1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 ( RCRA ), 42 U.S.C. SECTION 6928(A), AS A- MENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984. SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G). 2. WILLIAM NEIL RENFROW RENFROW HARD CHROME PLATING COMPANY R.R. 6, BOX 170 LUBBOCK, LUBBOCK COUNTY, TEXAS 79412 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY (1) FAILURE TO MAKE A HAZARDOUS WASTE DETERMINATION, AND (2) FAILURE TO MEET THE EXEMPTION REQUIREMENTS OF 90 DAY OR LESS HAZARDOUS WASTE GENERATOR REQUIREMENTS; AND RESPOND- ENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY CON- DUCTING THE RELEVANT ACTVITIES AT THE FACILITY AND NOT BEING COVERED BY AN NPDES STORM WATER PERMIT OR A STORM WATER POLLUTION PREVENTION PLAN. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA AND 309(G) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $49,871 FOR THE RCRA VIOLATIONS CITED. AND $27,500 FOR THE CWA VIOLATIONS CITED. EPA ALSO ISSUED A RCRA COMPLI- ANCE ORDER. THE ORDER REQUIRES THE RESPONDENT TO: (A) WITHIN 60 DAYS, TAKE THE NECESSARY STEPS TO DEVELOP AND IMPLEMENT PROCEDURES THAT WILL EN