preview

research

explanatory Essay
522 words
522 words
bookmark

13. Subsequent to the submittal of the application, the Respondent was notified by ADEQ’s Permits Branch in a correspondence dated December 12, 2012 that the Respondent must submit a Title V permit application due to styrene emissions exceeding the minor threshold of 10 tons per year for an individual HAP. The Respondent submitted a Title V permit application on January 29, 2013. The application was deemed final upon issuance of R1 on May 14, 2013. 14. In a correspondence dated April 03, 2013, the Air Enforcement Branch of ADEQ issued a proposed CAO for violations discovered during the May 07, 2012 inspection. 15. In a response dated April 10, 2013, the Respondent stated that any monetary fine is not justified due to non-budgeted expense to retain a consultant to assist in obtaining compliance with the Permit. 16. The April 10, 2013 correspondence did not contain any new mitigation factors which would cause modification to the CAO. ADEQ sent a re-proposed CAO to the Respondent on May 09, 2013. 17. In a telephone call and e-mail from the Respondent on May 20, 2013, the Respondent ...

In this essay, the author

  • Explains that the respondent submitted a title v permit application due to styrene emissions exceeding the minor threshold of 10 tons per year for an individual hap.
  • Explains that adeq issued a proposed cao for violations discovered during the may 07, 2012 inspection.
  • Responds to the respondent's statement that any monetary fine is not justified due to non-budgeted expense to retain a consultant to assist in obtaining compliance with the permit.
  • Explains that adeq sent a re-proposed cao to the respondent on may 09, 2013.
  • Explains that adeq requested the submittal of applicable tax forms from the past three years to evaluate the respondent's ability to pay the proposed settlement amount.
  • States that adeq conducted a routine compliance inspection of the respondent for the time period of may 2012 through july 2013.
  • Explains that records reviewed at the time of the inspection show incorrect threshold limits values for the following hap materials.
  • Explains that the respondent exceeded the permitted limit of 1,500 gallons of acetone per consecutive twelve-month rolling total period. similar violations were noted in the previous inspection.
  • Explains that adeq notified the respondent of the findings discovered during the inspection.
  • Explains that respondent submitted acetone usage records for time period january 2013 through april 2013. the records show exceedances of the permitted limit of 1,500 gallons per consecutive twelve month rolling total period for each month.
Get Access