10/20/97ONE VOLATILITY VIOLATION. ON JUNE 10, 1995, AED/MSEB #4636 WAS ISSUED TO GULF OIL FOR ONE DAY OF VIOLATION FOUND AT THE GULF TERMINAL IN LINDEN, NJ, BY AGENTS OF EPA. THE PROPOSED PENALTY WAS $27,044 FOR OFFERING FOR SALE AND SELLING ON MAY 1, 1995, 87 OCTANE GASOLINE FROM TANK #102 WHOSE RVP WAS FOUND BY THE EPA LABORATORY TO BE IN VIOLATION OF THE STANDARD FOR VOC-REGION 2: FFI #1058113-13: (ALL LEVELS) RVP = 8.71 PSI STD = 8.3 PSI. EPA INSPECTORS FOUND AND COPIED EVIDENCE OF ONE SALE FROM TANK #102 ON MAY 1, 1995 (FOR 1,000 GALLONS). SINCE THE ENTIRE TANK WAS OFFERED FOR SALE (1,424,304 GALLONS), THE PENALTY WAS SET AT THE STATUTORY MAXIMUM PLUS THE AMOUNT OF ECONOMIC BENEFIT GULF OIL WOULD HAVE REALIZED IF THE TANK HAD BEEN SOLD (AS DERIVED USING THE RFG PENALTY CALCULATION SPREADSHEET). SETTLEMENTOF THIS CASE WAS SIGNIFICANTLY DELAYED WHILE IT WAS PROPOSED FOR REFERRAL WITH OTHER INSTANCES OF SELLING AND OFFERING FOR SALE GASOLINE WHICH WAS ABOVE THE STANDARD BUT BELOW THE TOLERANCEBY THIS TERMINAL. ULTIMATELY, SINCE THE RFG QS&AS EXPLICITLY ALLOWED THIS PROCEDURE, IT WAS DECIDED THAT EPA WOULD INSTEAD ISSUE A NEW Q/A LATER THIS FALL WHICH WILL CLARIFY THE SITUATION. THE NEW Q/A WILL ESSENTIALLY RECAPITULATE THE SAME PREVENTION STEPS DETAILED BELOW AND