U.S. EPA issued an Administrative Consent Order (ACO) to Lithographic Industries, Inc. (Lithographic) to resolve violations of the Illinois SIP and the facility's federally enforceable state operating permit (FESOP). In a Notice of Violation (NOV) issued on June 23, 2016, EPA alleged that Lithographic violated the Illinois SIP provisions at 35 IAC 218.204(c) and the facility's FESOP by applying a paper coating in which the VOM content exceeded applicable emission limits and by operating a capture system and control device that did not provide at least 90 percent reduction in overall VOM emissions, a requirement to meet the alternative compliance requirements at 35 IAC 218.207. The NOV also alleged that Lithographic violated the FESOP for the facility by emitting toluene, a hazardous air pollutant (HAP), in excess of 7.9 tons per year. Lithographic installed a new regenerative thermal oxidizer (RTO) to control emissions of VOM and toluene at the facility. The ACO requires, among other things, that the coating line be equipped with a permanent total enclosure (PTE) with 100% capture and that the RTO achieve and maintain a VOM destruction efficiency of at least 93% by weight.