HISTORICALLY THE FACILITY HAS CLAIMED IT DOESN'T GENERATE A HAZ WASTE EVEN THOUGH IT NOTIFIED AS A GENERATOR IN 1980. RECORD REVIEW COMPLETED MARCH 12, 1984, FOUND INADEQUATE GROUNDWATER MONITORING WAIVER. EPA ISSUE A WARNING LETTER ON 3/12/84. A COMPLIANCE ORDER WAS ISSUED ON 3/29/85 FOR CLASS I GROUNDWATER MONITORING VIOLATIONS. A PENALTY OF $121,000 WAS ASSESSED AND $80,700 WAS COLLECTED. A SECTION 3013 ORDER WAS ISSUED APRIL 1, 1985 REQUIRING ASSESSMENT OF EXTENT OF CONTAMINATION AND CLEANUP FOR THE SURFACE IMPOUND- MENT. * A CLOSURE PLAN WAS SUBMITTED ON 11/22/85. EPA ISSUED A FINAL ORDER (FO) TO THE FACILITY ON 11/26/85. THE FO SAYS THAT THE CLOSURE PLAN BECOMES EFFECTIVE 30 DAYS AFTER THE STATE APPROVES IT. THE STATE SENT THE CLOSURE PLAN TO EPA FOR REVIEW. IT SHOULD BE COMPLETED SHORTLY.