Complaint filed with multiple violations of Subtitle I of RCRA at twenty-three Lowest Price gas stations owned by Euclid in Maryland, Virginia and the District of Columbia. The violations, which relate to seventy-two different underground storage tanks ( USTs ), involve the failure to maintain equipment and perform activities required to prevent leaks of petroleum products into the environment and to detect and minimize leaks if they occur. The complaint alleges that Euclid failed for various periods of time to maintain equipment or perform activities at the twenty-three facilities to detect leaks from underground tanks and/or piping. In addition, the complaint alleges that at certain facilities Euclid failed to comply with required standards for the prevention of corrosion, fialed to install and/or maintain equipment to prevent spills from occurring when tanks are filled, and failed to report to the appropriate state agency when monitoring results indicated that a leak may have occurred. Finally, the complaint alleges that Euclid failed to maintain financial assurances for its District of Columbia facilities, a requirement designed to ensure that sufficient resources are available to correct damage to the environmental should it occu