LEGAL BASIS FOR PROPOSED ACTION: SECTION 3008 OF THE RE- SOURCE CONSERVATION AND RECOVERY ACT OF 1976, AS AMENDED, 42 U.S.C. SECTION 6901 ET SEQ. IDENTITY OF DEFENDANT: THOMAS S. SAVAGE, LAST KNOWN AD- DRESS: 313 SOUTH LAKESHORE DRIVE, FOREST LAKE, MINNESOTA 55025. MR. SAVAGE, DOING BUSINESS AS T.S.S. CORPORATION, OWNS A FACILITY AT 1724 CLINTON STREET, KALAMAZOO, MI. ALLEGED VIOLATIONS: AS OF NOVEMBER 26, 1985, MR. SAVAGE HAS FAILED TO COMPLY WITH PARAGRAPHS (1), (2) AND (5) OF THE CONSENT AGREEMENT AND FINAL ORDER DULY ENTERED INTO BY HIMSELF WITH THE U.S. EPA ON JUNE 6, 1985. THESE VIOLA- TIONS CONSIST OF FAILURE TO PROVIDE THE EPA WITH SPECI- FIED DOCUMENTS, FAILURE TO PAY A CIVIL PENALTY, AND FAIL- URE TO MAKE A DEED NOTATION. PROPOSED RELIEF: INJUNCTION REQUIRING PROOF OF NOTATION ON DEED OF KALAMAZOO PROPERTY REGARDING PRESENCE OF CONTAMI- NATION BENEATH BUILDING AND NECESSITY FOR PROPER DISPOSAL OF CONTAMINATED MATERIALS. CIVIL PENALTY UNDER RCRA SECTION 3008(G) IN THE AMOUNT OF TWO THOUSAND, TWO HUNDRED FIFTY DOLLARS ($2,250.00). CIVIL PENALTY UNDER RCRA SECTION 3008(C) IN THE AMOUNT OF SEVEN HUNDRED FIFTY DOLLARS ($750.00). RECENT CONTACTS WITH DEFENDANT: THOMAS SAVAGE SIGNED, ON MAY 22, 1985, A FINAL ORDER AND CONSENT AGREEMENT ISSUED BY REGION V ON JUNE 6, 1985. THE