1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 ( RCRA ), 42 U.S.C. SECTION 6928(A). 2. ADVANCE CHROME CONNECTION, WHOLLY OWNED BY HULCHER ENTER- PRISES INC., A TEXAS COMPANY 2920 NORTH MAIN FORT WORTH, TARRANT COUNTY, TEXAS 76106 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY OP- ERATING HAZARDOUS WASTE STORAGE UNITS WITHOUT A PERMIT OR INTERIM STATUS AS A RESULT OF FAILING TO MEET THE EXEMPT- ION REQUIREMENTS, AND FAILING TO DETERMINE A HAZARDOUS WASTE. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA ISSUED A COMPLIANCE ORDER AND A PROPOSED PENALTY OF $21,375. THE COMPLIANCE ORDER REQUIRES THAT WITHIN 60 DAYS OF THE EFFECTIVE DATE OF THE COMPLAINT, THE RESPOND- ENT 1) PROVIDE TO EPA DOCUMENTATION WHICH VERIFIES THAT ALL HAZARDOUS WASTE ACCUMULATION AREAS AT THE FACILITY ARE BEING OPERATED IN COMPLIANCE, 2) SUBMIT TO EPA, FOR REVIEW AND COMMENT, A STANDARD OPERATING PROCEDURE (SOP) FOR MONITORING AND INSPECTION OF ALL HAZARDOUS WASTE AC- CUMULATION AREAS, 3) SUBMIT TO EPA, FOR REVIEW AND COM- MENT, A SOP FOR THE DETERMINATION OF HAZARDOUS WASTE, AND 4) SUBMIT TO EPA A SUBSEQUENT NOTIFICATION OF HAZARDOUS WASTE MANAGEMENT ACTIVITY.