EPA DETERMINED EARLY THIS YEAR THROUGH SEVERAL INSPECT- IONS OF THIS FACILITY THAT THE DEFENDANT CORPORATION WAS IN VIOLATION OF MANY OF THE MORE SERIOUS PROVISIONS OF THE FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT(FIFRA), INCLUDING IMPROPER DISPOSAL OF PESTICIDES, OPERATING AN UNRE GISTERED PRODUCER ESTABLISHMENT, AND DISTRIBUTING UNREGISTER ED PESTICIDES. ON MAY 27, 1986, A COMPLAINT WAS FILED IN THE UNITED STATES DISTRICT COURT FOR THE DISTRIC OF COLORA- DO AGAINST MIBAR AND MICHAEL LEVINE SEEKING AN INJUNCTION RELATING TO THESE VIOLATIONS. ON MAY 30,1986, A CONSENT DECREE BETWEEN THE UNITED STATES AND MIBAR TO COMPLY WITH THE TERMS OF THE INJUNCTION. THE CONSENT DECREE ESTABLISHED A COMPLIANCE PROGRAM TO REMEDY EXISTING VIOLATIONS OF FIFRA AND RESTRAINED FUTURE VIOLATIONS. THE ATTACHED AFFIDAVITS DEMONSTRATE THAT THE DEFENDANTS HAVE VIOLATED ALMOST EVERY PROVISION OF THIS DECREE.