1. SECTION 3008(H) OF THE RESOURCE CONSERVATION AND RECOVERY ACT, AS AMENDED ( RCRA ), 42 U.S.C. SECTION 6928(H). 2. OKLAHOMA ENERGY CORPORATION, A CALIFORNIA CORPORATION JOHN A. RAYLL, JR., AN INDIVIDUAL CYRIL PETROCHEMICAL CORPORATION, A CALIFORNIA CORPORATION 100 EAST MAIN STREET (U.S. 277 AND STATE HIGHWAY 8 INTER- SECTION) 3. RESPONDENT WAS IN VIOLATION 0F SECTION 3005(E) OF RCRA BY FAILING TO HAVE A PERMIT OR INTERIM STATUS TO STORE HAZ- ARDOUS WASTES D004 IN TANKS AND CONTAINERS, F037 IN IM- POUNDMENTS AND TANKS, AND TREAT AND STORE HAZARDOUS WASTE K052 IN TANKS. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(H) OF RCRA, EPA ISSUED THE RESPONDENT AN INITIAL ADMINISTRATIVE ORDER (AO). THE PURPOSE OF THE AO IS TO REQUIRE THE RESPONDENT TO: 1) IDENTIFY, INVESTIGATE, AND REMEDIATE THE RELEASES OF HAZARDOUS WASTES AND/OR HAZARDOUS WASTE CONSTITUENTS TO THE ENVIRONMENT; 2) PERFORM INTERIM MEASURES (IM) SE- LECTED OR APPROVED BY EPA AT THE FACILITY TO MITIGATE PO- TENTIAL THREATS TO HUMAN HEALTH OR THE ENVIRONMENT; 3) DETERMINE FULLY THE NATURE AND EXTENT OF ANY RELEASE(S) OF HAZARDOUS WASTE OR CONSTITUENTS AT OR FROM THE FACILI- TY; 4) PERFORM A CORRECTIVE MEASURE STUDY (CMS) TO IDEN- TIFY AND EVALUATE ALTERNATIVES FOR CORRECTIVE ACTION(S) TO PREVENT OR MITIGATE ANY MIGRAT