THIS ACTION INVOLVES THE SETTLEMENT OF VIOLATIONS UNDER THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA), 42 U.S.C. 6901 ET SEQ, AND THE TOXIC SUBSTANCE CONTROL ACT (TSCA), 15 U.S.C. 2501 ET SEQ. THE U.S. ENVIRONMENTAL PROTECTION AGENCY ( EPA , AGENCY OR COMPLAINANT ) AND SAFETY-KLEEN CORP., INCLUDING 28 SUBSIDIARIES (HEREIN AFTERWARD REFERRED TO AS SAFETY-KLEEN OR RESPONDENTS ), AGREED TO SETTLEMENT OF ALL CAUSES OF ACTION AS SPECIFIED IN THE CONSENT AGREEMENT BEFORE THE FILING OF A COMPLAINT. SEE 40 C.F.R. 22.13. . RESPONDENT SAFETY-KLEEN CORP. IS A HOLDING COMPANY THAT OWNS 100% OF THE COMMON STOCK OF SAFETY-KLEEN SERVICES, INC., WHICH DIRECTLY OR INDIRECTLY OWNS THE REMAINING RESPONDENTS LISTED IN THE CA/FO. CERTAIN RESPONDENTS OWN AND/OR OPERATE COMMERCIAL STORAGE AND/OR DISPOSAL FACILITIES THAT HANDLE PCBS, PCB WASTE AND OTHER PCB ITEMS THAT ARE REGULATED UNDER TSCA. CERTAIN RESPONDENTS ALSO OWN AND/OR OPERATE HAZARDOUS WASTE TREATMENT, STORAGE OR DISPOSAL FACILITIES (TSDS) THAT ARE REGULATED UNDER RCRA. . RCRA REQUIRES THAT PERMITTED AND INTERIM STATUS HAZARDOUS WASTE FACILITIES MEET THE FINANCIAL ASSURANCE REQUIREMENTS IN 40 C.F.R. PARTS 264 AND 265, SUBPARTS H, FOR CLOSURE, POST-CLOSURE, AND LIABILITY INSURANC