1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928(A). 2. HOECHST CELANESE CORPORATION, A DELAWARE CORPORATION 1901 CLARKWOOD ROAD CORPUS CHRISTI, NUECES COUNTY, TEXAS 78409 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) FAILING TO DETERMINE WHETHER THE SOLID WASTE IN THE NORTH CONTAINER STORAGE AREA WAS A HAZARDOUS WASTE, AND 2) OP- ERATING A HAZARDOUS WASTE STORAGE UNIT WITHOUT INTERIM STATUS OR PERMIT BY FAILING TO MEET THE EXEMPTION RE- QUIREMENTS. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSES A CIVIL PENALTY OF $10,250 AND ISSUED A COMPLI- ANCE ORDER TO THE RESPONDENT. THE ORDER REQUIRES THE RE- SPONDENT TO: 1) IMMEDIATELY CEASE THE UNAUTHORIZED STOR- AGE OF HAZ. WASTE IDENTIFIED IN THE COMPLAINT, 2) WITHIN 30 DAYS OF THE EFFECTIVE OF THE ORDER, REMOVE, TRANSPORT, AND DISPOSE OF THE HAZ. WASTE DISCOVERED DURING THE IN- SPECTION, 3) WITHIN 30 DAYS OF THE ORDER, SUBMIT TO EPA AND TRNCC A PLAN DOCUMENTING ALL HAZ. WASTE IN CONTAINERS WILL BE ACCUMULATED ON-SITE FOR 90-DAY OR LESS WITHOUT A PERMIT OR INTERIM STATUS AND THAT THE WASTE PLACED IN CONTAINERS COMPLIES WITH THE EXEMPTION REQUIREMENTS, AND 4) WITHIN 30 DAYS OF THE ORDER, HAVE ON-SITE A COPY OF ALL MANIFESTS, LAND DISPOSAL REST