THE VIOLATIONS INVOLVE A SEPTIC SYSTEM AT A PLANT OWNED BY COMMERCIAL EQUIPMENT IN CARROLL, IA, WHICH REFURBISHES COMMERCIAL REFRIGERATION UNITS WITH CHEMICALS WHICH ARE CLASSIFIED AS HAZARDOUS WASTES. THE COMPANY HAS REPEATEDLY VIOLATED UNDERGROUND INJECTION CONTROL REQUIREMENTS BY DISPOSING OF HAZARDOUS WASTES THROUGH THE SEPTIC SYSTEM. EPA IS REQUESTING COMMERCIAL EQUIPMENT TO PROPERLY CLOSE THE SEPTIC SYSTEM IN ACCORDANCE TO REGULATIONS AND TO UNDERTAKE ANY REMEDIATION ACTION NECESSARY TO CLEAN UP THE CONTAMINATION OF THE GROUNDWATER. THE PROPOSED PENALTY HAS BEEN CALCULATED BASED ON THE UIC SETTLEMENT POLICY. WHERE IS THE DESCRIPTION OF DISCRETE ENVIRONMENTAL PROBLEMS THAT WOULD MAKE THIS A MULTI MEDIA CASE???