1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928(A), AS AMENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984 (HSWA). 2. FIRESTONE SYNTHETIC RUBBER AND LATEX COMPANY, AN OHIO CORPORATION 5713 FM 1006 ORANGE, ORANGE COUNTY, TEXAS 77630 3. RESPONDENT WAS IN VIOLATION OF SECTION 3005(A) OF RCRA BY 1) FAILURE TO MAKE AN ADEQUATE HAZARDOUS WASTE DETERMINA- TION, 2) OPERATING A HAZARDOUS WASTE STORAGE UNIT WITHOUT INTERIM STATUS OR PERMIT BY FAILING TO MEET THE EXEMPTION REQUIREMENTS, AND 3) FAILURE TO PREPARE AN ADEQUATE MANI- FEST. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSED A CIVIL PENALTY OF $161,705 FOR THE VIOLATIONS CITED AND ISSUED A COMPLIANCE ORDER TO THE RESPONDENT. THE ORDER REQUIRED THE RESPONDENNT TO: 1) IMMEDIATELY CEASE THE UNAUTHORIZED STORAGE OF HAZ. WASTE, 2) WITHIN 30 DAYS, CONDUCT IN ACCORDANCE WITH ALL LAWS AND REGULA- TIONS, REMOVAL, TRANSPORTATION, STORAGE AND DISPOSAL OF THE HAZ. WASTE, 3) WITHIN 30 DAYS, SUBMIT TO EPA AND TRNCC A PLAN DOCUMENTING 1) THAT ALL HAZ. WASTE IN CON- TAINERS WILL BE ACCUMULATED ON-SITE FOR 90 DAYS OR LESS WITHOUT A PERMIT OR INTERIM STATUS AND 2) THAT THE WASTE PLACED IN CONTAINERS COMPLES WITH