1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6901 ET SEQ. 2. OCEAN TECHNICAL SERVICES, INC. 1140 PETERS ROAD HARVEY, JEFFERSON COUNTY, LOUISIANA 70058 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) STORAGE OF HAZARDOUS WASTE (IN CONTAINERS) WITHOUT A PER- MIT, 2) STORAGE OF HAZARDOUS WASTE (AT SATELLITE ACCUMU- LATION POINTS) WITHOUT A PERMIT, AND 3) FAILURE TO DEVE- LOP AND MAINTAIN A SPILL PREVENTION CONTROL AND COUNTER- MEASURES PLAN (SPCC). 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSED A CIVIL PENALTY OF $8,600 FOR THE VIOLATIONS CITED AND ISSUED A COMPLIANCE ORDER TO THE RESPONDENT. THE ORDER REQUIRES THE RESPONDENT TO IMMEDIATELY: 1) LA- BEL ALL HAZARDOUS WASTE STORAGE CONTAINERS WITH HAZARD- OUS WASTE , 2) MARK ALL HAZARDOUS WASTE STORAGE CONTAIN- ERS STORED IN THE CONTAINER STORAGE AREA WITH THE ACCUMU- LATION START DATE, 3) KEEP ALL CONTAINERS CLOSED EXCEPT WHEN ADDING OR REMOVING WASTE, 4) PROVIDE SECONDARY CON- TAINMENT FOR THE CONTAINER STORAGE AREA, 5) OPERATE IN A MANNER THAT WILL PREVENT RELEASE OF HAZ. WASTE TO THE EN- VIRONMENT, 6) PROVIDE AND MAINTAIN EMERGENCY SPILL AND FIRE FIGHTING EQUIPMENT AT THE CONTAINER STORAGE AREA, 7) BEGIN A PROGRAM TO ENSURE THAT AL