RESPONDENT UNBRANDED RETAIL OUTLET IS LOCATED IN A VOC CON TROL REGION 2 AREA WHERE THE MINIMUM VOC-EMISSIONS PERFORMAN CE REDUCTION IS 13.1%. WHEN TESTED THE 93 OCTANE GASOLINE H AD A VOC-EPR OF 8.39%. THE VIOLATION WAS ATTRIBUTED TO LOW TURNOVER. ON JUNE 9, 1998, EPA REPRESENTATIVES CONDUCTED A REFORMULATE D GASOLINE ( RFG ) RANDOM INSPECTION OF RESPONDENT'S UNBRAND ED RETAIL OUTLET. RESPONDENT'S RETAIL OUTLET IS LOCATED AT 2755 WEST 87TH STREET, EVERGREEN PARK, ILLINOIS, AN AREA COV ERED UNDER THE RFG PROGRAM DURING THE VOC CONTROL PERIOD. R ESPONDENT FAILED TO MEET THE APPLICABLE RFG STANDARD IN VOC CONTROL REGION 2 OF 13.1% MINIMUM. THE TEST RESULT FROM THE INSPECTION WAS 8.39%. THE VIOLATION HAS BEEN ATTRIBUTED TO LOW TURNOVER. THE NOV WAS ISSUED ON AUGUST 19, 1999, WITH A PROPOSED PENAL PENALTY OF $5,100. THE MAXIMUM ECONOMIC BENEFIT FOR THE DO CUMENTED VIOLATION IS $16.00 AS PER THE RFG SPREADSHEET. RE SPONDENT EXPLAINED THAT THE STANDARD PRACTICE OF GAS CITY, L L TD., IS TO REDUCE THE TANK TO BELOW 20% CAPACITY AT LEAST TW ICE BETWEEN MAY 1ST AND JUNE 1ST IN ORDER TO TURNOVER THE TA NKS SUFFICIENTLY. IN THIS CASE, HOWEVER, DUE TO AN OVERSIGH T, THE TANK WAS REDUCED TO BELOW 20% CAPACITY ONLY ONCE IN T HE MONTH OF MAY, HENCE THE LOW TURNOVER. THE PROPOSED PENAL TY WAS MITIGATED TO $4,000.