EPA issued a Notice and Finding of Violation to Spectro on January 13, 2015. During two separate inspections conducted by MPCA, inspectors noted Spectro failed to inject lime at rates established both during recent performance tests and at rates submitted to EPA and MPCA in its Notification of Compliance Status. MPCA inspectors also discovered in July 2014 that Spectro had failed to perform and/or document multiple inspections and maintenance activities required by the NESHAP at 40 C.F.R. ? 63.1510 et seq,(Subpart RRR) and had incorrectly certified compliance with all monitoring and recordkeeping requirements for the years 2012 and 2013, all of which constitute violation of Section 112 of the CAA, 42 U.S.C. ? 7412, Title V, and the Minnesota SIP. In the ACO, Spectro agrees to modify its OM&M-SSM and submit an updated OM&M-SSM Plan within three months of the Effective Date of the ACO, incorporating additional requirements, including weekly verification of each baghouse's lime injection rate to ensure each respective injection rate is no less than 90% of the rate used to demonstrate compliance during the most recent performance test. Spectro also agrees to inspect lime feeders and augers for free flowing lime once per shift, create a checklist requiring documentation of lime feed rate inspections, baghouse blowdown and maintenance, and furnace burner cleanings, among other inspections, and maintain such records in accordance with Subpart RRR.