A Michigan manufacturer received a request under Section 114a of the Clean Air Act to assemble and produce records and information on process changes over a 20-year period. After assisting the client in interpreting the request, and obtaining an extension, Varnum assisted in assembling and producing the relevant documents. The U.S. EPA then conducted a one-week â€wall to wall inspection of the operations.

Varnum had advised the client on how to prepare, and a series of internal teams were assembled to accompany each member of the EPA's inspection team. All potential non-compliance was reviewed with counsel immediately after the inspection, and a follow up document production was made within three days. The facility was eventually cited in a Notice of Violation for alleged Clean Air Act violations for process changes that had occurred ten years earlier. After two years of discussions, a compromise settlement was negotiated with U.S. EPA.