ILLEGAL STORAGE AND DISPOSAL OF F032, F034 AND CCA. ONE DEFENDANT -- BROWN WOOD, THE CORPORATION. NATURE OF RELIEF REQUESTED: PENALTY AND COMPLIANCE WITH RCRA -- RCRA CLOSURE; CLEANUP. NATIONALLY SIGNIFICANT ISSUES: PENALTY IS ESTIMATED AT 3 MILLION; POTENTIAL HARMON ISSUES; HISTORY OF NONCOMPLIANCE. SEE ALSO 04-2000-0851. AMENDED REFERRAL SENT TO DOJ ON 06/26/01. SUPPLEMENTAL REFERRAL IS BASED UPON VIOLATIONS OF SECTION 301 AND 402 OF THE CWA. THE DEFENDANT, BROWN WOOD PRESERVING CO., IS A WOOD TREATING FACILITY LOCATED IN TUSCALOOSA COUNTY, NORTHPORT, AL. THE FACILITY OPERATES UNDER AN NPDES PERMIT WITH STORMWATER DISCHARGE REQUIREMENTS ISSUED BY THE ALABAMA DEPT. OF ENVIRONMENTAL MANAGEMENT (ADEM) UNDER PERMIT NO. AL0001121. THE FACILITY HAS VIOLATIONS OF ITS PERMIT CONDITIONS RELATING TO THE BEST MGMT PRACTICES (BMP) PLAN AND REQUIREMENTS TO MAINTAIN APPROPRIATE RECORDS. BASED UPON EPA INSPECTIONS AND THE REVIEW OF THE FACILTY'S BMP PLAN, EPA HAS DOCUMENTED 63 VIOLATIONS OF THE PERMIT, INCLUDING (1) FAILURE TO DEVELOP AN ADEQUATE BMP PLAN WHICH PREVENTS OR MINIMIZES STORMWATER CONTAMINATION; (2) FAILURE TO IMPLEMENT THE CONDITION OF ITS BMP PLAN; AND (3) FAILURE TO PROPERLY DOCUMENT RAINFALL AND SAMPLING RECORDS. EPA HAS CALCULATED A CIVIL PENALTY AMOUNT OF $28,000 US