This ACO requires Behr to develop and implement a fugitive dust plan, conduct regular monitoring of the building housing lead operations to limit uncaptured lead emissions, and incorporate these modifications into a federally enforceable construction permit, which will result in a 73 pound per year reduction in lead emissions and addresses the violations set forth in the NOV issued to the former owner of the facility on November 3, 2016, and the NOV issued to Behr on December 28, 2016.
The facility also repaved a large portion of the site and purchased a street sweeper to be used with the fugitive dust plan.