1. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 ( RCRA ), 42 U.S.C. SECTION 6928, AS AMENDED BY THE HAZARDOUS AND SOLID WASTE ADMENDMENTS OF 1984. 2. THE DOW CHEMICAL COMPANY 2301 BRAZOSPORT BOULEVARD FREEPORT, TEXAS 77541-3237 3. THE RESPONDENT WAS IN VIOLATION OF SUBTITLE C OF RCRA BY 1) FAILING TO MAINTAIN RECORDS OF TOTAL FEED RATE, 2) FAILING TO COMPLY WITH THE AIR EMISSION STANDARDS FOR E- QUIPMENT LEAKS, 3) FAILING TO ESTABLISH APPROPRIATE COC OPERATING LIMITS ON COMPLIANCE TEST DATA, AND 4) FAILING TO COMPLY WITH THE MAXIMUM STEAM PRODUCTION RATE. 4. RELIEF SOUGHT PURSUANT TO SECTION 3008(A) OF RCRA, EPA PROPOSES A COMPLIANCE ORDER THAT REQUIRES THE RESPONDENT TO SUBMIT TO EPA A WRITTEN DESCRIPTION OF THE ACTIONS TA- KEN TO ENSURE THAT RECORDS OF THE TOTAL HAZARDOUS WASTE FEED RATE ARE BEING MAINTAINED FOR INDUSTRIAL FURNACES A-607A AND B WITHIN 30 DAYS AFTER RECEIPT OF THE ORDER. ALSO, EPA PROPOSES A PENALTY OF $86,150 FOR THE ALLEGED VIOLATIONS IN THE COMPLAINT.