On January 29, 2020, a Consent Agreement and Final Order entered into by the U.S. Environmental Protection Agency, Region III ( EPA ) and National Retail Properties Trust ( Respondent ) was filed with the Regional Hearing Clerk settling alleged violations of the Resource Conservation and Recovery Act ( RCRA). The alleged violations, discovered as a result of 2017 inspections conducted by or on behalf of the Pennsylvania Department of Environmental Protection and 2018 inspections conducted by EPA at seven (7) UST facilities owned by Respondent across Pennsylvania. The violations include failure to conduct line leak detector testing, secondary piping release detection, investigation of suspected release, cathodic protection testing, line leak detector and tank release detection violations at the facilities. Fundamental goals of RCRA Subtitle I and implementing UST regulations are to prevent releases and limit harm from USTs that release regulated substances. Respondent's failures related to tank and piping detection increased the risk that a leak would go undetected. Respondent's failure to investigate a suspected release increased the risk of harm to human health and the environment should an actual release have taken place. Similarly, Respondent's failure to test its cathodic protection system increased the risk a release may occur due to corrosion, which could also cause harm to human health and the environment. According to the CAFO, Respondent is assessed a penalty in