On September 20, 2018, EPA Region 6 issued a Consent Agreement and Final Order (CAFO) under its authority pursuant to Section 3008(a) of the Resource Conservation and Recovery Act (RCRA) to The DOW Chemical Company facility located in Freeport, Texas. The CAFO was issued in response to the following violations of RCRA: 1)Illegal Storage of Hazardous Waste in an Unpermitted Unit; 2)Failure to Appropriately Label Units in Hazardous Waste Service; 3)Failure to Inspect a Container Subject to 40 CFR 264 Subpart CC; and 4)Misidentification of Valves Subject to Leak Detection Monitoring. The CAFO requires The DOW Chemical Company to: 1)Perform an audit under the Texas Environmental, Health, and Safety Audit Privilege Act; 2)Certify that it is operating in compliance with RCRA; and 3)Pay a civil penalty of $500,000.