UNION CARBIDE CHEMICALS AND PLASTIC COMPANY, INC. ( RESPON- DENT ) IS INCORPORATED IN AND UNDER THE LAWS OF THE STATE OF NEW YORK. RESPONDENT OWNS AND OPERATES A CHEMICAL PROCESSING AND PRO- DUCTION FACILITY (HEREINAFTER THE PLANT ) LOCATED AT 3301 5TH AVENUE SOUTH, GALVESTON COUNTY, TEXAS CITY, TX., AND A NEARBY MARINE TERMINAL WHERE IT MANAGES A VARIETY OF ORGANIC AND INORGANIC WASTES (IGNITABLE, CORROSIVE, TOXIC, REACTIVE, AND ACUTELY HAZARDOUS). AT THE PLANT, RESPONDENT IS PRIMARILY ENGAGED IN PETROCHEM- ICAL MANUFACTURING FROM NATURAL GAS. ON AUG. 11, 1980; JUL. 5, 1988; AND AUG. 8, 1991, RESPONDENT SUBMITTED ITS NOTIFICATION OF HAZARDOUS WASTE ACTIVITY AS REQUIRED BY SECTION 3010(A) OF RCRA, 42 U.S.C. SEC. 6930(A). ON NOV. 17, 1980, RESPONDENT SUBMITTED A PART A HAZARDOUS WASTE PERMIT APPLICATION. ON JAN. 10, 1991, EPA AND TEXAS NATURAL RESOURCES CONSERVA- TION COMMISSION ( TNRCC ) (FORMERLY THE TEXAS WATER COMMIS- SION ( TWC ) ISSUED A JOINT PERMIT NUMBER HW-50242-001 TO RESPONDENT, AUTHORIZING IT TO TREAT, STORE, AND DISPOSE OF HAZARDOUS WASTE GENERATED FROM THE RESPONDENT'S PLANT AND MARINE TERMINAL. ON MAR. 13, 1991, EPA ISSUED AND MADE EFFECTIVE PROVISIONS OF OF PERMIT NUMBER HW-50242-001, WHICH WERE REQUIREMENTS OF THE HAZARDOUS WASTE AND SOLID WASTE