1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 ( RCRA ), 42 U.S.C. SECTION 6928. 2. J.R.D. BRASS COMPANY 1498 NORTH BOLTON ROAD JACKSONVILLE, CHEROKEE COUNTY, TEXAS 75766 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) ACCUMULATION OF A HAZARDOUS WASTE FOR MORE THAN 90 DAYS WITHOUT HAVING APPLIED FOR A RCRA PERMIT OR HAVING INTER- IM STATUS, 2) FAILING TO LABEL CONTAINERS HOLDING HAZARD- OUS WASTE (USED FILTERS FROM THE CYANIDE PROCESS LINE), 3) FAILING TO LABEL CONTAINER HOLDING HAZARDOUS WASTE (RED DRUMS ACCUMULATING METHYLENE CHLORIDE STRIPPINGS FROM CLEANING OPERATIONS), 4) THE ACCUMULATION OF CON- TAINERS WITH HAZARDOUS WASTE (USED FILTERS FROM THE CYA- NIDE PROCESS LINE) NOT BEING CLOSED DURING STORAGE,AND 5) FAILING TO TRANSFER HAZARDOUS WASTE (METHYLENE CHLORIDE STRIPPINGS FROM CLEANING OPERATIONS) IN CONTAINERS IN POOR CONDITION TO CONTAINERS IN GOOD CONDITIONS. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA ISSUED A COMPLIANCE ORDER AND PROPOSED A CUVIL PENALTY OF $46,150. THE COMPLIANCE ORDER REQUIRES THE RESPONDENT TO VERIFY EACH CONTAINER IS PROPERLY LABELED, APPLY FOR A PERMIT FOR CONTAINERS HOLDING WASTE STORED MORE THAN 90 DAYS, ENSURE CONTAINERS HOLDING WASTE ARE CLOSED, ENSURE THAT WASTE IN CONTAINERS IN POOR