Industrial Wastewater Discharge Permit Renewal - Honeywell International, Inc.

Home Browse Search

Honeywell Groundwater Remediation Industrial Wastewater Discharge Permit page 29 of 39 Response Plan should normally be followed. However, certain circumstances or types of violations may require responses that deviate from this plan. The Enforcement Response Plan indicates the type of noncompliance, the circumstances which might vary the type of response and the range of responses for that particular category of noncompliance. The Enforcement Response Plan has been developed with the intention of serving the following purposes. 1. It recommends enforcement responses that are appropriate in relation to the nature and severity of the violation and the overall degree of noncompliance. 2. It provides a guide to encourage a uniform application of enforcement responses to comparable levels in types of violations, and it can be used as a mechanism to review the appropriateness of the response. The Enforcement Response Plan groups various types of violations into the following four categories: 1. Violations of sampling, monitoring, and reporting 2. Violations of compliance schedules 3. Violations of discharge limitations 4. Violations detected through inspection or field monitoring In order to provide a concise document in a usable format, abbreviations have been used for the types of response. A definition of each abbreviation is listed in increasing order of severity. 1. IA – An Informal Action may be used to respond to minor violations. This is typically conveyed to the industry contact person, either by phone or with a written notice. This type of response is used for very minor violations that only require follow up action at the next compliance event. 2. LOV – A Letter of Violation is the most widely used and is a written notification to the User indicating the type of apparent violation. The LOV will require a response within 14 days which usually consists of a written letter to the Control Authority (POTW – City of South Bend) indicating the reason for the noncompliance and a description of measures that are being taken to eliminate similar future violations. 3. AF – An Administrative Fine is a monetary penalty assessed by the Control Authority for violations of pretreatment standards and requirements. An administrative fine may not exceed $2,500 per day per violation and the Control Authority has discretion in setting the amount of the fine. In the case of long term noncompliance, or noncompliance with a long term average standard, a fine shall accrue for each day of the period of noncompliance. 4. AO – An Administrative Order is issued to a User by the Control Authority and contains necessary corrective measures that need to be carried out by a User to achieve compliance. The four basic types of administrative orders are: Cease and Desist, Consent, Show Cause, and Compliance. A description of each follows. The order would normally contain a short time frame. a. Cease and Desist - When the Director finds that a User has violated, or continues to