BACKGROUND: * BEN M. HOGAN CO OPERATES AN ASPHALT PRODUCTION PLANT. IN 1986 THE FACILITY SUBMITTED A PART A FOR STORAGE AND BURNING OF HAZ WASTE FUEL FOR ENERGY. THE FACILITY HAS SINCE CHANGED THE PROCESS AND REVERTED BACK TO BURNING NATURAL` GAS. * ARKANSAS DEPT OF POLLUTION CONTROL AND ECOLOGY REFERRED THIS CASE TO EPA FOR ENFORCEMENT OF SUBPART H VIOLATIONS ONLY. ADPC&E IS PURSUING ENFORCEMENT OF OTHER RCRA VIOLA- TIONS AT THE FACILITY. * ACTION REQUESTED: * RECOMMEND THE AO FOR FAILURE TO HAVE FINANCIAL ASSURANCE FOR CLOSURE AND SUDDEN LIABILITY INSURANCE BE SIGNED AND ISSUED. PENALTY IMPOSED $4,500 FOR FAILURE TO ESTABLISH FINANCIAL ASSURANCE FOR CLOSURE & FAILURE TO DEMONSTRATE FINANCIAL ASSURANCE FOR SUDDEN ACCIDENTAL OCCURRENCES.