Industrial Wastewater Permit - Honeywell International Inc.

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35 Honeywell International Industrial Discharge Permit 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 violate, any provision of this ordinance, an individual wastewater discharge permit, or order issued hereunder, or any other Pretreatment Standard or Requirement, or that the User's past violations are likely to recur, the Director may issue an order to the User directing it to cease and desist all such violations and directing the User to: (1) Immediately comply with all requirements; and (2) Take such appropriate remedial or preventive action as may be needed to properly address a continuing or threatened violation, including halting operations and/or terminating the discharge. Issuance of a cease and desist order shall not be a bar against, or a prerequisite for, taking any other action against the User. b. Consent - The Director may enter into Consent Orders, assurances of compliance, or other similar documents establishing an agreement with any User responsible for noncompliance. Such documents shall include specific action to be taken by the User to correct the noncompliance within a time period specified by the document. c. Show Cause - The Director may order a User which has violated, or continues to violate,