'1. SUBTITLE I OF THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 ( RCRA ), 42 U.S.C. SECTION 6912 ET SEQ. 2. ARKANSAS VALLEY ASSOCIATION 704 WEST C STREET RUSSELLVILLE, POPE COUNTY, ARKANSAS 72801 3. RESPONDENT WAS IN VIOLATION OF SECTION 9003 OF RCRA BY 1) FAILURE TO PERFORM REPLACEMENT, UPGRADE OR CLOSURE FOR EXISTING SUBSTANDARD UST SYSTEM; 2) FAILURE TO PROVIDE ADEQUATE RELEASE DETECTION METHOD FOR TANK; AND 3) FAIL- URE TO PROVIDE RELEASE DETECTION OR SINGLE CHECK VALVE AT DISPENSER FOR SUCTION PIPING SYSTEM. 4. RELIEF SOUGHT PURSUANT TO SUBTITLE I OF RCRA, EPA ASSESS- ED THE RESPONDENT A CIVIL PENALTY OF $1,900 FOR THE VIO- LATIONS CITED AND ISSUED THE RESPONDENT A COMPLIANCE ORDER TO CORRECT THE VIOLATIONS.'