Reilly Industries, Inc. (Reilly) owns and operates a chemical manufacturing facility which contains industrial process refrigeration units using stratospheric ozone depleting compounds. A Finding of Violation was issued to Reilly on March 8, 2005 alleging that Reilly failed to conduct initial and follow-up verification tests, failed to repair, failed to verify the success of these repairs, and document service performed to some of their refrigeration units. An Administrative Consent Order (ACO) was issued on September 6, 2005 to resolve the Finding of Violation issued by U.S. EPA regarding its refrigeration units. The ACO requires Reilly to implement an improved program for recordkeeping practices and to develop a program to study retrofitting its industrial process and comfort cooling refrigeration units.