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Chemithon Corp. v. Puget Sound Air Pollution Control Agency

Citations: 31 Wash. App. 276; 640 P.2d 1085; 12 Envtl. L. Rep. (Envtl. Law Inst.) 20420; 18 ERC (BNA) 1647; 1982 Wash. App. LEXIS 2457Docket: No. 8633-2-I

Court: Court of Appeals of Washington; February 16, 1982; Washington; State Appellate Court

Narrative Opinion Summary

In this case, Chemithon Corporation appealed a penalty imposed by the Puget Sound Air Pollution Control Agency (PSAPCA) for breaching air pollution regulations related to visual opacity standards. Specifically, Chemithon was fined $250 for emitting air contaminants that exceeded the permissible visual opacity threshold outlined in Regulation I, section 9.03, despite complying with particulate emission standards under section 9.09. The Pollution Control Hearings Board supported the fine, emphasizing the independent enforceability of opacity standards from particulate measures. Chemithon argued that the opacity measure was less reliable than particulate analysis and claimed an exemption based on mixing harmless water vapor with allowable particulate pollution. However, the court dismissed these claims, affirming that visual opacity violations are punishable even when particulate standards are met and clarified that the exception for uncombined water emissions is applicable only in the absence of particulate contaminants. Consequently, the court endorsed the Superior Court's judgment, maintaining the penalty against Chemithon for its violation of the visual opacity standard.

Legal Issues Addressed

Independent Assessment of Air Quality Violations

Application: Violations of visual opacity standards can be assessed independently of particulate emission compliance, underscoring the separate enforcement of each regulation.

Reasoning: The court clarified that violations of section 9.03 can be assessed independently of section 9.09, and the exception for uncombined water applies only if emissions are free of particulate contaminants.

Uncombined Water Exception in Air Emissions

Application: The exception for emissions solely caused by uncombined water does not apply if the emissions include particulate contaminants.

Reasoning: The court clarified that violations of section 9.03 can be assessed independently of section 9.09, and the exception for uncombined water applies only if emissions are free of particulate contaminants.

Visual Opacity Standards and Civil Penalties

Application: The court upheld the imposition of a civil penalty for violating visual opacity standards, regardless of compliance with particulate emission standards.

Reasoning: The court rejected Chemithon's argument, asserting that a civil penalty for visual opacity violations remains valid even if particulate standards are not breached.