1. SECTION 16 OF THE TOXIC SUBSTANCES CONTROL ACT, AS AMEND- ED ( TSCA ), 15 U.S.C. SECTION 2615. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928(A0, AND SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G). 2. HEMPEL COATINGS (USA) INC., A NEW YORK CORPORATION 6901 CAVALCADE STREET HOUSTON, HARRIS COUNTY, TEXAS 77028 3. RESPONDENT WAS IN VIOLATION OF SECTION 15(3)(B) OF TSCA BY (1) FAILURE TO SUBMIT 7 CHEMICAL SUBSTANCES TO BE IN- CLUDED IN THE 1994 INVENTORY UPDATE REPORT, SECTIONS 4, 15(1)(A) AND 15(B) OF TSCA BY (2) FAILURE TO SUBMIT A LETTER OF INTENT TO TEST OR AN EXEMPTION APPLICATION, SUBTITLE C OF RCRA BY (3) OPERATIMG A HAZARDOUS WASTE STORAGE UNIT (MAIN WASTE CONTAINER STORAGE AREA) WITHOUT A PERMIT OR INTERIM STATUS AS A RESULT OF FAILING TO MEET THE EXEMPTION REQUIREMEMTS, (4) OPERATING HAZARDOUS WASTE STORAGE UNITS (AREA NEAR THE PROPANE TANKS, AREA NEAR THE FENCE LINE WEST OF THE RAILROAD TRACKS, AND UNDER THE CANOPY BETWEEN THE MANUFACTURING AREA AND THE RAILROAD TRACKS) WITHOUT A PERMIT OR INTERIM STATUS AS A RESULT OF FAILING TO MEET THE EXEMPTION REQUIREMENTS, (5) OPERATING HAZARDOUS WASTE STORAGE UNITS (NORTH, SOUTH, AND MIDDLE MANUFACTURING SATELLITE ACCUMULATION AREAS) WITHOUT A PERMIT OR INTERIM STATUS AS A RES