03/29/91: SYNOPSIS OF THE CASE: GNB INCORPORATED ( GNB ) IS AN AUTOMOTIVE LEAD ACID BATTERY MANUFACTURER, LOCATED IN FARMERS BRANCH, TX. THE COMPANY HAD TWO SURFACE IMPOUNDMENTS WHICH WERE UTILIZED TO MANAGE WASTE WATER GENERATED FROM ITS BATTERY MANUFACTURING OPERATIONS. THE WASTE WTR, CONTAINING LEAD AND TRACE AMOUNTS OF OTHER METALS WAS TREATED TO PRECIPITATE SOLIDS AND PUMPED TO THE TWO SURFACE IMPOUNDMENT FOR SETTLING BEFORE THE WASTE WATER WAS DISCHARGED TO THE SANITARY SEWERAGE SYSTEM. THE PREPCIPITATED SOLIDS EXHIBITED THE CHARACTERISTIC OF EP TOXICITY FOR LEAD. GNB IDENTIFIED ITSELF TO EPA AS A TREATER & STORER OF HAZ WASTE ON AUG 18, 1980. THE FIRST ENFORCEMENT ACTION WAS TAKEN AGAINST GNB ON NOV 9, 1982 AS A RESULT OF DEFICIENCIES IN THEIR SOLID AND HAZ WASTE MANAGEMENT PROGRAM NOTED DURING A COMPLIANCE EVALU -ATION INSPECTION CONDUCTED BY TEXAS DEPT OF WATER RESOURCES ON AUG 20.1982. OVER THE NEXT TWO YEARS, THE COMPANY DID NOT FULLY REMEDY VIOLATIONS CITED IN THE ORIGINAL ENFORCE- MENT ACTIONS OR IN A SUBSEQUENT TDWR COMPLIANCE AGREEMENT OF MARCH 15, 1984. THE FACILITY WAS THEN REFERRED TO EPA FOR FURTHER ACTION.