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 (HSWA). 2. STANDARD ALLOYS AND MANUFACTURING, A DELAWARE CORPORATION KCS AND 4TH STREETS PORT ARTHUR, JEFFERSON COUNTY, TEXAS 77640 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) FAILURE TO MEET THE EXEMPTION REQUIREMENTS OF ONE HUNDRED AND EIGHTY DAYS OR LESS HAZARDOUS WASTE GENERATOR RE- QUIREMENTS, 2) FAILURE TO MEET THE EXEMPTION REQUIREMENTS OF ONE HUNDRED AND EIGHTY DAYS OR LESS HAZARDOUS WASTE GENERATOR REQUIREMENTS, 3) FAILURE TO MAKE A HAZARDOUS WASTE DETERMINATION, AND 4) FAILURE TO SUBMIT ANNUAL SUM- MARIES TO THE TRNCC. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSED A CIVIL PENALTY OF $60,000 FOR THE VIOLATIONS CITED. EPA ALSO ISSUED A COMPLIANCE ORDER TO THE RESPOND- ENT REQUIRING THE RESPONDENT TO: A) WITHIN 60 DAYS, PRO- VIDE TO EPA DOCUMENTATION WHICH CERTIFIES THAT ALL HAZ- ARDOUS WASTE ACCUMULATION AREAS AT THE PLANT ARE BEING OPERATED IN COMPLIANCE, AND B) WITHIN 60 DAYS, SUBMIT TO EPA A NOTIFICATION OF HAZARDOUS WASTE MANAGEMENT ACTIVITY WHICH SHOULD DESCRIBE ALL REGULATED WASTES GENERATED BY THE PLANT.