Sunoco failed to operate and maintain its flares in accordance with good air pollution control practices for minimizing emissions, and it failed to operate and maintain its flares in conformance with their design. Specifically, data showed that Sunoco oversteamed its flares which resulted in reduced destruction efficiency and excess emissions. The CAFO requires Sunoco to pay a penalty of $31,500 and to spend $118,000 to complete a supplemental environmental project (SEP). The SEP involves the abatement of lead-based paint in low-income homes and child-occupied facilities in the area nearby the refinery.