THE U.S.A. ON BEHALF OF U.S. EPA IS AUTHORIZED TO INITIATE AN ACTION ADJUDGING BSC TO BE IN CIVIL CONTEMPT FOR THE ABOVE-REFERENCED VIOLATIONS. IN ADDITION, THIS LITIGATION REPORT REQUESTS THAT THE CONTEMPT ACTION INCLUDE REQUESTS FOR INJUNCTIVE RELEAF AND STIPULATED PENALTIES OF, AT A MINIMUM, $255,750 IN ACCORDANCE WITH THE TERMS OF THE PARTIAL CONSENT DECREE.