ON SEPTEMBER 15, 1983, AND MARCH 22, 1984, REPRESENTA- TIVES OF THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY (IEPA) INSPECTED RESPONDENT'S CRAIG LAKE ROAD FACILITY TO DETERMINE COMPLIANCE WITH THE ILLINOIS ENVIRONMENTAL PROTECTION ACT, ILL. REV. STAT. 1982, CH. 111-1/2, SECTION 1001 ET SEQ., AS AMENDED, AND REGULATIONS ADOPTED BY THE ILLINOIS POLLUTION CONTROL BOARD, INCLUDING 35 ILL. ADM. CODE PART 725. DURING THESE INSPECTIONS, RESPONDENT'S CRAIG LAKE ROAD FACILITY WAS DETERMINED TO BE IN VIOLATION OF MONITORING REQUIREMENTS SET FORTH AT 35 ILL. ADM. CODE SECTION 725.191, SECTION 725.190, SECTION 725.192, SECTION 725.193 AND SECTION 725.194. SPECIFICALLY, THE FOLLOWING VIOLATIONS WERE IDENTIFIED: A. FAILURE TO ESTABLISH AN UPGRADIENT WELL CAPABLE OF MONI- TORING THE UPPERMOST AQUIFER, AS REQUIRED BY 35 ILL. ADM. CODE SECTION 35 ILL. ADM. CODE SECTION 725.191(A) (1). B. FAILURE TO ESTABLISH DOWNGRADIENT WELLS OF APPROPRIATE DEPTH TO DETECT MIGRATION OF CONTAMINANTS, AS REQUIRED BY 35 ILL. ADM. CODE SECTION 725.191(A)(2). C. FAILURE TO CONSTRUCT THE MONITOR WELLS IN A PROPER MANNER TO INSURE COLLECTION OF REPRESENTATIVE SAMPLES FROM THE APPROPRIATE AQUIFER FLOW ZONE, AS REQUIRED BY 35 ILL. ADM. CODE SECTION 725.191(C). D. FAILURE TO DEVELOP AND FOLLOW A SAMPLING AND ANALYSIS PLAN, AS REQUIRED BY 35 ILL. ADM.