On September 22, 2004, EPA isued an FOV to Allied for operating, reporting, and testing violations of 40 CFR Part 63, Subpart RRR (RRR). Allied then conducted a stack test on its thermal chip dryer and violated the emission limits in RRR. Allied was never able to produce a compliant test for its thermal chip dryer. On September 29, 2005, EPA referred the case to DOJ. In February of 2006, Allied shut down its dryer. Allied will achieve compliance with RRR by rendering its dryer inoperable and removing it from its operating permit. It will also surrender any pollution credits relating to emissions from the dryer and agree not to return the dryer to service unless it requests in writing and receives approval in writing from both EPA and IEPA to do so. Allied has agreed to pay a penalty of $92,210 and conduct two SEPs totalling $265,254: a diesel retrofit SEP on school buses or municipal vehicles in the Chicagoland area; and a Dioxin/Furan Adsorption and Natural Landscaping SEP along the bank of the Chicago River on the south-side Allied property.