BACKGROUND FACTS: RESPONDENT CONDUCTS BUSINESS OF RECLAIMING LEAD PLATES AND PLASTICS AND RUBBER COMPONENTS AT ITS FACILITY. * A CONSULTANT'S REPORT WAS ISSUED IN AUGUST 1980. * THE FACILITY HAS AN IMPOUNDMENT WHERE IT NEUTRALIZES THE ACID FROM THE BATTERY CRACKING OPERATION. * THE BATTERY CASES ARE TAKEN TO A WASTE PILE ON-SITE. * LIMESTONE CHIPS USED TO NEUTRALIZE THE ACID IN TEH IM- POUNDMENT IS STORED ON-SITE. * RESPONDENT WAS INSPECTED BY THE STATE AND EPA ON APRIL 2, 1981 AND MAY 30, 1984. * SOIL SAMPLES TAKEN AT VARIOUS POINTS AT THE FACILITY DURING THE 1984 INSPECTION INDICATE CONTAMINATED SOIL ABOVE EP TOXICITY LIMIS FOR LEAD IN THE USED LIMESTONE WASTE PILES AT THE BATTERY WASTE PILE AREA. * WATER SAMPLES TAKEN DURING THE 1981 INSPECTION INDICATE LEVELS OF CHROMIUM, ARSENIC, AND LEAD ABOVE DRINKING WATER STANDARDS FROM MONITORING W