1. SECTION 113(D) OF THE CLEAN AIR ACT ( CAA ), 42 U.S.C. SECTION 7413(D). 2. THE SCHUMACHER COMPANY, A TEXAS CORPORATION 5610 POLK AVENUE HOUSTON, HARRIS COUNTY, TEXAS 77023 3. RESPONDENT WAS IN VIOLATION OF SECTION 112 OF THE CAA AND THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLU- TANTS (NESHAPS) BY: I) FAILURE TO CONDUCT REQUIRED INI- TIAL PERFORMANCE TESTING TO DEMONSTRATE COMPLIANCE WITH EMISSION LIMITATION STANDARDS, AS REQUIRED; II) FAILURE TO SUBMIT NOTIFICATION OF COMPLIANCE STATUS FOLLOWING THE PERFORMANCE TESTS FOR SYSTEMS A AND C, CONDUCTED IN JUN. AND JUL., 1997, AS REQUIRED; III) FAILURE TO DEMONSTRATE COMPLIANCE FOR SYSTEM B WITH EMISSION LIMITATION STAND- ARDS FOLLOWING REPLACEMENT OF TANK #6, AS REQUIRED; IV) FAILURE TO TIMELY SUBMIT NOTIFICATION OF COMPLIANCE STAT- US FOLLOWING THE PERFORMANCE TESTS CONDUCTED FOR SYSTEMS B IN JUL., 1999, AS REQUIRED; V) FAILURE TO PREPARE AND IMPLEMENT AN OPERATION AND MAINTENANCE (O&M) PLAN BY THE REQUIRED COMPLIANCE DATE AS REQUIRED AND HAVE AVAILABLE AT THE TIME OF THE INSPECTION, AS REQUIRED; VI) FAILURE TO ESTABLISH FOR BUILDING A, AS A SITE SPECIFIC PARAMETER THE PRESSURE DROP ACROSS THE COMPOSITE MESH-PAD SYSTEM, AS REQUIRED, AND FOR THE FIBER BED MIST ELIMINATOR, AS REQUIRED, SETTING THE VALUE THAT