Trialco, Inc. is a secondary aluminum production facility subject to the Secondary Aluminum Production NESHAP (subpart RRR). The compliance deadline for existing sources under subpart RRR was March 24, 2003. Upon inspection on April 16, 2004, EPA found that Trialco had not met the subpart RRR requirements for performance testing, monitoring, operating, and notification. EPA issued a Finding of Violation to Trialco in September 2004. Trialco conducted performance testing at its furnace baghouse in November 2004, which demonstrated compliance with the subpart RRR dioxins/furans limit applicable to the furnaces. Trialco also installed all equipment necessary for compliance with the monitoring and operating requirements in subpart RRR, and Trialco submitted the required Notification of Compliance Status. EPA issued an Administrative Penalty Order to Trialco in September 2005, participated in settlement discussions with Trialco November 2005 through January 2006 and reached agreement on penalty and 2 supplemental environmental projects, as specified in the February 2006 Consent Agreement and Final Order.