On December 18, 2003, Region III issued an Administrative Order ( AO ) against Respondent Markovitz Enterprises, Inc., ( Markovitz ) to address alleged violations of the National Emission Standards for Halogenated Solvent Cleaning ( the Halogenated Solvent Cleaning NESHAP ) promulgated at 40 C.F.R. Part 63, Subpart T, pursuant to Section 112 of the Clean Air Act. The Halogenated Solvent Cleaning NESHAP requires sources to follow work practice standards to minimize the airborne release of hazardous air pollutants, monitor for compliance, and report compliance status to regulatory agencies. EPA discovered the alleged violations during August 5 and 6, 2003 inspections of the Markovitz's New Castle, Pennsylvania facility. Markovitz, through its Flowline Division operates a facility at 1400 Butler Avenue, in New Castle, Pennsylvania that manufactures corrosion resistant pipe fittings and flanges. The AO alleges that Markovitz violated the Halogenated Solvent Cleaning NESHAP by failing to: 1. install an automatic vapor level control shut off valve for its degreaser; and 2. failed to ensure that the freeboard ratio for the 0.75, or greater, as required. The result of these violations could have resulted in airborne releases of Trichloroethylene ( TCE ). The Order requires Markovitz to address and correct each violation by June 30, 2000. Respondent operates a degreasing cleaning machine, which utilizes Trichloroethylene ( TCE ), as a halogenated cleaning solvent. The deg