1. SECTION 7003(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6973. 2. CHIEF SUPPLY CORPORATION, A SUBSIDIARY OF CLEAN AMERICA CORPORATION, A DELAWARE CORPORATION. ROUTE 2 BOX 71 HASKELL, MUSKOGEE COUNTY, OKLAHOMA 74436 3. ON MAR. 26, 1997, AN EXPLOSION AND FIRE OCCURRED AT THE FACILITY. THE FIRE RESULTED IN THE DEATH OF ONE OF RE- SPONDENT'S EMPLOYEES, AND INJURIES TO TWO OTHER EMPLOY- EES. THE HANDLING, STORAGE, TREATMENT, OR TRANSPORTATION SOLID WASTE OR HAZARDOUS WASTE AT THE FACILITY MAY HAVE CREATED AN IMMINENT AND SUBSTANTIAL ENDANGERMENT TO HEALTH OR THE ENVIRONMENT. RESPONDENT HAS NOT MAINTAINED AND OPERATED THE FACILITY TO MINIMIZE THE POSSIBILITY OF A FIRE, EXPLOSION, OR ANY UNPLANNED SUDDEN OR NON-SUDDEN RELEASE OF HAZARDOUS WASTE OR HAZARDOUS WASTE CONSTITUENTS TO AIR, SOIL, OR SURFACE WATER WHICH COULD THREATEN HUMAN HEALTH OR THE ENVIRON- MENT. THERE IS OR HAS BEEN A RELEASE OF HAZARDOUS WASTES, HAZ- ARDOUS WASTE CONSTITUENTS, AND /OR SOLIDS INTO THE EN- VIRONMENT FROM THE FACILITY. RESPONDENT'S FAILURE TO MANAGE HAZARDOUS WASTE AND/OR SOLID WASTE AND OPERATE THE FACILITY TO MINIMIZE THE POS- SIBILTY OF A FIRE, AND THE SUBSEQ