EPA contracted helicopter flyovers for a portion of the Eagle Ford Shale during May 8-16, 2018, to assess emission sources using Optical Gas Imaging (OGI) technology. OGI video captures for the Facilities showed unauthorized hydrocarbon emissions at the Facilities. Specific SIP citations are: 1. General Requirements not being met as required under 30 TAC 106.6(b) and (c), and the TCEQ Non-Rule Standard Permit for Oil and Gas Facilities (e)(1). 2. Unlit or improperly operated flares in violation of specific requirements under the TCEQ Non-Rule Standard Permit for Oil and Gas Facilities (e)(11).