ACTION REQUESTED: ISSUE A 3008(A) COMPLAINT, COMPLIANCE ORDER AND NOTICE OF OPPORTUNITY FOR HEARING FOR PERMIT VIOLATIONS. BACKGROUND: * TRANE COMPANY IS A MANUFACTURER OF HIGH VOLUME HEATING AND AIR CONDITIONING EQUIPMENT. THE MANUFACTURING OPERATIONS INVOLVE THE GENERATION AND STORAGE OF HAZARDOUS WASTES INCLUDING SPENT SOLVENTS AND IGNITABLE WASTES. * TRANE COMPANY OPERATES UNDER A PERMIT ISSUED BY THE TEXAS WATER COMMISSION, PERMIT HW-50050. THE PERMIT INCORPORATES BY REFERENCE 40 CFR 264, SUBPART H, REQUIRING DEMONSTRATION OF FINANCIAL RESPONSIBILITY FOR SUDDEN ACCIDENTAL OCCUR- RENCES. * RECOMMENDATION: * WE RECOMMEND A COMPLAINT, COMPLIANCE ORDER BE ISSUED REQUIRING COMPLIANCE WITH THE PERMIT REQUIREMENTS AND A PROPOSED PENALTY OF $2,500.