10/20/97 TWO RFG VIOLATIONS. ON AUGUST 9, 1996, EPA INSPECTORS FOUND EVIDENCE OF MIS-DELIVERY OF TWO GRADES OF HIGH VOLATILITY GASOLINE TO THE BIGG O RETAIL GASOLINE FACILITY IN ARLINGTON, TN. EPA FURTHER DETERMINED THAT RESPONDENT WAS A DISTRIBUTOR OF GASOLINE TO THESE RETAIL OUTLETS, MAKING RESPONDENT LIABLE FOR THE VIOLATIONS PURSUANT TO 40 CFR 80.28. TRUMAN ARNOLD COMPANY ( RESPONDENT ) CHECKED THEIR RECORDS AND FOUND A BILL OF LADING SHOWING THE DELIVERY OF TWO GRADES OF 9.0 GASOLINE. RESPONDENT ADMITTED TWO MISDELIVERIES ON 9.0 GASOLINE INTO A 7.8 AREA. SETTLEMENT RECOVERS 75% OF PROPOSED PENALTY, BASED ON RESPONDENT'S PROMPT REMEDIAL ACTIONS.