Under EPA's Audit Policy, Respondent disclosed that for UST Tank #019 at the Canandaigua VA facility the leak detection system was not maintained or calibrated, and had been out of service for a year. Respondent committed in its audit agreement to resolve the violation no later than January 2006. Inspection by EPA in April 2007, as required under the Energy Policy Act, found no release detection records before January 2007.