THIS IS AN ADMINISTRATIVE ORDER ON CONSENT (CONSENT ORDER) WHICH WILL BE ISSUED UNDER SECTION 3008(h) OF RCRA. UNDER THE TERMS OF THE CONSENT ORDER, THE LYONDELL ENVIRONMENTAL CUSTODIAL TRUST (TRUST) HAS AGREED TO CONDUCT INTERIM MEASURES AS MAY BE NECESSARY, A RCRA FACILITY INVESTIGATION AND A CORRECTIVE MEASURE STUDY AT THE ST. HELENA FACILITY (FACILITY). THE TRUST IS THE RESPONDENT IN THIS CONSENT ORDER BECAUSE THE FACILITY'S PRIOR OWNER, MILLENNIUM HOLDINGS, LLC (MILLENNIUM), HAD PROCEEDED THROUGH A CHAPTER 11 BANKRUPTCY REORGANIZATION AND TRANSFERRED THE FACILITY TO THE TRUST. DURING INDUSTRIAL OPERATIONS FROM 1914 UNTIL 2007, MILLENNIUM AND ITS PREDECESSORS MANUFACTURED PIGMENTS AND SILICA GEL AT THE FACILITY.