EPA and Keystone Steel and Wire Co. (Keystone) have entered into a Consent Decree that provides for a civil penalty of five-hundred-sixty-five-thousand dollars ($565,000), to be paid in two installments. The Consent Decree requires, among other compliance measures, that Keystone (1) continuously operate its SO2 CEMS located at the Arc Shop, (2) continuously comply with a 30-day rolling average SO2 emission limit; (3) modify each baghouse fan motor to ensure that each fan has the potential to achieve 220,000 actual cubic feet per minute (acfm) at each Baghouse Fan Inlet at any time during Arc Shop operation; (4) submit to EPA for approval a preventative maintenance and operation plan (PMO Plan) and continuously comply with the requirements of the approved PMO Plan; and (5) perform root cause failure analyses (RCFAs) within 30 days of the conclusion of any heat of which the total duration is longer than one hundred and fifty (150) minutes, and (6) implement corrective action in accordance with the results of the RCFA.