Merit Energy owns and operates a natural gas processing plant (KGP) in Kalkaska, Michigan, which is subject to New Source Performance Standards for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants (the NSPS). The NSPS imposes requirements for leak detection and repair (LDAR) at KGP. EPA conducted an LDAR monitoring inspection at KGP in November 2012, which revealed a number of NSPS violations, alleged in a Notice and Finding of Violation which EPA issued to Merit on January 9, 2013. Merit met with EPA to discuss the violations on March 5, 2013. EPA referred the enforcement case to the Department of Justice on July 31, 2013. To remedy the violations, Merit implemented a new and expanded LDAR monitoring program at KGP in May 2013, which will result in a reduction in VOC emissions of 41 tons per year, and 2.2 tons of HAP. Merit and EPA reached agreement on final resolution of the violations, which is embodied in a Consent Decree (CD) lodged on and entered on . Under the CD, Merit will pay a cash penalty of $885,000 and implement an enhanced LDAR monitoring program at KGP,