'1. SECTION 3008(H) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ). 2. GNB TECHNOLOGIES, INC. 1880 VALLEY VIEW LANE FARMERS BRANCH, DALLAS COUNTY, TEXAS 75234-8905 3. EPA IDENTIFIED ELEVATED LEVELS OF LEAD, ARSENIC, CHEOMIUM AND NICKEL CONTAMINATION IN COMPOSITE SOIL/SEDIMENT SAM- PLES COLLECTED FROM TWO SAMPLING LOCATIONS IN AN ON-SITE DRAINAGE DITCH; RESULTING FROM HISTORIC OPERATION OF GNB, INC. THE ELEVATED LEVELS OF METALS IN THE SOIL CONSTITUTE A RELEASE OF HAZARDOUS CONSTITUENTS TO THE ENVIRONMENT. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(H) OF RCRA, EPA REQUESTED THE RESPONDENT AGREE TO UNDERTAKE REMEDIATION OF THE CONTAMINATED AREA TO MEET INDUSTRIAL LEVELS.'