THE KDM COMPANY CASE WAS REFERRED TO EPA ON APRIL 4, 1986, FOR ENFORCEMENT. IT WAS DETERMINED THAT KDM WAS A HIGH PRIORITY VIOLATOR ON MARCH 25, 1986, BECAUSE IT FAILED TO MAINTAIN SUDDEN LIABILITY INSURANCE COVERAGE. * KDM OPERATES A SOLVENT RECOVERY FACILITY IN SAN ANTONIO, TX. AS PART OF ITS PROCESS, KDM RECEIVES WASTE SOLVENTS FROM OTHER INDUSTRIES AND STORES THESE WASTE SOLVENTS IN TANKS PRIOR TO RECYCLING IN DISTILLATION UNITS. KDM GENERATES BOTH HALOGENATED AND NON-HALOGENATED STILL BOTTOMS FROM THE RECOVERY OF THESE SOLVENTS. THESE STILL BOTTOMS ARE STORED IN CONTAINERS OR TANKS LOCATED ON-SITE AND ARE HAZARDOUS WASTES AS DEFINED IN 40 CFR 261.31 UNDER CODES F002, F003, AND F005. THE HALOGENATED STILL BOTTOMS ARE DISPOSED OF OFF-SITE AND THE NON-HALOGENATED STILL BOTTOMS ARE SOLD AS A BLENDED FUEL TO AN OFF-SITE FACILITY. * ON NOVEMBER 26, 1985, TWC ISSUED A WARNING LETTER TO KDM INFORMING THE FACILITY THAT TWC HAD RECEIVED A NOTICE OF NON-RENEWAL FROM THE FACILITY'S INSURANCE COMPANY AND GIVING KDM 30-DAYS TO SUBMIT PROOF OF COVERAGE BY AN ALTERNATE CARRIER OR MECHANISM. * ON DECEMBER 16, 1985, TWC RESPONDED TO KDM'S DEC 9, 1985, RESPONSE TO TWC'S NOV 26, 1985, LETT