If the owner or operator submits a notice of disagreement, what steps should the EA follow?
Follow the steps provided in the EPP to resolve the disagreement like any other violation contested by the owner or operator. For example, the EA may coordinate a compliance meeting with the cited owner or operator to consider their contention (e.g., statement of facts) that the violation(s) is not a minor violation. Depending on the determination made during the compliance meeting, the EA may rescind the notice to comply (and issue an amended inspection report), modify the notice to comply, or uphold the notice to comply. If the EA upholds the notice to comply and the operator has not corrected the minor violation, the EA may cite a violation in an inspection report and implement enforcement action as described in their EPP. • Will this process circumvent the Inventory process (Title 14, California Code of Regulations, Sections 18360 through 18368)? No. If the same violation of a state minimum standard is documented in an inspection report during two consecutive months, the Board will
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- If the owner or operator submits a notice of disagreement, what steps should the EA follow?