1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928. 2. SHURE BROTHERS, INC., A TEXAS CORPORATION 21A ZANE GREY BLVD. EL PASO, EL PASO COUNTY, TEXAS 79906 3. RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) FAILURE TO PROVIDE LAND DISPOSAL RESTRICTION NOTIFICA- TIONS WITH RESTRICTED WASTE SHIPMENT, 2) FAILURE TO RE- TAIN LAND DISPOSAL RESTRICTION NOTIFICATION ON-SITE, AND 3) FAILURE TO COMPLETE LAND DISPOSAL NOTIFICATION. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSES A CIVIL PENALTY OF $40,097 AND ISSUED A COMPLI- ANCE ORDER TO THE RESPONDENT. THE ORDER REQUIRES THE RE- SPONDENT TO 1) NO LATER THAN 30 DAYS AFTER RECEIPT OF THE COMPLAINT, SUBMIT TO EPA A WRITTEN NOTIFICATION CERTIFY- ING THAT LAND DISPOSAL RESTRICTION NOTIFICATIONS FOR THE ZANE GREY FACILITY AND MEXICAN MAQUILADORA PLANT ARE BE- ING KEPT ON-SITE ST THE ZANE GREY FACILITY, 2) NO LATER THAN 30 DAYS AFTER RECEIPT OF THE COMPLAINT, SUBMIT TO EPA ANDTHE APPROPRIATE TREATMENT, STORAGE, AND DISPOSAL FACILITY A WRITTEN CORRECTION OF THE SUBJECT LAND DISPOS- AL RESTRICTION NOTIFICATIONS, 3) NO LATER THAN 30 DAYS AFTER RECEIPT OF THE COMPLAINT, SUBMIT TO EPA, FOR REVIEW AND COMMENT, THE PROCEDURES RESPONDENT SHALL IMPLEMENT TO ENSURE THAT ALL SUBSEQUENT LAND D