A Notice of Violation and Finding of Violation was issued to Sauder on April 18, 2008 in which Sauder was cited for violating opacity, nitrogen oxide (NOx) and carbon monoxide (CO) emission limits, failing to continuously run its continuous opacity monitoring systems and continuous emission monitoring systems and not fulfilling all applicable reporting requirements. A FOV was issued to Sauder on February 26, 2009 in which Sauder was cited for violating its volatile organic compound (VOC) emission limit. Sauder demonstrated compliance with their CO limit by using a corrected boiler operating rate to calculate CO emissions. The recalculated CO emissions showed complaince with their limit. The remainder of the alleged violations were resolved in an Administrative Consent Order (ACO) in which Sauder was required to: increase the availability of trained maintenance personnel, maintain spare parts at the facility, take action at emission set points that are lower than emission limits, improve pollution control equipment operation, follow a pollution control equipment component replacement schedule, revise startup and shutdown procedures, adhere to quality assurance/quality control plans, increase equipment inspections and preventive maintenance schedules, submit data on revised reporting templates and overall improve boiler efficiency.