COMPLAINT FILED 9/30/98 PROPOSING A PENALTY OF $75,197. COMPLAINT ALLEGES: COUNT I RESPONDENTS FAILED TO PROVIDE ADEQUATE SECONDARY CONTAINMENT FOR THE UNDERGROUND PIPING COMPONENT OF A HAZARDOUS SUBSTANCE UST SYSTEM AND FAILED TO RELEASE DETECTION, IN VIOLATION OF 40 C.F.R. SECTION 280.42(B)(4). RESPONDENT FAILED TO PERMANENTLY CLOSE THE SUBSTANDARD UST SYSTEM AFTER 12 MONTHS OF TEMPORARY CLOSURE, IN VIOLATION OF 40 C.F.R. SECTION 280.70(C).