1. SECTION 3008(A) OF THE RESOURCE, CONSERVATION AND RECOV- ERY ACT OF 1976 ( RCRA ), 42 U.S.C. SEC. 6928 ET SEQ. 2. B. J. TIDWELL CARDELL CABINETS, INC. 3215 NORTH PAN AM EXPRESSWAY SAN ANTONIO, TEXAS 78220-0850 FACILITY ID. TXD085154359 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) FAILING TO LABEL CONTAINERS, 2) FAILING TO PROPERLY MAN- AGE CONTAINERS, 3) INADEQUATE PERSONNEL TRAINING AND TRAINING RECORDS, 4) FAILING TO MAINTAIN ADEQUATE CON- TINGENCY PLAN, 5) INSUFFICIENT AISLE SPACE, 6) OPERATING A HAZARDOUS WASTE STORAGE AND DISPOSAL FACILITY WITHOUT A PERMIT, 7) FAILING TO COMPLY WITH THE 55 GALLON RULE, AND 8) LAND DISPOSAL OF RESTRICTED WASTES. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSES A PENALTY OF $774,065 FOR THE ALLEGED VIOLATIONS AND A COMPLIANCE ORDER TO CORRECT THE ALLEGED VIOLATIONS. THE COMPLIANCE ORDER REQUIRES THE RESPONDENT TO 1) PROP- ERLY LABEL ALL CONTAINERS AND THE REMOVAL OF ALL VOLUMES OF HAZARDOUS WASTE EXCEEDING 55 GALLONS FROM ACCULUMATION AREAS, 2) WITHIN 30 DAYS SUBMIT EVIDENCE OF SUFFICIENT AISLE SPACE FOR INSPECTION AND EMERGENCY RESPONSE, 3) IMMEDIATELY CEASE ALL UNAUTHORIZED DISCHARGES OR SPILLS OF HAZARDOUS MATERIALS AND SUBMIT