THIS REFERRAL REQUESTS THE FILING OF A CIVIL ACTION PURSUANT TO SECTION 3008 OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928, AGAINST WORMUTH BROTHERS FOUNDRY, INC FOR VIOLATIONS OF RCRA OCCURRING AT THE COMPANY'S FACILITY LOCATED IN ATHENS, NEW YORK. THE REFERRAL REPORT DESCRIBES SEVENTEEN SEPARATE VIOLATIONS OF FEDERAL AND STATE RCRA REGULATIONS. WORMUTH IS A NON-NOTIFYING GENERATOR OF WASTE WHICH HAS BEEN FOUND TO BE HAZARDOUS DUE TO THE PRESENCE OF LEAD. WORMUTH HAS STORED SUCH WASTE AT ITS FACILITY, IN A FEDERALLY-PROTECTED WETLAND, FOR OVER THREE YEARS, WITHOUT A PERMIT AND WITH- OUT INTERIM STATUS UNDER SECTION 3005E OF RCRA, 42 U.S.C. SECTION 6925E. THESE WASTES HAVE BEEN STORED IN OPEN, CORRODED CONTAINERS. AMONG THE MORE SIGNIFICANT VIOLATIONS CITED ARE: FAILURE TO NOTIFY EPA OF HAZARDOUS WASTE ACTIVITY; FAILURE TO SUBMIT A PERMIT APPLICATION; FAILURE TO MAKE A HAZARDOUS WASTE DETERMINATION; FAILURE TO MAINTAIN AND OPERATE THE FACILITY TO PREVENT A RELEASE OF HAZARDOUS WASTES TO THE ENVIRONMENT; AND ILLEGAL LAND DISPOSAL OF HAZARDOUS WASTES. * FACILITY ADDR (IN FINDS) HOWARD HALL RD & SCHOHARIE TURNPIKE ATHENS, NY 12015