IN THE PROCESS OF RECOVERING FERROUS AND NON-FERROUS METALS FROM SCRAP AUTOMOBILES AND APPLIANCES, MIDEWST METALLICS GENERATED SIGNIFICANT QUANTITIES OF AUTO SHREDDER RESIDUE OR AUTO FLUFF . SINCE THE MID-1980, MIDWEST METALLICS HAS STORED THAT FLUFF IN A LARGE PILE AT ITS FACILITY. TESTED PORTIONS OF THIS WASTE EXHIBIT THE CHARACTERISTIC OF TOXICITY BECAUSE OF ITS LEAD CONTENT PURSUANT TO 40 C.F.R. 261.24. 3013 AUTHORITY IS BEING USED TO ATTEMPT TO FORCE THE COM- PANY TO COME UP WITH A REPRESENTATIVE SAMPLING PLAN TO DETERMINE IF THE ENTIRE PILE IS HAZARDOUS PURSUANT TO RCRA, WHICH WILL ASSIST IN PLANNING FOR THE MATERIAL'S DISPOSAL. COMPANY HAS SHUT DOWN OPERATIONS AT THE SITE, SELLING THE AUTO SHREDDING EQUIPMENT AND THE EDDY CURRENT SEPARATOR (USED TO PROCESS NONFERROUS METAL) TO ANOTHER SCRAP PROCESSING COMPANY.