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. 2. ICO WORLDWIDE, INC. D/B/A/ ICO TUBULAR ,A TEXAS CORP. 401 SARATOGA ROAD CORPUS CHRISTI, NUECES COUNTY, TEXAS 78415 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) FAILURE TO MAKE A HAZARDOUS WASTE DETERMINATION, 2) FAIL- URE TO MEET THE EXEMPTION REQUIREMENTS FOR GENERATORS, AND 3) DISPOSAL WITHOUT A PERMIT OR INTERIM STATUS. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSED A CIVIL PENALTY OF $49,499 FOR THE VIOLATIONS CITED. EPA ISSUED A COMPLIANCE ORDER REQUIRING THE RE- SPONDENT TO: A) WITHIN 30 DAYS, MEET AND COMPLY WITH 40 CFR SECTION 262.11 FOR ALL WASTE AT THE FACILITY, AND ANY WASTES DETERMINED TO BE HAZARDOUS MUST BE MANAGED ACCORD- ING TO RCRA REGULATIONS, B) WITHIN 30 DAYS, MEET AND COM- PLY WITH 40 CFR 262.20 FOR ANY HAZARDOUS WASTES, WHICH THE FACILITY SENDS FOR DISPOSAL, C) WITHIN 30 DAYS, MEET AND DOCUMENT COMPLIANCE WITH 40 CFR 262.34 FOR ALL HAZ- ARDOUS WASTE STORED AT THE FACILITY, AND D) WITHIN 30 DAYS, MEET AND DOCUMENT COMPLIANCE WITH ALL APPLICABLE REGULATIONS FOR ALL HAZARDOUS WASTES, INCLUDING BUT NOT LIMITED TO CONTINGENCY PLAN, CONT