ON APRIL 18, 1988, DEFENDANT RECEIVED AN AUTHORIZED REQUEST FOR INFORMATION CONCERNING THE DISPOSAL OF HAZARDOUS SUBSTANCES AT THE LONE PINE LANDFILL SITE IN FREEHOLD TOWNSHIP, NEW JERSEY. THE COMPANY ALSO RECEIVED TWO LETTERS WARNING THAT A RESPONSE TO THIS INFORMATION WAS OVERDUE THAT IF IT DID NOT PROVIDE THE REQUESTED INFORMATION EPA MIGHT INITIATE AN ENFORCEMENT ACTION AGAINST IT. THE COMPANY NEVER RESPONDED TO THESE LETTERS AND DID NOT PROVIDE THE REQUESTD INFORMATION. EPA SEEKS AN ORDER UNDER SECTION 104(E)(5) OF CERCLA, REQUIRING DEFENDANT TO PROVIDE THE INFORMATION REQUESTED BY EPA. IT ALSO SEEKS PENALTIES FOR THE DEFENDANT'S FAILURE TO PROVIDE THE REQUESTED INFORMATION IN VIOLATION OF SECTION 104(E)(1) AND (2).