THIS IS A REFERRAL TO DOJ ASKING THAT A COMPLAINT BE FILED AGAINST THE TRW VSSI COMPANY FOR VIOLATIONS OF RCRA. THE PRIMARY FACILITY THAT IS THE SUBJECT OF THE REFERRAL IS TRW VSSI'S MESA II AIRBAG MANUFACTURING PLANT. THERE ARE EIGHT COUNTS FOR VIOLATIONS AT THIS FACILITY. THE PRINCIPAL VIOLATIONS ARE STORAGE IN TANKS AND SURFACE IMPOUNDMENTS WITHOUT A PERMIT, FAILURE TO COMPLY WITH STANDARDS FOR TANKS AND SURFACE IMPOUNDMENTS AND VIOLATION OF LAND DISPOSAL RESTRICTIONS. THE PROPOSED PENALTY FOR THESE VIOLATIONS IS $5,776,680. THERE IS NOT YET A FIRM FIGURE FOR THE INJUNCTIVE RELIEF, BUT IT IS LIKELY TO BE AT LEAST $1 MILLION TO $2 MILLION, SINCE IT INVOLVES INVESTIGATION AND REMEDIATION OF 24 TANKS & SURFACE IMPOUNDMENTS. THE SECOND MAJOR FACILITY THAT IS COVERED BY THE REFERRAL IS WASTE MANAGEMENT BUTTERFIELD STATION WHERE TRW DISPOSED OF WASTE UNLAWFULLY. HERE THE TWO PRINCIPAL COUNTS ARE LAND DISPOSAL AND VIOLATIONS OF TREATMENT STANDARDS UNDER THE LAND DISPOSAL RESTRICTIONS. THE PROPOSED PENALTY FOR BUTTERFIELD TOTALS $1,019,756. THE PRINCIPAL INJUNCTIVE RELIEF WILL BE REMEDIATION OF UNLAWFULLY DISPOSED WASTE. TRW HAS ESTIMATED THAT IT WOULD COST $16 MILLION TO REMOVE THE WASTE. IT IS LIKELY THAT THE ACTUAL INJUNCTIVE RELIEF TO BE AGREED UPON WILL INVOLVE SOME ON-SITE REMEDIATION OPTION THAT WOULD COST CONSIDERABLY LESS, BUT COULD EASILY BE IN EXCESS OF $2 MILLION TO $3 MILLION. ADDITIONAL VIOLATIONS RELATE TO TRW'S IMPROPER WASTE IDENTIFICATION, MANIF