EPA has conducted a comprehensive review of the facility-specific information gathered based upon observations made from the OGI video captures, facility permitted operations, and information provided by Respondent. Based on this review, EPA alleges one or more of the following violations for the Facilities: Respondent violated 20 NMAC 2.72.210(D) by failing to comply with the Facilities' permit conditions, as identified in subparagraphs 31.b. Respondent violated Part A205(B) of a Facility's GCP-O&G permit by failing to either limit the hydrocarbon liquid throughput and average separator pressure to the amount and pressure listed in the relevant Registration Form or, otherwise, operate a control device and/or vapor recovery unit as a closed vent system that captures and routes tank emissions to the process stream or to the control device, and does not vent to atmosphere. Respondent violated Part A100(F) of the GCP-O&G permit by failing to operate certain Facilities as specified in the Facilities' Registration Form(s). Respondent violated 20 NMAC 2.7.14 and Parts A107(E) and B109 of the GCP-O&G by failing to implement a plan to minimize emissions during routine or predictable startup, shutdown, and scheduled maintenance through work practice standards and good air pollution control practices at a Facility. Respondent violated 20 NMAC 2.7.109 by failing to comply with the Facilities' permit conditions, resulting in emissions of an air contaminant in excess of the quantity, rate