MOBIL OIL CORPORATION (MOBIL) IS INCORPORATED IN AND UNDER THE LAWS OF THE STATE OF NEW YORK AND IS AUTHORIZED TO DO BUSINESS IN THE STATE OF LOUISIANA. RESPONDENT MAY BE SERVED WITH LEGAL PROCESS BY SERVING ITS REGISTERED AGENT, VICTOR A. SACHSE, III, AT 1 AMERICAN PLACE ,23RD FLOOR, BATON ROUGE, LA. RESPONDENT IS A PERSON AS DEFINED IN THE LOUISIANA ADMIN- ISTRATIVE CODE ( LAC ) AT 33:V.109, IN SECTION 1004(15) OF RCRA, 42 U.S.C. SEC. 6903(15) AND IN 40 C.F.R. SEC. 260.10. RESPONDENT OWNS AND OPERATES AN INTEGRATED PETROLEUM REFIN- ERY LOCATED AT 500 WEST ST. BERNARD HIGHWAY, CHALMETTE, LA., WHERE IT PRODUCES A WIDE RANGE OF PRODUCTS ( THE PLANT ). MOBIL PURCHASED THE PLANT FROM TENNECO OIL COMPANY (TENNECO) IN 1988. THE PLANT IS A FACILITY AS THAT TERM IS DEFINED AT 40 C.F. R.SEC. 260.10. THE PLANT IS AN EXISTING HAZARDOUS WASTE MANAGEMENT FACIL-I TY AS DEFINED AT 40 C.F.R. SEC. 260.10. COMPLAINT CONTAINS SIX COUNTS OF VIOLATIONS: COUNT 1 - FAILURE TO POST WARNING SIGNS AT THE HEAT EXCHANG- ER BUNDLE CLEANING AREA. COUNT 2 - FAILURE TO REVISE THE WASTE ANALYSIS PLAN. COUNT 3 - FAILURE TO MARK DRUMS CONTAINING HAZARDOUS WASTE WITH ACCUMULATION DATE. COUNT 4 - FAILURE TO LABEL A DRUM CO