SUNOCO VIOLATED NUMEROUS STATUTORY AND REGULATORY REQUIREMENTS THROUGH ITS FAILURE TO PROPERLY CALCULATE AND MEET EMISSION LIMISTS AND OTHER REPORTING REQUIREMENTS UNDER ITS EARLY REDUCTION PERMIT, TO PROPERLY ACCOUNT FOR AND REPORT EMISSIONS UNDER ITS EMISSION AVERAGING PLAN, TO MEET THE OPERATING PARAMETERS FOR CERTAIN CONTROL DEVICES, TO IMPLEMENT REGULATORY REQUIREMENTS AT CERTAIN PROCESS VENTS, AND TO PROPERLY CALCULATE ITS BENEZENE WASTE EMISSIONS.