THIS SUPPLEMENTAL LITIGATION REPORT AUGMENTS THE LITIGATION REPORT SUBMITTED TO THE DEPARTMENT OF JUSTICE ON SEPTEMBER 27, 1994. IT SETS FORTH ADDITIONAL ALLEGATIONS OF VIOLATIONS AND EVIDENCE IN SUPPORT THEREOF WHICH THE DEPARTMENT HAS ALREADY DETERMINED WILL BE INCLUDED IN ANY CIVIL JUDICIAL ACTION TAKEN BY IT IN THE U.S. DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT AGAINST PFALTZ AND BAUER INC., UNDER SECTION 3008(A) OF THE RESOURCE AND RECOVERY ACT, 42 U.S.C. SECTION 6908(A). THE PROPOSED CIVIL ACTION WOULD REQUEST THAT THE COURT ORDER P&B TO COMPLY WITH RCRA AND THE REGULATIONS PROMULGATED THEREUNDER AT 40 C.F.R. PARTS 260 - 268, AND THE STATE OF CONNECTICUT'S FEDERALLY AUTHORIZED HAZARDOUS WASTE MANAGEMENT REGULATIONS (TITLE 22A CHAPTER 449) THE PROPOSED CIVIL ACTION WOULD ALSO REQUEST THAT THE COURT ASSESS CIVIL PENALTIES FOR P&B'S VIOLATIONS OF THESE REGULATIONS.