Avery Dennison violated the Ohio State Implementation Plan, the National Emissions Standards for Hazardous Air Pollutants for Paper and Other Web Coating at 40 C.F.R. Part 63, Subpart JJJJ, and the Title V Permits for two buildings (3 and 5), each a separate facility. Specifically, Avery Dennison failed to capture 100% of volatile organic compounds and hazardous air pollutants in some of their web coating lines. We discovered these violations using an optical gas imaging camera during our August 15, 2017 Inspection of these buildings. Avery Dennison has also taken corrective action to remedy these violations and return to compliance, including the repair of oven access ways and other points in the web coating lines found venting in their web coating process. Avery Dennison has also agreed to increased monitoring and maintenance to ensure better emissions capture not only at the Painesville, Ohio facilities, but a total six domestic facilities. Avery Dennison also agreed to a penalty based on the Clean Air Act Stationary Source Penalty Policy of $160,000.