Both the Raceway Old Bridge and Franklin Park facilities failed to upgrade its USTs, and Raceway Respondents failed to submit a required statement as outlined in a July 2001CAFO 2) EPA is seeking the statutory max on all three counts: $11,000/day/tank for Counts 1 and 2 and $27,500/day for Count 3.
1) Failure to upgrade or close USTs. (USTs were closed)
2) failure to comply with CA/FO requirement for submission of tax deduction certification. (Certification submitted.)