LEGAL BASIS FOR PROPOSED ACTION: SECTIONS 3008(A) AND (C), AND SECTION 3005(E)(2) OF THE RESOURCE AND RECOVERY ACT OF 1976 (RCRA), AS AMENDED, 42 U.S.C. SECTION 6928(A) AND (C), AND SECTION 6925(E)(2). IDENTITY OF DEFENDANT: GRAND BLANC LANDFILL, INC., 2277 WEST GRAND BLANC ROAD, GRAND BLANC, MICHIGAN 48439. ALLEGED VIOLATIONS: PURSUANT TO AN ADMINISTRATIVE ACTION FILED AGAINST IT, GRAND BLANC ENTERED INTO A CONSENT AGREE- MENT AND FINAL ORDER (CAFO) IN WHICH IT AGREED TO COMPLETE CLOSURE AND TO PROVIDE FINANCIAL ASSURANCES FOR CLOSURE AND POST-CLOSURE. GRAND BLANC FAILED TO PERFORM EITHER OF THESE REQUIREMENTS WITHIN THE TIME STIPULATED IN THE CAFO. IN ADDITION GRAND BLANC LOST INTERIM STATUS BY FAILURE TO CERTIFY COMPLIANCE WITH GROUNDWATER MONITORING AND FINANCIAL RESPONSIBILITY REQUIREMENTS BY THE STATUTORY DEADLINE OF NOVEMBER 8, 1985. PROPOSED RELEIF: EPA REQUESTS THE IMPOSITION OF A PERMA- NENT INJUNCTION REQUIRING COMPLIANCE WITH THE TERMS OF THE CAFO AND RECOMMENDS THE ASSESSMENT OF A CIVIL PENALTY PURSUANT TO SECTION 3008(C). RECENT CONTACTS WITH DEFENDANT: A LETTER FROM VALDUS ADAMKUS, REGIONAL ADMINISTRATOR, DENYING GRAND BLANC'S REQUEST FOR AN EXTENSION TO COMPLETE CLOSURE WAS FORWARDED TO GRAND BLANC ON JUNE 19, 1986. SIGNIFICANCE OF REFERRAL: THE EFFEC