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: a. Respondent violated 30 Tex. Admin. Code 106.4(c) by failing to maintain the Facility's emission control equipment in good condition and properly operate such equipment. b. Respondent violated 30 Tex. Admin. Code 106.6(e) by failing to timely submit a certification of maximum VOC emission rate by the date of operation to demonstrate that 30 TAC 122 (addressing Federal Operating Permits Program) did not apply to the Block SWD Facility.