1. SECTION 3008(A) OF THE SOLID WASTE DISPOSAL ACT, AS A- MENDED BY THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976(RCRA), AS AMENDED BY THE HAZARDOUS AND SOLID WASTE ADMENDENTS OF 1984 (HSWA), PUB. LAW. 98-616 (HEREIN JOINTLY REFERRED TO AS ( RCRA ), 42 U.S.C. SEC. 6901, ET. SEQ. 2. WHY WASTEWATER?, INC. 3350 DONIPHAN DRIVE EL PASO, TEXAS 79922 3. THE VIOLATIONS UPON WHICH THE PROPOSED CIVIL ACTION IS BASED: A. WWI HAS VIOLATED THE REGULATIONS PROMULGATED PURSUANT TO SUBTITLE C OF RCRA RELATING TO THE STORAGE OF HAZARDOUS WASTE. 4. PROPOSED RELIEF: RELIEF SOUGHT PURSUANT TO SECTION 3008 (A) OF RCRA WOULD ENJOIN WWI FROM STORING HAZARDOUS WASTE SHIPMENTS AT ITS TRANSFER FACILITY IN EL PASO, TX., IN EXCESS OF TEN DAYS. IN ADDITION, IMPOSITION AND PURSUIT OF A $383,900.00 CIVIL PENALTY, AS CALCULATED UNDER THE RCRA CIVIL PENALTY POLICY, IS ALSO RECOMMENDED. 5. THE MOST RECENT CONTACT WITH DEFENDANT CONCERNING THE VIOLATIONS ALLEGED IN THIS REPORT OCCURRED WHEN EPA IS- SUED RCRA SEC. 3007 REQUESTS FOR INFORMATION IN 1993 AND WHEN THE INTENDED DEFENDANT RESPONDED TO SAID REQUESTS FOR INFORMATION. 6. THE VIOLATIONS ALLEGED IN THE LIT