An automobile supplier client with two coating operations had two air use permits with VOC limits. New management discovered possible non-compliance with both the permits and Clean Air Act (CAA) rules. Varnum engaged in compliance counseling with the client wherein the company's non-compliance was confirmed and quantified and a corrective action plan developed.

Then, at the request of management, the non-compliance was self-reported to the Michigan Department of Environmental Quality (MDEQ). A Notice of Violation (NOV) was issued, but a new permit and a Consent Order were negotiated. The initial penalty proposed by MDEQ of $240,000 was reduced by 60% through negotiations, and additional time for reaching full compliance was obtained to allow the company to pursue coating change options dependent upon customer approval.