Ross Incineration Services, Inc. (Ross) owns and operates a hazardous waste incinerator located in Eaton Township, Lorain County, Ohio. The incinerator is regulated under the National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors (HWC MACT), 40 C.F.R. Part 63, subpart EEE. On September 26, 2007, EPA issued to Ross a Notice of Violation (NOV) and Finding of Violation (FOV) for violating emission standards set forth in and operating parameter limits (OPLs) established pursuant to the HWC MACT, 40 C.F.R. 63, Subpart EEE. The FOV/NOV cited violations of the dioxin/furan emission standard on 89 days between February 8 and May 9, 2006; violations of the carbon monoxide emission standards on 126 days between October 2, 2004, and February 26, 2007; and 700 exceedances of Ross?s operating parameter limits. In August 2009, EPA requested Ross?s continuous monitoring data for carbon monoxide and operating parameters between March 1, 2007, and August 20, 2009.