1. SECTION 3008 OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 ( RCRA ), AS AMENDED 42 U.S.C. SEC. 6928, AS AMENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984. 2. CITGO PETROLEUM CORPORATION HIGHWAY 108, CALCASIEU PARISH LAKE CHARLES, LOUISIANA SIC CODE: 4953 OTHER SIC CODES: 2869 2911 2821 3. RESPONDENT HAS VIOLATED SECTION 3005(J)(6)(A) OF RCRA BY PLACING D018 HAZARDOUS WASTE INTO THREE UNRETROFITTED IM- POUNDMENTS AFTER MAR. 29, 1994. 4. PROPOSED RELIEF SOUGHT PURSUANT TO SECTION 3008 OF RCRA, EPA PROPOSES A CIVIL PENALTY OF $47,500.00.