1. SECTION 3008 OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 ( RCRA ), 42 U.S.C. SECTION 6928, AS AMENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984. 2. VALLEY SOLVENTS & COMPANY, INC. D.B.A. VALLEY SOLVENTS & CHEMICALS, A TEXAS CORPORATION 8215 UPRIVER ROAD CORPUS CHRISTI, NUECES COUNTY, TEXAS 78535 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY (1) FAILURE TO MEET THE EXEMPTIONS FOR TRANSFER FACILITY, AND (2) FAILURE TO MAKE A HAZARDOUS WASTE DETERMINATION FOR GENERATORS. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008 OF RCRA, EPA PRO- POSED A CIVIL PENALTY OF $13,500 FOR THE VIOLATIONS CITED AND ISSUED THE RESPONDENT A COMPLIANCE ORDER. THE ORDER REQUIRES THE RESPONDENT TO: (A) WITHIN 60 DAYS, PROVIDE TO EPA AN AMENDED CONTINGENCY PLAN WHICH LISTS THE FACI- LITY'S CURRENT EMERGENCY COORDINATORS, (B) WITHIN 60 DAYS SUBIT TO EPA A CERTIFICATION THAT COPIES OF THE AMENDED CONTINGENCY PLAN HAVE BEEN PROVIDED TO LOCAL AUTHORITIES, (C) WITHIN 60 DAYS, SUBMIT TO EPA A COPY OF THE FACILI- TY'S WRITTEN INSPECTIONS PROCEDURE, WHICH INCLUDE A DES- CRIPTION OF TYPES, SCHEDULE, A COPY OF INSPECTION FORMS, AND RECORDS MAINTENANCE, IN ACCORDANCE, (D) WITHIN 60 DAYS, SUBMIT TO EPA A COPY OF THE FACILITY'S WRITTEN PER- SONNEL TRAINING PROGRAM, WHICH SH