On September 19, 2018 the Regional Judicial Officer ratified a combined Complaint and Consent Agreement ( CAFO ) between EPA Region III and 3951 Roosevelt Blvd. Realty Corporation ( 3951 ) and Liberty Tradeplus, Inc. ( LTI')(collectively, Respondents ). 3951 is a Pennsylvania corporation and real estate management company with a business address of 439 S. Governor Prince Blvd., Essington, Pennsylvania, that owns petroleum underground storage tank systems ('USTs ) at a gasoline service station and convenience store facility located 3951 Roosevelt Boulevard, Philadelphia, PA 19124 (the AF-Street Sunoco Facility or the Facility ). LTI a Pennsylvania corporation and gasoline service station/convenience store operator that operates the F-Street Sunoco Facility. The CAFO settles and resolves violations of RCRA Subtitle I and of federally-authorized Pennsylvania Authorized UST Management Program regulations which occurred at the Facility. As a result of September 28, 2017 Facility compliance evaluation inspection, and a subsequent investigation, EPA alleged that the Respondents violated 25 PA Code 245.442(1) tank release detection requirements by failing to comply with the applicable tank release detection Statistical Inventory Reconciliation ( SIR ) report availability requirements of 25 PA Code 245.444(8)(ii)(A), or to otherwise fully comply with the requirements of any of the other available tank release detection methods, with respect to two of the three USTs at the F-Str