THE DECEMBER 12TH, 1997, CONSENT AGREEMENT AND FINAL ORDER FILED IN THE OLIN CORPORATION MATTER ONLY REQUIRED OLIN TO PAY A CIVIL PENALTY OF $23,699. NO CORRECTIVE ACTIONS WERE REQUIRED IN THE ORDER. HOWEVER, OLIN DID SUBMIT INFORMATION TO US REGARDING THE CORRECTIVE ACTIONS THEY TOOK IN ORDER TO MEET THE SELF-DISCLOSURE CRITERIA FOR A REDUCTION IN PENALTI ES. THE VIOLATION INVOLVED 24 SHIPMENTS TOTALING 599,520 POUNDS OF HAZARDOUS WASTE BAGHOUSE DUST (D006) TO A FERTILI- ZER MANUFACTURER NAMED FRIT INDUSTRIES. THE FOLLOWING CORRECTIVE ACTIONS WERE TAKEN BY OLIN: - ALL OLIN PERSONNEL INVOLVED WITH THE SHIPMENT OF MATERIALS HAVE BEEN INSTRUCTED NOT TO SHIP BAGHOUSE DUST TO FRIT, OR ANY OTHER FERTILIZER PRODUCT MANUFACTURER. - OLIN INFORMED FRIT OF THE HAZARDOUS CHARACTERISTIC OF THE MATERIAL THAT WAS SENT AND TOLD FRIT NOT TO USE IT, BUT TO HOLD IT UNTIL OLIN COULD ARRANGE FOR PROPER DISPOSAL. - OLIN NOTIFIED THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY AND THE ARKANSAS DEPARTMENT OF POLLUTION CONTROL AND ECOLOGY OF THE ISSUE, AND SENT THEM COPIES OF THE SELF-DISCLOSURE. - BASED ON A JUNE 16, 1997, LETTER FROM OLIN'S ATTORNEY, OLIN ARRANGED FOR AND COMPLETED SHIPMENT OF ALL OF THE REMAINING BAGHOUSE DUST THAT WAS BEING HELD BY FRIT AFTER BEING INFORMED OF THE PROBLEM TO EITHER SAVAGE ZINC IN CLARKSVILLE, TENNESSEE OR BIG RIVER ZINC IN SAUGET, ILLINOIS THE BAGHOUSE DUST IS BEING USED AS A