Respondent is a for-profit corporation organized under the laws of the Commonwealth of Puerto Rico, and is a wholly owned subsidiary of Total Marketing Services of France. Respondent is engaged in the wholesale distribution of petroleum products, including gasoline and aviation fuel supply for airports in Puerto Rico and the USVI. In 2015 and 2016, EPA inspected three fuel terminals, operated by the Respondent, located in St. Thomas and Puerto Rico, and identified multiple violations related to the management of hazardous waste and universal waste. Consequently, EPA issued a Complaint, Compliance Order and Notice of Opportunity for Hearing, including a penalty of $543,203.85, requesting the Respondent to address the violations found at its facilities.