1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928(A) ET SEQ. 2. NICOLAUS PAPER, INC., A DELAWARE CORPORATION 139 JOE BROWN ROAD LOCKPORT, LAFOURCHE PARISH, LOUISIANA 70374 3. RESPONDENT WAS IN VIOLATION OF SECTION 3005(A) OF RCRA BY 1) OPERATING A HAZARDOUS WASTE STORAGE UNIT, THE NORTH DRUM STORAGE AREA, WITHOUT A PERMIT OR INTERIM STATUS, AND 2) FAILING TO LABEL USED OI CONTAINERS. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSES A CIVIL PENALTY OF $9,800 FOR THE VIOLATIONS CITED. EPA SLSO ISSUED A COMPLIANCE ORDER REQUIRING THE RESPONDENT TO: 1) UPON RECEIPT OF THE COMPLAINT, ENSURE COMPLIANCE TO KEEP ALL HAZ. WASTE STORAGE DRUMS CLOSED, EXCEPT WHEN ADDING OR REMOVING WASTE, 2) UPON RECEIPT OF COMPLAINT, ENSURE ITS COMPLIANCE TO MAINTAIN HAZ. WASTE STORAGE DRUMS IN GOOD CONDITION, INCLUDING ENSURING THE INTEGRITY OF THE INNER LINER OF DRUMS IS MAINTAINED, 3) UPON RECEIPT OF COMPLAINT, ENSURE ITS COMPLIANCE TO IN- SPECT THE HAZ. WASTE STORAGE CONTAINERS WEEKLY, 4) UPON RECEIPT OF COMPLAINT, ENSURE ITS COMPLIANCE TO PROVIDE SECONDARY CONTAINMENT SYSTEM FOR HAZ. WASTE STORAGE DRUMS, 5) UPON RECEIPT OF COMPLAINT, ENSURE ITS COMPLI- ANCE TO LABEL OR MARK ALL HAZ. WASTE STORAGE DRUMS WITH HAZARDOUS WASTE , 6) UPON RECEIP