LEGAL BASIS FOR PROPOSED ACTION: SECTION 3008 OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976, AS AMENDED, 42 U.S.C. SECTION 6901 ET SEQ. IDENTITY OF DEFENDANT: RSR - QUEMETCO, INCORPORATED, 900 QUEMETCO DRIVE, INDIANAPOLIS, INDIANA 46321. ALLEGED VIOLATIONS: FROM NOVEMBER 9, 1985 TO THE PRESENT, QUEMETCO, INC. (QI) HAS BEEN STORING HAZARDOUS WASTE AT ITS LAND DISPOSAL FACILITY WITHOUT A PERMIT OR INTERIM STATUS IN VIOLATION OF SECTION 3005(A) OF RCRA. THE INTERIM STATUS OF QI WAS TERMINATED BY OPERATION OF LAW ON NOVEMBER 9, 1985. SUCH TERMINATION RESULTED FROM QI'S FAILURE TO CERTIFY THAT ITS FACILITY WAS IN COMPLIANCE WITH ALL APPLICABLE GROUNDWATER MONITORING AND FINANCIAL RESPON- SIBILITY REQUIREMENTS BY NOVEMBER 8, 1985 AS REQUIRED BY SECTION 3005(E)(2). QI THEN FAILED TO SUBMIT A CLOSURE AND POST-CLOSURE PLAN BY NOVEMBER 23, 1985 (15 DAYS AFTER TERMINATION OF INTERIM STATUS) AS REQUIRED BY 40 C.F.R. 265.112(C). EVEN BEFORE QI'S LOSS OF INTERIM STATUS, QI HAD BEEN WITHOUT ADEQUATE INSURANCE LIABILITY COVERAGE SINCE AUGUST 27, 1985 IN VIOLATION OF 40 C.F.R. 265.147. PROPOSED RELIEF: THE AGENCY SEEKS A PRELIMINARY INJUNC- TION AND A PERMANENT INJUNCTION WHICH WOULD PROHIBIT QI FROM STORING OR DISPOSING OF ANY WASTE AT ITS FACILITY AND WOULD REQUIRE QI TO CLOSE ITS ON-SITE WASTE PILES AND SUR- FACE IMPOUNDMENTS. IN ADDITION, THE A