THE DEFENDANT, R & R DISTRIBUTING CO., INC. IS A TENNESSEE CORPORATION AND A PETROLEUM DISTRIBUTOR WHO DELIVERS PETROLEUM PRODUCTS TO UST SYSTEMS. R & R IS THE OWNER AND/OR OPERATOR OF APPROX. 74 USTS AT 33 FACILITIES IN THE COLUMBIA, TN, AREA. MOST OF THESE FACILITIES CONSIST OF SMALL TO MEDIUM SIZED CONVENIENCE STORES AND GAS STATIONS. 19 OF R & R'S FACILITIES ARE IN VIOLATION OF NUMEROUS REQUIREMENTS OF THE UST REGS AT 40 CFR PART 280. THE VIOLATIONS INCLUDE LEAK DETECTION/CLOSURE REQUIREMENTS, AND DEMONSTRATION OF FINANCIAL RESPONSIBILITY