EPA issued two Notices of Violation (NOV) and Findings of Violation (FOV)to Shall and Merit. On September 21, 2005, EPA issued a NOV/FOV alleged violations of the PSD and Title V permitting requirements of the Clean Air Act (Act). The NOV/FOV alleged that Shell/Merit violated the CAA and the Michigan SIP by installing equipment at the Manistee plant and increasing the natural gas production at the Manistee plant without obtaining PSD permit.