VIOLATION: IN EXCESS OF 62 LBS. PER DAY OF CHROMIUM ARE MIGATING FROM ALLIED'S FACILITY TO THE PATAPSCO RIVER, PAT- UXENT AQUIFER AND INNER HARBOR. PROPOSED INJUNCTIVE RELIEF REQUIRING ALLIED TO UNDERTAKE CORRECTIVE MEASURES TO PREVENT OR MITIGATE RELEASE OR THREATENED RELEASES OF SOLID WASTE, HAZARDOUS WASTE OR HAZARDOUS WASTE CONSTITUENTS FROM THE FACILITY TO PROTECT PUBLIC HEALTH AND WELFARE AND THE ENVIR- ONMENT.