THIS REFERRAL RECOMMENDS THE FILING OF THE HAZARDOUS WASTE PERMIT, WASTE ANALYSIS, AND IGNITABLE WASTE HANDLING REQUIREMENTS UNDER THE RESOURCE CONSERVATION AND RECOVERY ACT, AS AMENDED, ( RCRA ), 42 U.S.C. PARA 6901 ET SEQ. AND FOR VIOLATIONS OF THE REPORTING REQUIRMENTS OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT ( CERCLA ) SECTION 103, 42 U.S.C. PARA 9603. THE VIOLATION OCCURRED DURING A PERIOD FROM JANUARY 28, 1992 TO MAY 19, 1992, DURING WHICH TIME APC ILLEGALLY STORED AND DISPOSED OF HAZARDOUS WASTE AT ITS FACILITY IN RILLITO, ARIZONA. BETWEEN JANUARY 28, 1992 AND MAY 8, 1992, APC RECEIVED AND STORED ON-SITE 844.84 TONS OF SPENT CATALYST FROM HESS OIL VIRGIN ISLAND CORPORATION ( HOVIC ). THE SPENT CATAYST WAS A CHARACTERISTICALLY HAZARDOUS WASTE, EXHIBITING THE CHARACTERISTICS OF IGNITABILITY (D001) AND TOXICITY BASED ON THE PRESENCE OF BENZENE (D018). APC DID NOT HAVE A RCRA PERMIT OR INTERIM STATUS AUTHORIZING IT TO TREAT, STORE OR DISPOSE OF HAZARDOUS WASTE. APC STORE ALL BUT 126 TONS OF THE HAZARDOUS WASTE DIRECTLY ON THE GROUND; APC'S PLACEMENT OF THE HAZARDOUS WASTE DIRECTLY ON THE GROUND CONSTITUTED UNLAWFUL DISPOSAL OF HAZARDOUS WASTE UNDER RCRA. REGION IX IS RECOMMENDING THAT APC AND ITS PARENT, CPC, BE CHARGED WITH OPERATING A TREATMENT, STORAGE OR DISPOSAL FACILITY WITHOUT A PERMIT, A COUNT FOR FAILURE TO COMPLY WITH T