Respondent failed to comply with upgrade requirements by the required date, December 22, 1998. In addition, respondent failed to comply with release detection requirements. 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 a multi-facility owner and has facilities in different states. This CAFO was negotiated and finalized without the issuance of a complaint.