1. SECTIONS 104, 106, AND 122 OF THE COMPREHENSIVE ENVIRON- MENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT ( CERCLA ), 42 U.S.C. SECTIONS 9604, 9606, AND 9622. 2. BROWNSVILLE DRUMS SUPERFUND SITE 1985 NORTH CENTRAL AVENUE BROWNSVILLE, CAMERON COUNTY, TEXAS 78520 3. THE SITE CONTAINS APPROXIMATELY 199 DRUMS, SEVERAL FIVE- GALLON CONTAINERS AND NUMEROUS SMALLER CONTAINERS. THERE ARE HAZRDOUS SUBSTANCES IN THOSE DRUMS AND OTHER CONTAIN- ERS THAT ARE BEING RELEASED AND/OR POSED A POTENTIAL THREAT FOR FUTURE RELEASES. ACTUAL OR THREATENED RELEASES OF HAZARDOUS SUBSTANCES, POLLUTANTS OR CONTAMINANTS FROM THIS SITE, IF NOT ADDRESSED BY IMPLEMENTING A WORK PLAN, MAY PRESENT AN IMMINENT AND SUBSTANTIAL ENDANGERMENT TO THE PUBLIC HEALTH, WELFARE, AND/OR ENVIRONMENT. THE U.S. HAS INCURRED RESPONSE COSTS IN RESPONDING TO THE RELEASE OR THREAT OF RELEASE OF HAZARDOUS SUBSTANCES FROM THE SITE. 4. RELIEF SOUGHT PURSUANT TO SECTIONS 104, 106, AND 122 OF CERCLA, THE EPA AND THE RESPONDENT, DENOVA ENVIRONMENTAL, INC. ENTERED INTO AN ADMINISTRATIVE ORDER ON CONSENT (AOC). THE AOC REQUIRES THE RESPONDENT TO SUBMIT A WORK PLAN, WITHIN 15 DAYS, THAT DETAILS THE RESPONSE ACTIONS TO BE TAKEN BY THE RESPONDENT TO ELIMINATE THE RELEASES AND THREAT OF RELEASES OF HAZARDO