ACME FILL CORPORATION OWNS AND OPERATES A HAZARDOUS WASTE DISPOSAL FACILITY IN CONTRA COSTA COUNTY, CALIFORNIA. EPA APPROVED A FINAL CLOSURE PLAN FOR THE FACILITY ON MAY 25, 1989. ACME HAS COMPLIED WITH VERY FEW OF THE REQUIREMENTS IN THE CLOSURE PLAN AND HAS APPEALED THE FINAL CLOSURE PLAN. THIS ACTION IS A COUNTER CLAIM FOR PENALTIES AND COMPLIANCE WITH THE CLOSURE PLAN.