THIS IS A UST COMPLAINT AND CONSENT AGREEMENT/FINAL ORDER ISSUED FOR THE FOLLOWING VIOLATIONS: FAILURE TO PERFORM REPLACEMENT, UPGRADE OR CLOSURE FOR EXISTING SUBSTANDARD TANK SYSTEM; FAILURE TO PROVIDE ADEQUATE RELEASE DETECTION METHOD FOR PETROLEUM TANKS; FAILURE TO PROVIDE ANY RELEASE DETECTION FOR UNDERGROUND PIPING; AND FAILURE TO COMPLY WITH FINANCIAL RESPONSIBILITY REQUIREMENTS.