SUNOCO'S OPERATION OF ITS FLARES AT THE FORMER MARCUS HOOK REFINERY FAILED ON A NUMBER OF OCCASIONS TO COMPLY WITH REGULATORY REQUIREMENTS BY OPERATING A FLARE 1) WITHOUT A FLAME PRESENT, 2) WITH AN EXCESSIVE EXIT VELOCITY, 3) IN A MANNER INCONSISTENT WITH GOOD AIR POLLUTION CONTROL PRACTICE FOR MINIMIZING EMISSIONS, AND 4) IN A MANNER THAT IS NOT IN CONFORMANCE WITH ITS DESIGN.