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 Crimson facilities show unauthorized hydrocarbon emissions at the Facilities. Crimson Energy's ownership of the Facilities was determined based on global positioning coordinates available in current federal and state databases and in permits issued by the Texas Commission on Environmental Quality (TCEQ). Specific SIP citations for the violations include: 1. General Requirements not being met as required under 30 TAC 116.620, and 2. Tanks with unauthorized emissions in violation of permit representations made under sections (e)(1), (e)(5) and (e)(6) of the Air Quality Standard Permit for Oil and Gas Handling and Production Facilities, effective November 8, 2012.