THE FACILITY HAS MANY TANKS AND TWO DISTILLATION SYSTEM UNITS AND DID NOT HAVE A COMPREHENSIVE SUBPART AA, BB & CC PROGRAM. THREE COUNT COMPLAINT FILED ON SEPTEMBER 28, 2001, ALLEGING (1) FAILURE TO CONDUCT MONTHLY MONITORING OF PUMPS AND VALVES (40 CFR 265.1052, 1057); (2) FAILURE TO CLOSE CLOSURE DEVICE ON TANK (40 CFR 265.1085); (3) FAILURE TO MARK EQUIPMENT (40 CFR 265.1050).