1. SECTION 113(D) OF THE CLEAN AIR ACT ( CAA ), 42 U.S.C. SECTION 7413(D). 2. UNITED STATES BRASS CORPORATION, A TEXAS CORPORATION 901 10TH STREET PLANO, COLLIN COUNTY, TEXAS 75086 3. RESPONDENT WAS IN VIOLATION OF THE NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS ( NESHAP ) REGULA- TIONS UNDER SECTION 112 OF THE CAA BY: 1) FAILURE TO PRE- PARE AND IMPLEMENT AN OPERATION AND MAINTENANCE (O&M) PLAN BY THE REQUIRED COMPLIANCE DATE AS REQUIRED AND HAVE IT AVAILABLE AT THE TIME OF THE INSPECTION AS REQUIRED. 4. RELIEF SOUGHT PURSUANT TO SECTION 1139D) OF THE CAA, EPA PROPOSED A CIVIL PENALTY OF $30,000FOR THE VIOLATION CITED.