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 PROPERLY CONDUCT LINE TIGHTNESS TEST OR USE MONTHLY MONITORING ON SUCTION PIPING; FAILURE TO PERMANENTLY CLOSE OR UPGRADE A TEMPORARILY CLOSED UST SYSTEM AFTER 12 MONTHS; AND FAILURE TO COMPLY WITH FINANCIAL RESPONSIBILITY REQUIREMENTS.