PREET PETROLEUM, A RETAIL OUTLET, WAS DISCOVERED DURING A RANDOM INSPECTION TO HAVE VIOLATED THE APPLICABLE RFG STANDA RDS FOR MINIMUM VOC-EPR. FOLLOW UP INSPECTIONS AT DISTRIBUT OR/RESELLER, U.S. OIL CO., INC., AND REFINER, CLARK REFINING AND MARKETING, INC., DETERMINED THAT A BATCH OF ETHANOL RBO B FOR VOC REGION 2, EPA BATCH #09-000224, MANUFACTURED BY CL ARK AND THE MAJORITY OF WHICH WAS DISTRIBUTED BY U.S. OIL, F AILED TO MEET THE RFG STANDARD FOR VOC EPA SPECIFIED IN 40 C .F.R. 80.41. IN PARTICULAR, THE BATCH OF 87 OCTANE REGULA R GRADE RBOB, WHICH CONSISTED OF 891,925 GALLONS, HAD A VOC- EPR OF 10.35 % INSTEAD OF A MINIMUM VOC EPR OF 13.1%. AS TH E REFINER WHO MANUFACTURED AND/OR SOLD THE GASOLINE FOUND TO BE IN VIOLATION, CLARK IS LIABLE FOR VIOLATION OF 40 C.F.R. 80.78(A)(1) PURSUANT TO 40 C.F.R. 80-79(A)(3). AS THE D ISTRIBUTOR/RESELLER WHO TRANSPORTED AND STORED, AND/OR CAUSE D THE TRANSPORTATION OR STORAGE, OF THE GASOLINE FOUND TO BE IN VIOLATION, U.S. OIL IS LIABLE FOR VIOLATION OF 40 C.F.R. 80.78(A)(1) PURSUANT TO 40 C.F.R. 80.79(A)(3). NOTICES OF VIOLATION WERE ISSUED TO PREET PETROLEUM (AED # 5 042) WITH A PROPOSED PENALTY OF $26,800, AND TO U.S. OIL, IN C. (AED #5043) WITH A PROPOSED PENALTY OF $24,000. BOTH CAS ES WERE SETTLED AND SETTLEMENT AGREEMENTS ENTERED INTO. PRE ET PETROLEUM, NEWLY NAMED THE PREMCOR REFINING GROUP INC., E NTERED INTO A SETTLEMENT AGREEMENT, RATIFIED BY EPA ON 9/18/ 00, AND PAID $26,800 BY CHECK RECEIVED