VALLEY BUMPER RECYCLING, INC.(VBR) OWNS & OPERATES A BUS- INESS LOCATED AT 920 EAST LABURNUM AVE. JUST OUTSIDE RICH- MOND, VA. THIS BUSINESS HAS BEEN IN OPERATION BY VARIOUS EN- TITIES SINCE 1959 & INVOLVES THE NICKEL & CHROME PLATING OF RECYCLED AUTOMOBILE BUMPERS. THE PLATING PROCESS CONSISTS OF PASSING THE BUMPERS THROUGH SEQUENTIAL SERIES OF TANKS WHICH 1ST CLEAN, THEN STRIP & FINALLY PLATE THE BUMPERS. VBR'S HAZARDOUS WASTE MANAGEMENT PRACTICES WERE 1ST DIS- COVERED DURING AN INSPECTION PERFORMED BY PERSONNEL FROM THE VA. STATE HEALTH DEPT.'S BUREAU OF HAZARDOUS WASTE MANAGE- MENT(BHWM) IN 4/83. WBR'S PLATING PROCESS GENERATED A WASTE STREAM WHICH IT DISCHARGED INTO AN ON-SITE SURFACE IMPOUND- MENT. THIS WASTESTREAM WAS A RCRA REGULATED HAZARDOUS WASTE BECAUSE IT EXCEEDED THE EP TOXICITY LIMIT FOR CHROMIUM. CON- SEQUENTLY, VBR WAS GENERATING & STORING HAZARDOUS WASTES. HOWEVER, VBR NEVER NOTIFIED EITHER EPA OR BHWM OF ITS HAZARD OUS WASTE ACTIVITIES AS REQUIRED BY SEC 3010 OF RCRA, 42 USC SEC 6930. ADDITIONALLY, VBR NEVER FILED A PART A PERMIT AP- PLICATION AS REQUIRED BY SEC 3005 OF RCRA, 42 USC SEC 6925. CONSEQUENTLY, VBR NEVER QUALIFIED FOR INTERIM STATUS TO OPER ATE A HAZARDOUS WASTE STORAGE FACILITY. EPA SEEKS 3 TYPES OF RELIEF AGAINST VBR. 1ST, IT SEEKS AN INJUNCTION DIRECTING VBR TO COMPLY W/THE TERMS OF THE CON- SENT AGREEMENT & ORDER. THE INJUNCTION WOULD REQUIRE VBR TO PAY THE ORIGINAL $12,000 CIVIL PENALTY