1. SECTION 311(B)(6)(B)(I) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1321(B)(6)(B)(I), AS AMENDED BY THE OIL POLLUTION ACT OF 1990. 2. PHILIP SERVICES CORPORATION FACILITY: 2131 PROGRESSIVE DRIVE DALLAS, DALLAS COUNTY, TEXAS 75212 3. RESPONDENT WAS IN VIOLATION OF SECTION 311 OF THE CWA BY (1) SPCC PLAN NOT CERTIFIED BY A PROFESSIONAL ENGINEER; (2) NO EVIDENCE OF THREE YEAR REVIEW OF SPCC PLAN BY OWN- ER/OPERATOR; AND (3) NO DESIGNATED PERSON FOR SPILL PRE- VENTION. 4. RELIEF SOUGHT PURSUANT TO SECTION 311(B)(6)(B)(I) OF THE CWA, EPA ASSESSED A CIVIL PENALTY OF $400 FOR THE VIOLA- TION CITED.