RESPONDENT OWNS AND OPERATES A FACILITY WHERE IT PRODUCES INDUSTRIAL AND INORGANIC CHEMICALS. MONSANTO CHEMICAL, INC. OWNED AND OPERATED THE FACILITY FROM 11/19/80 TO 08/01/86 WHEN IT WAS TRANSFERRED TO STERLING. RESPONDENT'S PREDECES- SOR SUBMITTED A NOTIFICATION OF HAZARDOUS WASTE ACTIVITY IN WHICH IT CERTIFIED THAT IT GENERATES, TRANSPORTS, TREATS, STORES, AND DISPOSES OF HAZARDOUS WASTE AND CONDUCTS UNDER- GROUND INJECTIONS. THE COMPLAINT ISSUED LISTED THE FOLLOWING COUNTS: COUNT 1 - FAILURE TO UPDATE THE WASTE ANALYSIS PLAN IN A TIMELY MANNER. COUNT 2 - FAILURE TO AMEND THE CONTINGENCY PLAN IN A TIMELY MANNER. COUNT 3 - FAILURE TO ESTABLISH TOTAL HAZARDOUS WASTE FEED LIMITS IN THE COP. COUNT 4 - INADEQUATE TESTING OF THE AWFCO. COUNT 5 - INADEQUATE WASTE ANALYSIS. ADDRESS: 201 BAY STREET TEXAS CITY, TX. 77590