IT CORPORATION OWNS AND OPERATES HAZARDOUS WASTE TRANSPOR- TATION AND DISPOSAL FACILITIES THROUGHOUT THE UNITED STATES. ONE OF THE MANY IT FACILITIES IS NAMED THE BAKER FACILITY AND IS LOCATED NEAR MARTINEZ, CA. AT THE BAKER FACILITY HAZARDOUS WASTES ARE TREATED, STORED, AND DISPOSED OF IN SURFACE IMPOUNDMENTS. RECORDS FURNISHED BY IT SHOW THAT SURFACE IMPOUNDMENTS D-1 AND D-2 WERE EMPTY FROM JULY 1985 TO JANUARY 1986, SURFACE IMPOUNDMENTS D-3 AND E WERE EMPTY FROM MAY 1985 TO JANUARY 1986. IT IS IN THE PROCESS OF CONSTRUCTING A SLURRY WALL TO CONFINE WASTES IN IMPOUNDMENTS D-2 AND D-3. THE SURFACE IMPOUNDMENTS WERE OBSERVED TO BE FULL ON MARCH 18, 1986. THE SURFACE IMPOUNDMENTS MEET THE DEFINITION OF REPLACEMENT UNITS AND SHOULD HAVE MET THE MINIMUM TECHNOLOGY REQUIREMENTS PRIOR TO REUSE. (THE MINIMUM TECHNOLOGY REQUIREMENTS ESSENTIALLY REQUIRE A DOUBLE LINER AND A LEACHATE COLLECTION SYSTEM BEFORE REUSE.) HOWEVER, THE IMPOUNDMENTS DID NOT MEET THE MINIMUM TECHNOLOGY REQUIRE- MENTS. THE LEGAL BASES FOR THE VIOLATION ARE SECTIONS 3004(B), (42 U.S.C. 6924) AND 3015 (42 U.S.C. 6935) OF THE RESOURCE CONSERVATION AND RECOVERY ACT AS AMENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984. THESE PROVISIONS ARE INTERPRETED BY EPA/530-SW-85-012 DATED MAY 24, 1985 (REAUTH- ORIZATION STATUTORY INTERPRETATION #5D