED. THE INFO IS ALSO RELELVANT TO AN ON GOING COST RECOVERY CASE. (MULTI-MEDIA)