1) FAILURE TO PROVIDE A METHOD OF RELEASE DETECTION; 2) FAILURE TO UPGRADE BY DEC. 22, 1998; AND 3) FAILURE TO TEMPORARILY CLOSE. * AMENDED COMPLAINT ISSUED ON 12/20/00. THE AMENDED COMPLAINT LOWERED THE PROPOSED PENALTY FROM $37,221 TO $15,396.50. * WHEN THE FO IS EXECUTED THE AMENDEMENT WILL CLOSE WITH THE DATE OF THE FO. *