1. SECTION 3008(A) OF THE RESOURCE CONSSRVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928(A), AS AMENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984, AND SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G). 2. GULF GRINDING CO., INC., A TEXAS CORPORATION, D.B.A. GULF PRECISION INDUSTRIES, AND GULF PRECISION, INC., A TEXAS CORPORATION 9420 KNIGHT ROAD HOUSTON, HARRIS COUNTY, TEXAS 77045 3. RESPONDENT WAS IN VIOLATION OF SECTION 3005(A) OF RCRA BY OPERATING A HAZARDOUS WASTE STORAGE UNIT WITHOUT INTERIM STATUS OR PERMIT, AND IN VIOLATION OF SECTION 301(A) OF THE CWA BY CONDUCTING THE RELEVANT ACTIVITIES AND OPERA- TING THE FACILITY WITHOUT NPDES COVERAGE AND BY FAILING TO DEVELOP AND IMPLEMENT A STORM WATER POLLUTION PREVENT- ION PLAN (SWPPP) FOR THE FACILITY AS REQUIRED. 4. RELIEF SOUGHT PURSUANT TO SECTIONS 3008(A) OF RCRA, EPA PROPOSED A CIVIL PENALTY OF $12,098 FOR THE RCRA VIOLA- TION CITED, AND PURSUANT TO SECTION 309(G) OF THE CWA, EPA PROPOSED A CIVIL PENALTY OF $27,500 FOR CWA VIOLATION CITED, FOR A PROPOSED TOTAL PNALTY OF $39,598. EPA ALSO ISSUED THE RESPONDENT A COMPLIANCE ORDER THAT REQUIRES THE RESPONDENT TO: A) IMMEDIATELY CEASE THE UNAUTHORIZED STORAGR OF HAZARDOUS WASTE IDENTI