ON SEPTEMBER 28, 2001, A COMPLAINT, COMPLIANCE ORDER AND NOTICE OF OPPORTUNITY FOR HEARING ( COMPLAINT ) WAS FILED BY REGION III PURSUANT TO THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976, AS AMENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984 (COLLECTIVELY RCRA ), 42 U.S.C. SECTION 6991E. THE COMPLAINT ALLEGGES VIOLATION S OF EPA'S TECHNICAL STANDARDS AND CORRECTIVE ACTION REQUIREMENTS FOR OWNERS AND OPERATORS OF UNDERGROUND STORAGE TANKS ( UST REGULATIONS ), 40 C.F.R. PART 280, PROMULGATED PURSUANT TO SUBTITLE I OF THE RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA ), 42 U.S.C. SECTION 6991-6991I. THE COMPLAINT WAS FILED AGAINST THE OWNER, MCEWEN OIL COMPANY INC ( RESPONDENT ) FOR VIOLATIONS REGARDING THE FACILITY KNOWN AS BARN'S SERVICE STATION ( THE FACILITY ). THE FACILITY IS LOCATED AT INTERSTATE # 79 AND ROUTE #62 IN MERCER COUNTY JACKSON CENTER, PENNSYLVANIA. THE VIOLATIONS AT THE FACILITY CONCERN RESPONDENT'S FAILURE TO MAINTAIN AND PROVIDE TO EPA RECORDS REGARDING THE OPERATION AND MAINTENANCE OF CORROSION PROTECTION FOR UST'S AT THE FACILITY; RESPONDENT'S FAILURE TO MAINTAIN, PERFORM AND/OR PROVIDE RELEASE DETECTION FOR USTS AT THE FACILITY; RESPONDENT'S FIALURE TO MEET THE PERFORMANCE STANDARDS FOR AN EXISTING UST SYSTEM; RESPODNENT'S FAILURE TO COMPLY WITH THE STANDARDS NECESSARY FOR TEMPORARY CLOSURE AND RESPONDENT'S FAILURE TO PERMANENTLY