On June 8, 2018, duly authorized EPA inspectors conducted an optical gas imaging survey of the gasoline and petroleum storage tanks at the facility. Based on the strong emissions visible, using optical gas imaging, from roof vents on Tanks 13, 14, 15, 19, and 21 as observed by a FLIR camera, EPA issued a Clean Air Act, Section 114(a) Request for Information (Information Request), CAA-02 2019-1456, dated February 25, 2019. The Information Request required Total to conduct LEL monitoring in the headspace between the fixed and internal floating roofs for Tanks 13, 14, 15, 19, and 21, using an LEL monitoring procedure specified by EPA. Based on the National Fire Protection Association's (NFPA) standard and experienced EPA inspector opinion, the LEL readings in the May 8, 2019 Report indicated dangerously high LEL, above the NFPA standard, at each of the tanks tested and that the tanks pose an imminent fire risk.