VIOLATIONS: 1) Failure to properly follow the monitoring test procedure(s) prescribed for method 21 for the leak monitoring of subject valves within the Rheinformer Process Unit; 2) Failure to comply with Standards for Open-ended valves or lines for 10 valves in VOC or VHap service; and 3) Exceeding its permit limit for annual emissions of SO2 for calendar year 2000. RELIEF SOUGHT: EPA is seeking injunctive relief and a civil penalty. the settlement will be part of the EPA's National Petroleum Refinery Initiative.