SHELL OPERATED ON AT LEAST TWO OCCASIONS A LEAKING VAPOR STORAGE AND RECOVERY SYSTEM FOR THE TERMINA'S GASOLINE LOADING BAY SYSTEM. SHELL LOADED GASOLINE ONTO BARGES W/O REQUIRED VAPOR RECOVERY EQUIPMENT, RESULTING IN EXCESS EMISSIONS. SHELL FAILED TO MEET REQUIREMENTS FOR CONSTRUCT- ING AND OPERATING A MAJOR MODIFICATION TO THE FACIITIES GASOLINE LOADING BAY SYSTEM (BY ADDING AN ADDITIONAL BAY W/O OBTAINING THE NECESSARY PERMITS AS REQUIRED BY CT SIP AND WITHOUT COMPLYING WITH THE FEDERAL REGULATORY REQUIRE- MENTS UNDER CAA. SHELL THEREBY AVOIDED THE REQUIREMENT TO PROVIDE APPROXIMATELY 80 TONS PER YEAR OF VOC OFFSETS.