DISCHARGE OF POLLUTANTS WITHOUT NPDES PERMIT. THE REGION SUGGESTS NEGOTIATION OF AN INJUNCTIVE CONSENT DECREE, WITH APPROPRIATE CIVIL PENALTIES, FOR SIMULTANEOUS FILING WITH THE COMPLAINT. IN ADDITION TO ONGOING CONTACTS BY EPA'S HAZARDOUS WASTE PROGRAM STAFF CONCERNING RCRA CLOSURE OF THE LANDFILL, EPA ISSUED A 02/11/85 ADMIN ORDER TO DEFENDANT REQUIRING THAT UNPERMITTED DISCHARGES CEASE.