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. ZENECA AGRICULTURAL PRODUCTS, A SOLE PARTNERSHIP 5757 UNDERWOOD ROAD PASADENA, HARRIS COUNTY, TEXAS 77507 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) FAILURE TO MAKE A HAZARDOUS WASTE DETERMINATION; 2) FAIL- URE TO STORE HAZARDOUS WASTE WITHOUT A PERMIT OR INTERIM STATUS AND MEET THE EXEMPTION REQUIREMENTS OF 180-DAY OR LESS HAZARDOUS WASTE GENERATOR REQUIREMENTS (MAINTENANCE SHOP AND COVERED SHED CONTAINER STORAGE AREAS; AND 3) FAILURE TO STORE HAZARDOUS WASTE WITHOUT A PERMIT OR IN- TERIM STATUS AND MEET THE EXEMPTION REQUIREMENTS OF 180 DAY OR LESS HAZARDOUS WASTE GENERATOR REQUIREMENTS (CON- TAINER STORAGE AREAS). 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSED A CIVIL PENALTY OF $39,380 FOR THE VIOLATIONS CITED AND ISSUED THE RESPONDENT A COMPLIANCE ORDER TO CORRECT THE VIOLATIONS.