1. SECTION 3008(A) OF THE SOLID WASTE DISPOSAL ACT OF 1976, 42 U.S.C. SEC. 6928(A), AS AMENDED BY THE RESOURCE CON- SERVATION AND RECOVERY ACT ( RCRA ), AS FURTHER AMENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984 ( HS- WA ), 42 U.S.C. SEC. 6901 ET SEQ. 2. LACKLAND TRAINING ANNEX SAN ANTONIO, TEXAS 78236-5637 FACILITY ID NO. TX4570099933 DOCKET OR INDEX NO. RCRA VI-311-H 3. RESPONDENT HAS VIOLATED 31 TAC SEC. 335.43 AND SECTION 3005(A) OF RCRA BY TREATING HAZARDOUS WASTE WITHOUT A PERMIT OR INTERIM STATUS. 4. PROPOSED RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA RESPONDENT IS ISSUED A COMPLIANCE ORDER TO CEASE UN- PERMITTED TREATMENT AT ANY OF ITS TREATMENT UNITS THAT DO NOT HAVE A PERMIT OR INTERIM STATUS, PREPARE AND SUBMIT CLOSURE PLANS ANY TREATMENT UNIT LOCATED AT THE FACILITY, AND INSTITUTE A FACILITY ENVIRONMENTAL AUDIT. ALSO, A PROPOSED PENALTY OF $346,500.00 IS ASSESSED. 5. AN AMENDED COMPLAINT WAS FILED ON APR. 13, 1994 BY REGION 6. A NEW VIOLATION WAS ADDED TO THE COMPLAINT. THE RE- SPONDENT VIOLATED 31 TAC SEC. 335.43(A) AND SECTION 3005 (A) OF RCRA AND IS LIABLE FOR CIVIL PENALTIES FOR EACH DAY OF OPERATION AFTER OCT. 6, 1992, BY OPERATING THE SITE 7 WASTE MANAGEMENT UNIT WITH