1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928(A) ET SEQ., AS A- MENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984 (HSWA). 2. BERRY BROTHERS GENERAL CONTRACTORS, INC., A LOUISIANA CORPORATION 1414 RIVER ROAD BERWICK, SAINT MARY PARISH, LOUISIANA 70342 3. RESPONDENTS WERE IN VIOLATION OF SUBTITLE C OF RCRA BY: (1) FAILURE TO NOTIFY OF HAZARDOUS WASTE ACTIVITY, (2) FAILURE TO MAKE A HAZARDOUS WASTE DETERMINATION, AND (3) FAILURE TO MEET PERMIT EXEMPTION REQUIREMENTS. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSED A CIVIL PENALTY OF $105,160 FOR THE VIOLATIONS CITED AND ISSUED A COMPLIANCE ORDER TO THE RESPONDENTS. THE ORDER REQUIRES THE RESPONDENTS TO: (A) TAKE THE NE- CESSARY STEPS TO ENSURE THAT EACH CONTAINER OF HAZ. WASTE IS LABELED HAZARDOUS WASTE , HAS THE DATE OF EACH PERIOD OF ACCUMULATION, AND VISIBLE FOR INSPECTION, (B) BEGIN CONDUCTING WEEKLY INSPECTIONS AND DOCUMENTATION OF EACH CONTAINER STORAGE AREA, (C) TAKE THE NECESSARY STEPS TO ESTABLISH AND MAINTAIN SECONDARY CONTAINMENT SYSTEM FOR ITS HAZ. WASTE CONTAINER STORAGE AREA(S), (D) TAKE THE NECESSARY STEPS TO MAKE ARRANGEMENTS WITH LOCAL AUTHOR- ITIES, (E) TAKE THE NECESSARY STE