INSPECTED BY: BIONETICS INSPECTION REASON: DETERGENT AUDIT INSPECTION DATE: NO. OF VIOLATIONS: DETERGENT AUDIT FOUND SEVERAL VAR AND RECORD VIOLATIONS. AT ONE OF ITS TERMINALS, THIS RESPONDENT FAILED TO ATTAIN TH E DETERGENT'S LAC IN ITS GASOLINE FOR 3 MONTHS IN 1997, RESU LTING IN THE UNDERADDITIZATION OF 5,200,000+ GALLONS OF GASO LINE. RESPONDENT ALSO FAILED TO CREATE MONTHLY VAR RECORDS FOR 23 MONTHS. RESPONDENT AGREED TO PAY 60% OF ITS PROPOSED NOV PENALTY, WHICH MORE THAN COMPENSATED FOR THE ECONOMIC BE NEFIT ATTAINED. RESPONDENT HAS UNDERTAKEN EXHAUSTIVE PREVENT ATIVE ACTION.