THE PURPOSE OF THIS REFERRAL IS TO RECOVER PAST EPA RESPONSE COSTS UNDER CERCLA AND TO COLLECT APPROPRIATE RELIEF FOR VIOLATIONS OF AUTHORIZED RCRA SUBTITLE C REQUIREMENTS FROM THOMAS PLATING COMPANY, INC., ITS OWNER, F. JEROME THOMAS, AND ITS SUCCESSOR-IN-INTEREST, A-Z CO. THOMAS PLATING CO. IS A METAL FINISHING BUSINESS. THE PRO- POSED CERCLA ACTION ARISES FROM EPA'S EMERGENCY REMOVAL ACTION AND ATTEMPT TO RECOVER COSTS FROM THE CO. FOLLOWING THE PLANT'S CLOSURE ON 2/23/95, EPA PERFORMED A SITE ASSESS- MENT AND EMERGENCY REMOVAL ACTION. SINCE THAT TIME, EPA HAS SOUGHT TO RECOVER ITS COSTS IN THE AMOUNT OF $302,943. EPA ISSUED A DEMAND FOR PAYMENT ON 7/23/96. TO DATE, EPA HAS NOT RECEIVED A PAYMENT FOR REIMBURSEMENT. EPA ALSO SEEKS $712,635 FOR RCRA VIOLATIONS. THESE VIO- LATIONS CONSIST OF VIOLATIONS OF PREVIOUS NOTICES OF VIO- LATIONS DATING BACK TO 1990. IN A 1990 NOV, RESPONDENT STORED HAZARDOUS WASTES IN OPEN CONTAINERS AND EXCEEDED THE ALLOWABLE TIME FOR SUCH STORAGE. IN A 1994 NOV, RESPONDENT FAILED TO MAKE HAZARDOUS WASTE DETERMINATIONS, TREATING AND DISPOSING OF CHEMICALS WITHOUT A PERMIT, DISPOSAL OF ON-SITE, TREATMENT OR STORAGE OF ANY HAZARDOUS WASTE WITHOUT HAVING EITHER INTERIM STATUS OR PER= MIT, FAILURE TO CONDUCT ADEQUATE CONTAINER INSPECTIONS, FAILURE TO TRANSFER HAZARDOUS WASTE FROM A DAMAGED CONTAINER TO A GOOD ONE, FAILURE TO CONDUCT AD