ON MAY 19, 1999, AN RFG INSPECTION WAS CONDUCTED AT WILLIA MS PIPELINE COMPANY TERMINAL, IN ST. PETERS, MO FOUND THE RE GULAR UNLEADED GASOLINE IN TANK 1422 HAD A VOC EMISSIONS PER FORMANCE REDUCTION OF 27.12% WHICH IS LESS THAN THE MINIMUM STANDARD OF 32.6% FOR VOC CONTROL REGION 1. FOLLOW-UP INVES TIGATION REVEALED THAT ALTHOUGH WILLIAMS HAD BEEN INFORMED B Y CONOCO ON APRIL 19 OF CONVENTIONAL GASOLINE IN THE PIPELIN E, WILLIAMS ALLOWED THE CG TO BE MIXED WITH A SHIPMENT OF R FG INTO TANK 1422 ON MAY 1, CAUSING THE VIOLATION. THERE WE RE 733,152 GALLONS IN TANK 1422 ON MAY 1, 1999. ON MAY 17 ( PRIOR TO THE EPA INSPECTION), WILLIAMS LEARNED FROM A CORREC TED LAB RESULT THAT THE PRODUCT WAS OUT OF COMPLIANCE AND IM MEDIATELY SHUT DOWN THE TANK. WILLIAMS SOLD 569,478 GALLON S BETWEEN MAY 1 AND MAY 17. SINCE WILLIAMS DISCOVERED THE V IOLATION PRIOR TO EPA'S INSPECTION, STOPPED SALES AND ATTEMP TED TO RECOVER AS MUCH OF THE VIOLATING PRODUCT AS POSSIBLE (SEE BELOW), THE PENALTY WAS BASED ON THE VOLUME OF GASOLINE SOLD, RATHER THAN THE TOTAL GALLONS IN THE TANK AS IS OUR U SUAL METHOD. RESPONDENT ADMITS THE VIOLATION AND HAS CHANGE D THEIR REPORTING SYSTEM FOR LABORATORY RESULTS TO PREVENT T HIS VIOLATION FROM HAPPENING IN THE FUTURE. . ON MAY 22, WIL LIAMS TESTED THE GASOLINE BEING SOLD AT THE 11 RETAIL STATIO NS WHICH HAD RECEIVED PRODUCT FROM TANK 1422 AND PUMPED OUT 49,338 GALLONS FROM THE 7 STATIONS WHOSE PRODUCT TESTED AS O UT-OF-COMPLIANCE. WILLIAMS ADDITIONALL