TRIGGS TRAILER CORP. ENTERED INTO A CONSENT AGREEMENT AND CONSENT ORDER (CA/CO) WITH EPA IN JUNE 1989. THE CA/CO REQUIRED PAYMENT OF $15,000 IN PENALTY OVER FOUR YEARS. THE CA/CO ALSO REQUIRED RCRA CLOSURE OF HAZARDOUS WASTE MANAGEMENT UNITS (HWMU) OPERATED BY TRIGGS TRAILER IN BELMOND AND KANAWHA, IOWA. THE CA/CO WAS ALSO SIGNED BY DENNIS TRIGGS, THE PRESIDENT OF TRIGGS TRAILER IN HIS INDIVIDUAL CAPACITY AS AN OWNER/OPERATOR OF THE RCRA FACILITIES. TRIGGS TRAILER FAILED TO MAKE TIMELY PENALTY PAYMENTS AND FAILED TO COMPLETE CLOSURE OF THE HWMUS. IN NOVEMBER 1990, TRIGGS TRAILER FILED A BANKRUPTCY PETITION UNDER CHAPTER 11 FOR CORPORATE REORGANIZATION.