STATUTES AND REGULATIONS WHICH ARE THE BASIS FOR THE PRO- POSED ACTION: THIS SUIT SHOULD BE INSTITUTED PURSUANT TO SECT 3008(A) OF RCRA WHICH PROVIDES THAT EPA AFTER GIVING NOTICE TO A STATE AUTHORIZED TO CARRY OUT A HAZARDOUS WASTE PROGRAM, MAY INSTITUTE A CIVIL ACTION WHEN ANY REQUIREMENT OF SUBTITLE C OF RCRA IS VIOLATED. THE STATE OF LA, FORMERLY THROUGH THE LA DNR AND CURRENTLY THROUGH THE LDEQ, HAS RECEIVED FINAL AUTHORIZATION BY EPA TO ADMINISTER THE FEDERAL HAZ- ARDOUS WASTE PROGRAM IN LA. THIS PROGRAM OPERATES IN LIEU OF THE EPA PROGRAM IN LA PURSUANT TO SECT 3006(B) OF RCRA. THEREFORE, EPA WILL BE ENFORCING THE STATE HAZARDOUS WASTES LAWS AGAINST THE DEFENDANTS. THUS, VIOLATIONS OF THE LHWMP AND ITS SUCCESSOR, THE LA HAZARDOUS WASTE REGULATIONS, ARE THE BASIS FOR THE PROPOSED ACTION. NOTICE TO THE STATE OF LA WILL BE PROVIDED PRIOR TO THE COMMENCEMENT OF THE SUIT. * VIOLATIONS UPON WHICH THE ACTION IS BASED: 1. FAILURE TO OBTAIN AND ANALYZE A REPRESENTATIVE SAMPLE OF SOLIDIFIED WASTES PRIOR TO PLACING THE SOLIDIFIED WASTES INTO A LANDFILL. 2. FAILURE TO DEVELOP AN ADEQUATE WASTE ANALYSIS PLAN DUE TO A FAILURE TO INCLUDE THE TEL MONOFILL OPERATIONS IN THE WASTE ANALYSIS PLAN. 3. FAILURE TO PREPARE PRE-ACCEPTANC