IN THE EARLY 1980'S, ESCAMBIA TREATING COMPANY, INC. (ESCAMBIA) OWNED AND OPERATED FOUR WOOD TREATMENT FACILITIES LOCATED IN PENSACOLA, FL.; BROOKHAVEN, MS.; BRUNSWICK. GA.; AND CAMILLA, GA. THE COMPANY HEADQUARTERS WAS ALSO LOCATED IN PENSACOLA. EACH FACILITY INCLUDED A SURFACE IMPOUNDMENT, CONTAINING A BOTTOM SEDIMENT SLUDGE DESIGNATED AS EPA HAZARDOUS WASTE NUMBER K001. CONSEQUENTLY, THE FACILITIES WERE SUBJECT TO REGULATION UNDER RCRA, 42 U.S.C. SECTION 9601, AND A PART A APPLICATION WAS SUBMITTED FOR EACH FACILITY, QUALIFYING THE FACILITIES FOR INTERIM STATUS. HOWEVER, ADEQUATE PART B APPLICATIONS HAVE NOT BEEN RECEIVED FOR ANY OF THE FACILITIES, NOR HAVE THE GROUNDWATER MONITORING REQUIREMENTS OF 40 CFR PART 265, SUBPART F, AND THE FINANCIAL RESPONSIBILITY REQUIREMENTS OF 40 CFR PART 265, SUBPART H, BEEN MET. AS A RESULT, EACH FACILITY HAS LOST INTERIM STATUS. THERE ARE ADDITIONAL VIOLATIONS AT EACH FACILITY RELATED TO CLOSURE, POST-CLOSURE CARE, GROUNDWATER MONITORING, GROUNDWATER QUALITY ASSESSMENT, LIABILITY INSURANCE REQUIRE- MENTS AND GENERAL FACILITY OPERATING STANDARDS. IN ADDITION, CORRECTIVE ACTION WILL BE REQUIRED AT EACH FACILITY. THE PARCELS OF LAND ON WHICH THE REGULATED SURFACE IMPOUNDMENTS SIT REMAIN AS THE PRINCIPAL ASSETS. THE COMPANY NOW LACKS SUFFICIENT ASSETS TO CLOSE THE IMPOUNDMENTS AND TO CARRY OUT THE CORRECTIVE ACTION NEEDED AT EACH FACILITY.