As part of the Consent Decree, EPA resolved the following allegations described in EPA's Amended Complaint filed on August 4, 2009: (1) failure to design and install adequate capture and collection systems and to submit information demonstrating their conformance; (2) failure to conduct adequate performance testing; (3) failure to properly establish and maintain total reactive flux injection rate and to record flux injection; (4) failure to maintain and record molten metal level at sidewell furnaces; (5) failure to prepare and implement adequate operation, maintenance and monitoring plans and startup, shutdown malfunction plans; (6) failure to maintain free-flowing lime in continuous lime-injected fabric filters; (7) failure to demonstrate compliance with applicable emission limits at Morgantown Delacquering kiln; and (8) failure to apply for a title V permit for Chicago Heights facility.