1. SECTION 3008 OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 ( RCRA ), 42 U.S.C. SEC. 6928 ET SEQ.; SEC- TION 109 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT ( CERCLA ), 42 U.S.C. SEC. 9609, AS AMENDED; AND SECTION 325(C) OF THE EMERGEN- CY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT ( EPCRA ), 42 U.S.C. SEC. 11001 ET SEQ. 2. SHELL OIL COMPANY DEER PARK MANUFACTURING COMPLEX STATE HIGHWAY 225 DEER PARK, TEXAS 77536 REGISTERED AGENT FOR SERVICE : C.T. CORPORATION SYSTEM 1601 ELM STREET, SUITE 3700 DALLAS, TEXAS 75201 3. THE COMPLAINT ALLEGES THAT SHELL OIL COMPANY, AT ITS DEER PARK MAUNFACTURING COMPLEX, VIOLATED SUBTITLE C OF RCRA AND THE REGULATIONS PROMULGATED UNDER THE TAC, SECTION SECTION 103(A) OF CERCLA, AND SECTION 313(A) OF EPCRA. THE VIOLATIONS UNDER RCRA ARE: (1) FAILURE TO MAINTAIN ADEQUATE AISLE SPACE IN CONTAINER STORAGE AREA, (2) FAIL- URE TO MAINTAIN CONTAINER STORING HAZARDOUS WASTE IN GOOD CONDITION, (3) FAILURE TO PROVIDE ADEQUATE SECONDARY CON- TAINMENT FOR HAZARDOUS WASTE STORAGE TANKS, AND (4) FAIL- URE TO SUBMIT PROPERLY COMPLETED