FACILITY WAS ALLEGED TO VIOLATE RCRA SUBPART BB MONITORING REQUIREMENTS DUE TO THE FAILURE TO MONITOR AND KEEP RECORDS. FACILITY FAILED TO CONDUCT MONTHLY MONITORING FROM 12/96 UNTIL 7/98. FROM 7/98 UNTIL COMPLIANT THE FACILITY LARGELY COMPLIED WITH THE REQUIREMENT BUT FAILED TO IDENTIFY AND MONITOR A SIGNIFICANT NUMBER OF VALVES AND OTHER PIECES OF EQUIPMENT. PENALTY WAS REDUCED FROM INITIAL COMPLAINT DUE TO NEW INFORMATION WHICH INDICATED THAT THE FACILITY FAILED TO MONITOR FEWER POINTS THAN ALLEGED IN THE COMPLAINT. IN ADDITION THE ECONOMIC BENEFIT OF NONCOMPLIANCE COMPONENT WAS NOT SOUGHT BY EPA DUE TO ACTUAL COST DATA WHICH SUGGESTED THAT THE AMOUNT WAS MINOR.