1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928(A), AS AMENDED BY THE HAZARDOUS WASTE AND SOLID WASTE AMENDMENTS OF 1984. 2. GEORGIA GULF LAKES CHARLES, LLC, A DELAWARE CORPORATION 1600 VCM PLANT ROAD WESTLAKE, CALCASIEU PARISH, LOUISIANA 70669 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY: I) DISPOSAL OF HAZARDOUS WASTE WITHOUT A PERMIT; II) FAILURE TO MAKE AN ADEQUATE WASTE DETERMINATION (F024 COKE FINES WITH WASTEWATER); III) OPERATING A HAZARDOUS WASTE STOR- AGE UNIT -THE LUGGER - WITHOUT A PERMIT AS A RESULT OF FAILING TO MEET THE EXEMPTION REQUIREMENTS; IV) OPERATING A HAZARDOUS WASTE STORAGE UNIT - STEAM STRIPPER C-717A ASSOCIATED STORAGE TANK T-550, T-110 AND T-551 - WITHOUT A PERMIT AS A RESULT OF FAILING TO MEET THE EXEMPTION RE- QUIREMENTS; AND V) OPERATING A HAZARDOUS WASTE STORAGE UNIT - FRAC TANK - WITHOUT A PERMIT AS A RESULT OF FAIL- ING TO MEET THE EXEMPTION REQUIREMENTS. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSED A CIVIL PENALTY OF $701,605 FOR THE VIOLATIONS CITED AND ISSUED THE RESPONDENT A COMPLIANCE ORDER TO CORRECT THE VIOLATIONS.