1. SECTION 3008 OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 ( RCRA ), 42 U.S.C. SEC. 6901 ET SEQ. 2. AIR PRODUCTS, INC. HIGHWAY 225 P.O. BOX 3326 PASADENA, TEXAS 77501 3. RESPONDENT VIOLATED SUBTITLE C OF RCRA BY FAILING TO LA- BEL HAZARDOUS WASTE CONTAINERS, FAILING TO UPDATE WASTE ANALYSIS PLAN FOR BIF, FAILING TO UPDATE CLOSURE PLAN FOR BIF, AND FAILING TO UPDATE FINANCIAL ASSURANCE IN A TIME- LY MANNER. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA IS SEEKING A CIVIL PENALTY OF $17,300 AND IS ISSUING A COM- PLIANCE ORDER TO THE RESPONDENT. THE COMPLIANCE ORDER RE- QUIRES THE RESPONDENT TO FURNISH EPA WITH WASTE CHARACT- ERIZATION INFORMATION AND DOCUMENTATION OF SHIPMENT OFF- SITE AND PROPER DISPOSAL OF THE UNLABELED 29 DRUMS OF BOILER ASH/RESIDUE THAT HAS STORED NEAR THE RAW MATERIALS STORAGE AREA, AND SUBMIT TO EPA FOR REVIEW AND COMMENT, A WASTE ANALYSIS PLAN, CLOSURE PLAN, AND FINANCIAL ASSUR- ANCE.