This CAFO was negotiated without the issuance of a complaint. The penalty was negotiated to be $120,000. However, this penalty will be a monetary penalty of $30,000 and a SEP in the amount of $90,000 (which really cost the respondent to $112,500). The agency will be gaining much more through the sep as opposed to having a monetary penalty. Respondent failed to comply with release detection and cathodic protection requirements at all its facilities. Under this order he is required to certify compliance at all his facilities. Under this CAFO, he's also required to conduct training for his employees that handled the UST systems at all his facilities. He's also required to conduct assessments at idle properties in Puerto Rico.This CAFO was negotiated and finalized without the issuance of a complaint.