THIS REFERRAL ISSUED FOR VIOLATIONS OF REPORTING REQUIREMENTS ASSOCIATED WITH THE LANDFILL GAS REMEDY DESCRIBED IN THE LFG CMP. DEFENDANTS ALSO FAILED TO ENSURE COMPLIANCE WITH THE LFG PERFORMANCE STANDARDS LISTED IN THE ROD AND LFG CMP AS REQUIRED BY PARAGRAPH 36 (WORK TO BE PERFORMED)OF THE UAO. ALSO, DEFENDANTS FAILED TO IMMEDIATELY TAKE ACTION TO PREVENT, ABATE, OR MINIMIZE THE PRESENCE OF VOCS IN THE SUBSURFACE ENVIRONMENT AT THE SITE BOUNDARIES AND FAILED TO IMMEDIATELY NOTIFY EPA AS REQUIRED BY THE UAO. PROPOSED PENALTY: $828,300.