1. SECTION 113(D) OF THE CLEAN AIR ACT ( CAA ), 42 U.S.C. SECTION 7413(D). SECTION 309(G)(2) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G)(2). SECTION 325(C) OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT ( EPCRTKA ), 42 U.S.C. SECTION 11045. SECTION 3008(A) OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6928. 2. THE DOW CHEMICAL COMPANY, A DELAWARE CORPORATION 2301 BRAZOSPORT BLVD. FREEPORT, BRAZORIA COUNTY, TEXAS 77541 3. RESPONDENT WAS IN VIOLATION OF SECTION 112 OF THE CAA BY 1) FAILURE TO COMPLY WITH STANDARDS FOR OPEN-ENDED VALVES OR LINES (NESHAPS), 2) FAILURE TO COMPLY WITH STANDARDS FOR OPEN-ENDED VALVES OR LINES (HON), 3) FAILURE TO DE- TERMINE THE NET HEATING VALUE OF COMBUSTED FLARE GAS (NE- SHAPS), 4) FAILURE TO DETERMINE FLARE EXIT VELOCITY (NE- SHAPS), 5) FAILURE TO DETERMINE THE NET HEATING VALUE OF COMBUSTED FLARE GAS (HON), AND 6) FAILURE TO DETERMINE FLARE EXIT VELOCITY (HON). RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY EXCEEDING THE EFFLUENT LIMITATIONS OF ITS PERMIT. RESPONDENT WAS IN VIOLATION OF THE REPORTING REQUIREMENTS OF SECTION 312(A) OF EPCRTKA BY FAILING TO REPORT STORAGE OR USAGE OF ACETYLENE, COMPRESSED