1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SEC. 6901 ET SEQ., AS AMENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984. 2. DANA CORPORATION BOSTON WEATHERHEAD DIVISION 1100 NORTH DANA AVENUE VINITA, OKLAHOMA FACILITY ID NO. OKD980877856 3. RESPONDENT IS CHARGED WITH VIOLATIONS OF RCRA SUBTITLE C INCLUDING VIOLATIONS RELATING TO IMPROPER USE AND MANAGE- MENT OF TANKS AND CONTAINERS OF HAZARDOUS WASTE (FAILURE TO ASSESS TANKS, FAILURE TO LABLE AND MARK ACCUMULATION DATES ON TANKS AND CONTAINERS, CONTINUED PLACEMENT OF HAZARDOUS WASTE IN TANKS WHICH COULD CAUSE THE TANKS TO LEAK OR FAIL), FAILURE TO COMPLY WITH PREPAREDNESS AND PREVENTION PROVISIONS, AND FAILURE TO COMPLY WITH CON- TINGENCY AND EMERGENCY PROCEDURES PROVISIONS. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA IS SEEKING INJUNCTIVE RELIEF TO CORRECT THE VIOLATIONS AS WELL AS A PENALTY IN THE AMOUNT OF $576,640.00.