RESPONDENT FAILED TO DO RELEASE DETECTION FOR UST #1 FROM AT LEAST NOVEMEBER 29, 2005 THROUGH MAY 4, 2006 AND FROM DECEMBER 1, 2007 THROUGH APRIL 3, 2008.
RESPONDENT ALSO FAILED TO MAINTAIN UST RELEASE DETECTION RECORDS FOR THE FACILITY FROM NOVEMBER 1, 2008 THROUGH APRIL 1, 2010.