1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 ( RCRA ), 42 U.S.C. SECTION 6901 ET SEQ. 2. PHILLIPS PETROLEUM COMPANY SPUR 119 NORTH BORGER,TEXAS 79008 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) DISPOSING OF A HAZARDOUS WASTE WITHOUT A PERMIT OR INTER- IM STATUS, AND TWO COUNTS OF OPERATING A HAZARDOUS WASTE STORAGE FACILITY WITHOUT A PERMIT OR INTERIM STATUS (FAILURE TO MEET THE EXEMPTION OF 40 CFR SEC. 262.34 NINETY DAY OR LESS HAZARDOUS WASTE GENERATOR REQUIRE- MENTS). 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA ISSUED A COMPLIANCE ORDER AND PROP[OSED A CIVIL PENALTY OF $45,500. THE COMPLIANCE ORDER REQUIRES THE RESPONDENT TO 1) SUBMIT AN AMENDED NOTIFICATION OF HAZARDOUS WASTE MANAGEMENT ACTIVITY TO TRNCC AND EPA WITHIN 60 DAYS RE- CEIPT OF THE COMPLAINT, 2) SUBMIT A STANDARD OPERATING PROCEDURE (SOP) FOR THE MONITORING AND INSPECTIONS OF THE 90 DAYS OR LESS HAZARDOUS WASTE ACCUMULATION POINTS WITH- IN 120 DAYS OF RECEIPT OF THE COMPLAINT TO EPA FOR REVIEW AND COMMENT, AND 30 PERFORM SUCH TASKS AS ARE REQUIRED TO PREVENT FUTURE RELEASES OF F037 HAZARDOUS WASTE FROM THE TRANSFER BOX AND WITHIN 120 DAYS OF RECEIPT OF COM- PLAINT, PROVIDE EPA THE MEASURES