On October 13, 2021, EPA Region 6 issued a Consent Agreement Final Order (CAFO) under its authority pursuant to Section 113(d) of the Clean Air Act, (the CAA or Act), 42 U.S.C. 7413(d), and Sections 22.13, 22.18, and 22.34 of the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties and the Revocation/Termination or Suspension of Permit (Consolidated Rules), as codified at 40 C.F.R. Part 22 to Equistar Chemicals LLC located Westlake, LA. The CAFO was issued in response to violations of: Pursuant to 40 C.F.R. 60.11(d), [a]t all times, . . . owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. EPA has interpreted the good air pollution control practice requirement to include operating flares with an appropriate steam-to-vent-gas ratio. Studies have shown that flare efficiencies decrease sharply when steam-to-vent-gas ratios exceed 3-to-1. During the violations period, two flares at the Facility operated for periods of time with excessively high steam-to-vent-gas ratios of 10-to-1 or greater.