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 the
following violations for the Facilities:
a. Respondent violated 20 N.M.A.C. 2.72.210(D) by failing to comply with
the GCP Facilities permit conditions, as identified in subparagraphs 28.b through 28.d.
b. Respondent violated Part A205(B) of the GCP Facilities GCP-O&G permits
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.
c. Respondent violated Part A207(B)(6) of the GCP Facilities GCP-O&G
permits by failing to combust gas at all times gas was sent to the flares.
d. Respondent violated Part A100(F) of the GCP Facilities GCP-O&G permits
by failing Respondent to operate the GCP Facilities as specified in the Facilities
Registration Forms.