1. SECTION 3008 OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928, AS AMENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984 ( HSWA . 2. BROWN & JORDAN COMPANY, A TEXAS CORPORATION 8600 GATEWAY EAST, DOOR 13 EL PASO, EL PASO COUNTY, TEXAS 79907 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) FAILURE TO IDENTIFY THE IMPORTER OF RECORD NAME AND AD- DRESS ON MANIFEST, 2) FAILURE TO RETAIN COPIES OF MANI- FEST ON-SITE, AND 3) FAILURE TO MAKE A HAZARDOUS WASTE DETERMINATION. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008 OF RCRA, EPA PRO- POSED A CIVIL PENALTY OF $13,198 FOR THE VIOLATIONS CITED. EPA ALSO ISSUED THE RESPONDENT A COMPLIANCE ORDER THAT REQUIRED THE RESPONDENT TO: A) WITHIN 60 DAYS, SUB- MIT TO EPA A WRITTEN CORRECTION OF UHWMS LISTED IN THE COMPLAINT TO INCLUDE THE CORRECT IMPORTER OF RECORD'S NAME, ADDRESS AND CORRESPONDING EPA ID NUMBER; B) WITHIN 60 DAYS, PROVIDE DOCUMENTATION OF ACTIONS AND/OR STEPS TAKEN TO PREVENT RECURRENCE OF HAZARDOUS WASTE BEING SHIPPED WITHOUT MAKING A PROPER HAZARDOUS WASTE DETER- MINATION; AND C) WITHIN 60 DAYS, CERTIFY THAT MANIFESTS ATE BEING KEPT ON-SITE AT THE DESIGNATED IMPORTER OF RE- CORD FACILITY.