1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928(A). SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G). 2. JAMES W. HALL HALL PLATING COMPANY 2415 LIFEHAUS-INDUSTRIAL DRIVE NEW BRAUNFELS, COMAL COUNTY, TEXAS 78130 3. RESPONDENT WAS IN VIOLATION OF SECTION 3005(A) OF RCRA BY 1) FAILURE TO MEET THE EXEMPTION REQUIREMENTS OF 180 DAYS OR LESS HAZARDOUS WASTE GENERATOR REQUIREMENTS (CONTAINER STORAGE AREA - CSA); 2) STORAGE OF HAZARDOUS WASTE IN THE EQUIPMENT STORAGE AREA WITHOUT A PERMIT OR INTERIM STATUS AND 3) FAILURE TO MEET THE EXEMPTION REQUIREMENTS OF 180 DAYS OR LESS HAZARDOUS WASTE GENERATOR REQUIREMENTS (WASTEWATER TREATMENT AREA - WTA). THE RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY FAILING TO OB- TAIN A NPDES STORM WATER PERMIT OR A STORM WATER POLLU- TION PREVENTION PLAN (SWPPP). 4. RELIEF SOUGHT PURSUANT TO SECTIONS 3008(A) OF RCRA AND 309(G) OF THE CWA, EPA PROPOSED A CIVIL PENALTY OF $8,580 FOR THE RCRA VIOLATIONS AND $10,000 FOR THE CWA VIOLA- TIONS FOR A PROPOSED TOTAL OF $18,580. THE RESPONDENT WAS ISSUED A RCRA COMPLIANCE ORDER TO CORRECT THE VIOLATIONS. 5. TECHNICAL CONTACT: CWA - TAYLOR S