STAR ENTERPRISE ( RESPONDENT ) IS A CORPORATION IN GOOD STANDING, IS INCORPORATED UNDER THE LAWS OF THE STATE OF NEW YORK AND IS HEADQUARTERED AT 2 PENN PLAZA, SUITE 1500, NEW YORK CITY, NEW YORK 10121. RESPONDENT IS AN OWNER AND OPERATOR OF UNDERGROUND STORAGE TANKS AND UNDERGROUND STORAGE TANK SYSTEMS ( USTS ) AS THOSE TERMS ARE DEFINED AT SEC. 9001 OF THE SWDA, 42 U.S.C. SEC. 6991, 40 C.F.R. 280.12. IN THE OPERATION OF ITS BUSINESS, RESPONDENT IS THE SOURCE OF AND PROVIDES EQUIPMENT AND MATERIALS FOR SALE TO CON- SUMERS IN THE FUEL MARKETING INDUSTRY THROUGH ITS CONVEN- IENCE STOES. RESPONDENT SUBMITTED DOCUMENTATION TO THE LA. DEPT. OF EN- VIRONMENTAL QUALITY TO REGISTER 4 USTS AT 5001 VETERANS BLVD., METAIRIE, LA. 70002 (HEREINAFTER REFERRED TO AS THE ( FACILITY ). THE USTS REGISTERED BY RESPONDENT INCLUDE USTS WITH INSTALL- ATION DATES OF 1984. ON MAR. 5, 1992, A DULY AUTHORIZED EPA REPRESENTATIVE ( THE INSPECTOR ) CONDUCTED AN INSPECTION ( THE INSPECTION ) OF 4 USTS AT THE FACILITY TO DETERMINE, INTER ALIA, RESPONDENT'S COMPLIANCE WITH RELEASE DETECTION REGULATIONS. VIOLATIONS: COUNT 1: RESPONDENT'S FAILURE TO IMPLEMENT THE REQUIRED RE- LEASE DETECTION SYSTEM IN ACCORDANCE