1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928(A) ST SEQ, AS AMEND- ED. 2. STUPP CORPORATION, A MISSOURI CORPORATION 12555 RONALDSON ROAD BATON ROUGE, EAST BATON ROUGE, LOUISIANA 70807 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) OPERATING A HAZARDOUS WASTE STORAGE UNIT WITHOUT A PERMIT OR INTERIM STATUS AS A RESULT OF FAILING TO MEET THE EX- EMPTION REQUIREMENTS, 2) OPERATING A HAZARDOUS WASTE STORAGE UNIT WITHOUT A PERMIT OR INTERIM STATUS AS A RE- SULT OF FAILING TO MEET THE EXEMPTION REQUIREMENTS, AND 3) FAILURE TO FILE AN EXCEPTION REPORT. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSED A CIVIL PENALTY OF $23,650 FOR THE VIOLATIONS CITED. EPA ISSUED THE RESPONDENT A COMPLIANCE ORDER THAT REQUIRES THE RESPONDENT TO: 1) UPON RECEIPT OF ORDER, KEEP ALL HAZ. WASTE STORAGE CONTAINERS CLOSED, EXCEPT WHEN IT IS NECESSARY TO ADD OR REMOVE WASTE, 2) UPON RE- CEIPT OF ORDER, MARK ALL HAZ. WASTE STORAGE CONTAINERS WITH THE ACCUMULATION START DATE, 3) UPON RECEIPT OF ORDER, PROVIDE SECONDARY CONTAINMENT SYSTEM FOR HAZ. WASTE STORAGE CONTAINERS, 4) UPON RECEIPT OF ORDER, DE- VELOP AND MAINTAIN AN ADEQUATE CONTINGENCY PLAN, 5) UPON RECEIPT OF ORDER, CLEARLY LABEL O