1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928, AS AMENDED BY THE HAZARDOUS WASTE AND SOLID WASTE AMENDMENTS OF 1984 (HSWA) 2. BAROID DRILLING, INC., A LOUISIANA CORPORATION 8000 JOURDAN ROAD NEW ORLEANS, ORLEANS PARISH, LOUISIANA 70126 3. RESPONDENT WAS IN VIOLAION OF SUBTITLE C OF RCRA BY: I) FAILURE TO MAKE A HAZARDOUS WASTE DETERMINATION BY NOT DETERMINING THAT THE CONTAINERS CONTAINED HAZARDOUS WASTE; AND II) FAILURE TO MEET EXEMPTION REQUIREMENTS BY STORING HAZARDOUS WASTE WITHOUT A PERMIT OR INTERIM STAT- US. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSED A CIVIL PENALTY OF $62,260 FOR THE VIOLATIONS CITED AND ISSUED THE RESPONDENT A COMPLIANCE ORDER TO CORRECT THE VIOLATIONS.