RCRA VIOLATIONS WERE NOTED DURING A JUNE 15 - 16, 1998 FACILITY INSPECTION. A RESPONSE TO AN INFORMATION REQUEST DATED NOVEMBER 2, 1998, PROVIDED FURTHER DOCUMENTATION OF RCRA VIOLATIONS. U.S. EPA ISSUED A NOTICE OF VIOLATION ON AUGUST 5, 1999. AFTER NEGOTIATIONS AND AGREEMENT ON THE CIVIL PENALTY AND EXTENT OF INJUNCTIVE RELIEF, A COMPLAINT AND A CONSENT AGREEMENT AND FINAL ORDER WERE FILED SIMUL- TANEOUSLY.