EPA has conducted a comprehensive review of the facility-specific information gathered based upon observations made from the OGI video captures, facility permitted operation, and information provided by the Respondent. Based on this review, EPA alleges the following violations for the Facilities:
a. Respondent violated NSPS Subparts OOOO and OOOOa, 40 C.F.R. 60.5370(b) and 60.5370a(b), by failing to maintain and operate the NOI Facilities in a manner consistent with good air pollution control practice for minimizing emissions.
b. Respondent violated NSPS Subparts OOOO and OOOOa, 40 C.F.R. 60.5395(e)(1) and 60.5395a(b)(1), by failing to use the NOI Facilities control device(s) to reduce emissions from the NOI Facilities by connecting the NOI Facilities through a closed vent system and routing emissions to a control device or to a process.
c. Respondent violated NSPS Subpart OOOO, 40 C.F.R. 60.5395(e)(1), by failing to operate the closed vent systems of the NOI Facilities which all use control devices or route emissions to process and operate as closed vent systems with no detectable emissions, as determined using olfactory, visual, and auditory inspections, as required by 40 C.F.R. 60.5411(c).
d. Respondent violated NSPS Subpart OOOOa, 40 C.F.R. 60.5395a(b)(1), by failing to operate the closed vent systems of the NOI Facilities which all use control devices or route emissions to process and operate as closed vent systems with no detectable emissions, as determined using