THE COMPLAINTS ALLEGES VIOLATIONS OF SUBTITLE I OF RCRA, 42 U.S.C. SECTION 6991-6991I AND THE STATE OF MARYLAND'S AUTHROIZE UNDERGROUND STORAGE TANK PROGRAM. THE COMPLAINTS ARE FILED AGAINST THE OPERATOR, CLARK AUTOMOTIVE SERVICES, INC. ( CLARK OR RESPONDENT ), AND THE OWNER, EUCLID OF VIRGINIA INC. ( EUCLID OR RESPONDENT ) FOR VIOLATIONS AT THE FACILITY, CLOVERLY AUTO CARE ( THE FACILITY ), FORMERLY KNOWN AS THE LOWEST PRICE GAS & SERVICE CETNER . THE FACILITY IS LOCATED AT 15501 NEW HAMPSHIRE AVENUE IN SILVER SPRING, MARYLAND. RESPONDENTS FAILED TO MAINTAIN THE RECORDS FOR ITS USTS AT THE FACILIT, OR TO HAVE SUCH RECORDS AVAILABLE FOR INSPECTION, OR TO PROVIDE THE RECORDS TO THE STATE OF MARYLAND OR EPA UPON REQUEST. IN ADDITION, RESPONDENTS FAILED TO INSTALL SPILL AND OVERFILL PROTECTION EQUIPMENT FOR THE USTS AT THE FACILITY. EPA PROPOSES IN ITS COMPLAINTS THE ASSESSMENT OF A CIVIL PENALTY OF UP TO $11,000 PER DAY AGAINST EACH RESPONDENT, FOR EACH OF THE ALLEGED VIOLATIONS OF EPA'S TECHNICAL STANDARDS AND CORRECTIVE ACTION REQUIREMENTS FOR OWNERS AND OPERATORS OF UNDERGROUND STORAGE TANKS ( USTS REGULATIONS ).