'3/25/02 - Complaint filed, proposing a penalty of $72,670. Respondent failed to notify or submit a notice to either TDEC UST Division or EPA within 30 days of bringing into use UST systems; in violation of Section 9003 of RCRA. Respondent failed to comply with the UST system release detection requirements for UST systems; in violation of Section 9003 of RCRA. Respondent failed to upgrade or permanently close UST systems prior to the December 22, 1998 deadline. Respondent failed to permanently close and assess the site for releases after 12 months of temporary closure; in violation of Section 9003 of RCRA.'