EPA determined that the Respondent failed to comply with the following UST requirements - financial responsibility for UST systems (40 C.F.R. 280.93); overfill prevention equipment (40 C.F.R. 280.20(c)(l)(ii)); investigate and confirm a suspected release (40 C.F.R. 280.52); conduct periodic walkthrough inspections (40 C.F.R. 280.36(a)); monitor tanks for releases (40 C.F.R. 280.41(a)); annually test automatic line leak detectors (40 C.F.R. 280.44(a)); conduct initial testing of spill and overfill prevention equipment and containment sumps (40 C.F.R. 280.35(b)(1)); and maintain documentation of compliance with release detection requirements (40 C.F.R. 280.34(b)(7)). The violations were settled through an administrative enforcement action with a penalty of $140,000.