1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 42 U.S.C. 2. REYNOLDS METALS COMPANY, A DELAWARE CORPORATION HIGHWAY 361 E GREGORY, SAN PATRICIO COUNTY, TEXAS 78359 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) FAILURE TO MAKE A HAZARDOUS WASTE DETERMINATION, AND 2) OPERATING A HAZARDOUS WASTE STORAGE UNIT WITHOUT INTERIM OR PERMIT BY FAILING TO MEET EXEMPTION REQUIREMENTS. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSES A CIVIL PENALTY OF $13,249, AND ISSUED A COMPLI- ANCE ORDER TO THE RESPONDENT. THE ORDER REQUIRES THE RE- SPONDENT TO: 1) IMMEDIATELY CEASE UNAUTHORIZED STORAGE OF HAZ. WASTE, 2) WITHIN 30 DAYS OF ORDER, REMOVE, TRANSPORT AND DISPOSE OF HAZ. WASTE DISCOVERED AT CORPUS CHRISTI FACILITY BY EPA, 3) WITHIN 30 DAYS OF THE ORDER, SUBMIT TO EPA AND TRNCC A PLAN DOCUMENTING THAT ALL HAZ. WASTE IN CONTAINERS WILL BE ACCUMULATED ON-SITE FOR 90-DAY OR LESS WITHOUT A PERMIT OR INTERIM STATUS AND THAT WASTE PLACED IN CONTAINERS COMPLIES WITH REGULATIONS, 4) WITHIN 30 DAYS OF THE ORDER, PROVIDE DOCUMENTATION TO EPA AND TRNCC THAT THE CORPUS CHRISTI FACILITY HAS DEVELOPED AND FOLLOWED A PLAN FOR INSPECTING ALL MONITORING EQUIPMENT, SAFETY AND EMERGENCY EQUIPMENT, SECURITY DEVICES, AND OP- ERATING AND STRUCTURAL EQUIPMENT,