Per a October 15, 1999 Agreement between Silgan Containers LLC (Silgan) and the U.S. Environmental Protection Agency, Silgan conducted a nationwide audit of each of its facilities to evaluate its compliance with 1) the Prevention of Significant Deterioration/New Source Review (PSD/NSR) requirements of the Clean Air Act (the Act); 2) other air pollution control regulations of the Act; and 3) its permits. In 2002, pursuant to EPA?s policy, ?Incentives for Self-Policing: Discovery, Disclosure, Correction, and Prevention of Violations,? referred to as the ?Audit Policy,? Silgan disclosed potential violations in EPA regions 2, 4, 5, and 7, and in 2004, Region 10. Specific to Region 5, Silgan disclosed potential violations at its Broadview and Rochelle, Illinois; Hammond, Indiana; Benton Harbor, Michigan; St. Paul, Minnesota; and Menomonee Falls, Menomonie, Oconomowoc and Plover, Wisconsin facilities. The Consent Decree requires Silgan to pay a $365,000 civil penalty and, as injunctive relief, permanently cease all liquid side-seam coating application containing volatile organic compounds (VOCs) on three can welding lines at the Oconomowoc facility and convert these lines to use powder side-seam coating that contain no VOCs, resulting in a 41,960 pounds/year reduction of VOCs. $219,000 out of the $365,000 civil penalty is due to violations Silgan had in Region 5, and thus, $219,000 is the amount Region 5 is credited for. Silgan must submit applications to the Wisconsin Departm