ON DECEMBER 30, 1993, THE ACTING REGIONAL ADMINISTRATOR SIGNED A MULTI-MEDIA CIVIL LITIGATION REPORT IN SUPPORT OF EPA'S REQUEST THAT A COMPLAINT BE FILED AGAINST ACTION MANUFACTURING COMPANY ( ACTION ) UNDER SECTION 3008(A) OF THE CONSERVATION AND RECOVERY ACT ( RCRA ), SECTION 107 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT OF 1980, AS AMENDED BY THE SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986, PUB. L. NO. 99- 499 ( CERCLA ), AND SECTIO 1421 OF THE SAFE DRINKING WATER ACT ( SDWA ). EPA IS SPECIFICALLY REQUESTIONG THAT THE DEPARTMENT OF JUSTICE COMMENCE AN ACTION UNDER RCRA AND THE SDWA FOR INJUNCTIVE RELIEF AND PENALTIES AND UNDER CERCLA TO RECOVER COSTS INCURRED BY THE UNITED STATES AT THE ABOVE- REFERENCED FACILTIY. THIS ACTION SEEKS TO ENFORCE CERTAIN PROVISION OF RCRA WITH RESPECT TO THE DEFENDENT'S OPERATION OF HAZARDOUS WASTE MANAGEMENT UNITS WITHOUT A PERMIT OR INTERIM STATUS, AS WELL AS FAILURE TO COMPLY WITH INTERIM STATUS STANDARDS RELATING TO THOSE UNITS. BY THIS ACTION EPA ALSO SEEKS TO ENFORCE THE SDWA WITH RESPECT TO THE DEFENDANT'S OPERATION OF AN INJECTION WELL IN VIOLATION OF THE UNDERGROUND INJECTION WELL ( UIC ) PROGRAM. IN ADDITION, THIS ACTION SEEKS RE- COUPMENT OF APPROXIMATELY $212,000.00 INCURRED BY THE UNITED STATES FOR CERCLA EMERGENCY REMOVAL MEASURES UNDERTAKEN AT THE DEFENDANT'S FACILITY. EPA IS SE