DEFENDANT USED PCB OIL OTHER THAN IN A TOTALLY ENCLOSED MANNER, FAILED TO STORE PCB OIL IN A REQUIRED FACILITY AND REQUIRED CONTAINER AND FAILED TO MARK A PCB STORAGE AREA AND CONTAINER AS REQUIRED BY THE PCB REGULATIONS. DEFENDANT DID NOT PAY PENALTY ASSESSED IN ADMINISTRATIVE PROCEEDINGS IN ACCORDANCE WITH CONSENT AGREEMENT AND CONSENT ORDER ENTERED ON 05/05/87, AND HAS IGNORED NUMEROUS DEMAND LETTERS SENT BY REGION.