On March 24, 2025, EPA issued to the Dow Chemical Company a Consent Agreement and Final Order (the ?CAFO?) and provided a copy of the CAFO to the State of Texas. In the CAFO, EPA provided that it found Respondent committed the alleged violations of the National Emission Standards for Hazardous Air Pollutants (?NESHAP?) for Benzene Waste Operations described in Section F of this CAFO by failing to determine the total annual waste quantity at the point of waste generation.