FACTS/BACKGROUND: * - CHEMICAL MANUFACTURER: MALEIC ANHYDRIDE AND NEOPRENE RUBBER. - SURFACE IMPOUNDMENT WAS RECEIVING HAARDOUS WASTE. - HAZARDOUS ONLY FOR PH LESS THAN 2.0. - STOPPED ADDING WASTE OF PH LESS THAN 2.0 PRIOR TO NOV 8, 1985. - LOST LIABILITY INSURANCE BEFORE NOV 8, 1985, THEREFORE, LOST INTERIM STATUS. - HAS NOT CLOSED SURFACE IMPOUNDMENT. - MUST MAINTAIN LIABILITY INSURANCE UNTIL CERTIFIED CLOSED. - REFERRED TO EPA BY TWC FOR FINANCIAL VIOLATIONS. - FACTS MEETING CONFIRMED NO INSURANCE. * REQUESTED ACTION: * SIGN AO FOR ISSUANCE. CA & FO: - DENKA WAS REFERRED TO EPA BY TWC FOR FAILURE TO PROVIDE LIABILITY INSURANCE. - DENKA IS CLOSING IT'S LAND DISPOSAL UNITS. - DENKA LOST INTERIM STATUS BECAUSE THEY COULD NOT CERTIFY THEY WERE IN COMPLIANCE WITH THE FINANCIAL REQUIREMENTS. - EPA COULD NOT OBTAIN ADEQUATE EVI