THIS IS ONE OF THIRTEEN (13) INDIVIDUAL SETTLEMENTS ENTERED INTO PRUSUANT TO AN EXPEDITED SETTLEMENT AGREEMENT (ESA) STRATEGY APPROVED BY OECA TO ADDRESS VIOLATIONS OF CLEAN AIR ACT STAGE I AND STAGE II VAPOR RECOVERY STANDARDS, WHICH ARE FEDERALLY ENFORCEABLE THROUGH THE PENNSYLVANIA STATE IMPLEMENTATION PLAN ( SIP ), AT GAS STATIONS IN PHILADELPHIA, PA AND SURROUNDING COUNTIES. SPECIFIC VIOLATIONS INCLUDED FAILURE TO MAINTAIN VAPOR RECOVERY EQUIPMENT AND ENSURE THAT UNCOVERED GASOLINE WAS REMOVED AND/OR COVERED, AND RECORDKEEPING AND LABELING VIOLATIONS.
PURSUANT TO THE EXPEDITED SETTLEMENT STRATEGY, EACH VIOLATING FACILITY WAS SENT A STREALINED SUPER CAFO WHICH SETS FORTH ALLEGED VIOLATIONS AND A PROPOSED CIVIL PENALTY. THE CIVIL PENALTIES FOR EACH ASE WERE CALCULATED WITH CONSIDERATION OF THE PENALTY ASSESSMENT CRITERIA SET FORTH IN SECTION 113(c) OF THE CLEAN AIR ACT, 42 U.S.C. SUBSECTION 113(e).