1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 ( RCRA ), 42 U.S.C. SECTION 6928(A), AS A- MENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984. 2. ICO WORLDWIDE, INC., A TEXAS CORPOATION D/B/A/ ICO EXPLORATION SERVICES 9015 SHELDON ROAD HOUSTON, HARRIS COUNTY, TEXAS 77229 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE COF RCRA BY 1) FAILURE TO MEET THE EXEMPTION REQUIREMENTS FOR GENRATORS, AND 2) FAILURE TO MEET THE EXEMPTION REQUIREMENTS FOR SATELLITE ACCUMULATION AREAS. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSED A CIVIL PENALTY OF $23,703 FOR THE VIOLATIONS CITED. EPA ISSUED A COMPLIANCE ORDER TO THE RESPONDENT THAT REQUIRED THEM TO: A) UPON RECEIPT OF COMPLAINT, MEET AND DOCUMENT COMPLIANCE FOR ALL HAZARDOUS WASTE STORED AT THE FACILITY, B) UPON RECEIPT OF COMPLAINT, MEET AND DOCUMENT COMPLIANCE WITH ALL APPLICABLE RCRA REGULATIONS FOR ALL HAZARDOUS WASTES, INCLUDING BUT NOT LIMITED TO, SPENT SLUDGE ACCUMULATED AT THE FACILITY, AND C) DOCUMENT THE PROCEDURES USED IN DEVELOPING THE DETERMINATIONS FOR ACTIONS A AND B, AND PROVIDE THIS DOCUMENTATION TO EPA.