1. SECTION 113 OF THE CLEAN AIR ACT ( CAA ), 42 U.S.C. SEC- TION 7413. SECTION 3008 OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ). 2. SHELL DEER PARK REFINING COMPANY, A DIVISION OF SHELL OIL PRODUCTS COMPANY 5700 HIGHWAY 225 SHELL DEER, HARRIS COUNTY, TEXAS 77536 3. RESPONDENT WAS IN VIOLATIONS OF SECTIONS 112, 173, AND 165 OF THE CAA BY: 1) FAILURE TO TAG ALL EQUIPMENT SUB- JECT TO THE LDAR PROGRAM; 2) USING INCORRECT SAMPLING PROCEDURES TO MEASURE BENZENE LEAKS FROM VALVES; 3) NO WRITTEN PROTOCOL; 4) SPAN AND ZERO CALIBRATIONS WERE NOT BEING RECORDED; 5) FOUR VALVES IN BENZENE SERVICE WERE OPEN-ENDED; 6) ONE VALVE IN METHANOL SERVICE IN THE ALKYL PLANT WAS OPEN-ENDED; AND 7) TWO VALVES IN DU #1 WERE OPEN-ENDED; VIOLATIONS OF SECTIONS 3002 AND 3004 OF RCRA: 1) SPENT BULBS EXCEEDED 55 GALLONS AT THE ELECTRICAL SHED SATELLITE ACCUMULATION AREA; 2) FAILURE TO HAVE ACCUMULA- TION DATE ON FOUR DRUMS CONTAINING WASTE RESIN AND FIL- TERS; 3) FAILURE TO MAINTAIN STANDARDS FOR HAZARDOUS WASTE MANAGEMENT FACILITY; 4) FAILURE TO MAINTAIN SUFFI- CIENT SECONDARY CONTAINMENT FOR TWO TANKS IN THE LANDFILL ARE HOLDING F039 LANDFILL LEACHATE AS REQUIRED; 5) EX- CEEDING THE HEIGHT OF THE DIKE LO