REGION 9 ISSUED A NOTICE OF VIOLATION ( NOV ) TO BROWNWOOD ON JULY 28, 1998. THE NOV STATED THAT BROWNWOOD VIOLATED SCAQMD REGULATIONS II AND XIII BY: (1) FAILING TO PROVIDE ALL THE INFORMATION NECESSARY TO ENABLE THE DISTRICT TO MAKE THE PERMITTING DECISION; (2) INSTALLING EQUIPMENT WITHOUT MEETING BACT AND WITHOUT PROVIDING OFFSETS; (3) OPERATING UNDER VOID PTOS; (4) FAILING TO MAINTAIN RECORDS AS REQUIRED BY ITS PTOS; AND (5) EMITTING MORE VOCS THAN ALLOWED BY ITS PTOS. ATT: I. BROWNWOOD PREPARED A WRITTEN RESPONSE TO THIS NOV ON SEPTEMBER 1, 1998. ATT. J. BROWNWOOD AND REGION 9 MET ON SEPTEMBER 9, 1998, TO DISCUSS THE NOV. NO INJUNCTIVE RELIEF IS REQUIRED IF BROWNWOOD SUCESSFULLY CARRIES OUT THE PLAN TO COME INTO COMPLIANCE PRESENTED AT THE NOV CONFERENCE. REGION 9 IS SEEKING A PENALTY OF $98,150 TO REFLECT THE GRAVITY OF BROWNWOOD'S PERMITTING AND EMISSION VIOLATIONS. EPA AND THE SCAQMD PROSECUTOR'S OFFICE HAVE WORKED COOPERATIVELY TO DEVELOP THE FACTS OF THIS CASE, AND THE PROSECUTOR'S OFFICE IS DEVELOP THE FACTS OF THIS CASE, AND THE PROSECUTOR'S OFFICE IS ALSO PREPARING AN ENFORCEMENT ACTION AGAINST BROWNWOOD.