1. SECTION 9006 OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6912 ET SEQ. 2. WEST MEMPHIS UTILITY PLANT 604 E. COOPER WEST MEMPHIS, CRITTENDEN COUNTY, ARKANSAS 72301 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE I OF RCRA BY 1) FAILURE TO CONDUCT ADEQUATE RELEASE DETECTION FOR TANKS, AND 2) FAILURE TO CONDUCT TIGHTNESS TEST ON SUCTION LINE (FOR LINED TANK). 4. RELIEF SOUGHT PURSUANT TO SECTION 9006 OF RCRA, EPA ASSESSED THE RESPONDENT A CIVIL PENALTY OF $600 FOR THE VIOLATIONS CITED.