NIBCO , INC. WAS INCORPORATED IN AND UNDER THE LAWS OF THE STATE OF INDIANA ON OR ABOUT DEC. 15, 1909 ( NIBCO, INC. OF INDIANA ). NIBCO, INC., NACOGDOCHES DIVISION ( RESPONDENT ), IS A DIVI- SION OF NIBCO, INC. OF INDIANA AND IS AUTHORIZED TO DO BUS- INESS IN THE STATE OF TEXAS. RESPONDENT MAY BE SERVED WITH LEGAL PROCESS BY SERVING ITS REGISTERED AGENT, C.T. CORPORATION SYSTEM, AT 350 NORTH ST. PAUL STREET, DALLAS, TX. 75201. RESPONDENT OWNS AND OPERATES A BUSINESS LOCATED AT 723 SOUTH FREDONIA STREET, NACOGDOCHES, TX., WHERE IT CONDUCTS BRASS FOUNDRY AND BRASS VALVE MANUFACTURING AND FINISHING OPERATIONS (THE PLANT ). RESPONDENT'S PLANT IS COMPRISED OF TWO FOUNDRIES. UNIT 1, BUILT IN 1942, USES THREE ELECTRICAL INDUCTION FURNACES. UN- IT 2 IS A NEWER, MORE AUTOMATED FOUNDRY AND USES FOUR ELECT- RICAL INDUCTION FURNACES. RESPONDENT GENERATES AND HANDLES SEVERAL DIFFERENT WASTES RESULTING FROM THE FOUNDRY AND MANUFACTURING PROCESSES. THE CITY OF NACOGDOCHES (THE CITY ) OPERATESA MUNICIPAL LANDFILL UNDER TEXAS PERMIT NO. 720 (THE MUNICIPAL LAND- FILL ). ON OR ABOUT AUG. 15, 1980, RESPONDENT SUBMITTED A NOTIFICA- TION OF HAZARDOUS WASTE ACTIVITY TO EPA. IN THE NOTIFICA- TION, RESPONDENT STATED THAT THE NOT