On September 30, 2004, EPA Region III filed a Complaint, Compliance Order and Notice of Opportunity for Hearing ( Complaint ) against Duncan Petroleum Corporation ( Duncan ), a gasoline wholesaler, of Dover, Delaware. The Complaint alleges that Duncan violated Subtitle I of RCRA by failing to comply with the State of Marylandýýýs federally authorized underground storage tank ( UST ) regulations at Duncan's Super Soda Centers located in Federalsburg, Easton, Preston, Cambridge and Chestertown, Maryland. Duncan's alleged violations include failure to: properly monitor its USTs for releases (leaks); report suspected releases from its USTs to the Maryland Department of the Environment; investigate and confirm suspected releases from its USTs; operate and/or maintain a release detection system in accordance with the manufacturer's instructions; and periodically test and inspect a cathodic (corrosion) protection system. The Complaint proposes the assessment of a civil penalty of up to $11,000 for each tank for each day of alleged violation and includes a compliance order.