Document 6ZeJXpK0gNE7raVGnqqD6d9o

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 SENT VIA ELECTRONIC MAIL Ms. April Miller Chief Executive Officer W.T. Miller, LLC 1334 Blanchard Boulevard Columbus, Georgia 31901 april@wtmiller.com Re: W.T. Miller, LLC - Columbus, Georgia Notice of Potential Violation and Opportunity to Confer Dear Ms. Miller: Information currently available to the U.S. Environmental Protection Agency suggests that W.T. Miller, LLC may have committed violations of Section 112 of the Clean Air Act (CAA), 42 U.S.C. 7412, and the regulations promulgated at 40 C.F.R. Part 61, Subpart M (National Emission Standard for Asbestos). By this letter, the EPA is extending to you an opportunity to advise the Agency, in person, via a conference call, or in writing, of any further information the EPA should consider with respect to the potential violations. Specifically, the EPA has information indicating that on or about December 2, 2020, renovations including the removal of roofing materials began at The Stockyard located at 7505 River Road in Columbus, Georgia (the facility). Following this roof removal, W.T. Miller, LLC demolished the facility. As the company responsible for the renovation and demolition of the facility, W.T. Miller, LLC is an "owner or operator of a demolition or renovation activity" as defined by 40 C.F.R. 61.141. The EPA has reason to believe that W.T. Miller, LLC may have failed to conduct a thorough inspection for asbestos-containing materials prior to commencing renovation activities as required by 40 C.F.R. 61.145(a). The EPA also has reason to believe that the structure may have been demolished without W.T. Miller, LLC having provided notification to the Georgia Environmental Protection Division 10 days prior to the demolition. Such prior notification is required when demolition of any regulated facility occurs, regardless of the amount of asbestos-containing materials in the facility, pursuant to 40 C.F.R. 61.145(b). The EPA has authority under Section 113 of the CAA, 42 U.S.C. 7413, to pursue enforcement actions for violations of Section 112 of the CAA, 42 U.S.C. 7412, and the regulations promulgated at 40 C.F.R. Part 61, Subpart M, including the issuance of compliance orders, the assessment of administrative penalties and/or the initiation of civil or criminal actions. To discuss the potential violations identified above, the EPA requests that a representative of the facility contact Ms. Pamela Storm of the EPA Region 4 staff, the case development officer for this case, at (404) 562-9197 or via email at storm.pamela@epa.gov, within seven (7) calendar days of receipt of this letter to make Internet Address (URL) http://www.epa.gov arrangements to discuss the potential violations and the EPA's possible enforcement action. Please inform Ms. Pamela Storm if you intend to have legal representation present at this discussion. You may voluntarily submit any documentation or information that you would like the EPA to review in advance of any in person meeting or teleconference on the matter as to why you believe the EPA should not take an enforcement action with respect to the above-mentioned potential violations. If you decide to submit such documentation or information, the EPA respectfully requests that you do so two weeks in advance of the meeting or teleconference. If you have questions regarding the type of information that should be submitted to the EPA or any other questions regarding this matter, please contact Ms. Pamela Storm using the aforementioned contact information. Sincerely, TODD Digitally signed by TODD GROENDYKE GROENDYKE 08:13:33 -04'00' Date: 2021.03.16 Todd Groendyke Chief South Air Enforcement Section Air Enforcement Branch cc: Sarah Visser, Assistant Branch Chief Land Protection Branch Georgia Environmental Protection Division