EPA conducted a comprehensive review of the Facility-specific information gathered based upon observations made from OGI video captures, permitted Facility operations, and information provided by Respondent. Based on this review, EPA alleged the following violations applicable to the Facilities: failing to maintain the Facilities' emissions control equipment in good condition and properly operate such equipment; failing to operate equipment consistent with operating procedures in the Facilities' certified registrations; varying from representations in the Facilities' certified registrations regarding emissions; failing to obtain authorization prior to operating a source of air emissions; failing to ensure that equipment was maintained in good working order and operating properly during normal facility operations; failing to route emissions from tanks without floating roofs to a destruction device with a minimum VOC destruction efficiency of 98 percent or to a vapor recovery system with a minimum VOC recovery efficiency of 95 percent; and, not properly maintaining tank seals and gaskets to prevent leaking and not ensuring that tank hatches remain closed except during sampling, gauging, loading, unloading, or planned maintenance activities. The company must pay a civil penalty and implement inspection, monitoring, and corrective actions to minimize emissions and modify permits.