The United States Environmental Protection Agency ( EPA ) and Ross Stores, Inc.( Respondent ) agree to settle this matter and consent to the entry of this Consent Agreement and Final Order ( CAFO ). This CAFO simultaneously initiates and concludes this proceeding in accordance with 40 C.F.R. Sections 22.13(b) and 22.18(b). Respondent consents to the assessment of a civil administrative penalty in the amount of $55,000 as final settlement and complete satisfaction of the civil claims against Respondent arising from the facts alleged in Section I.C of the CAFO and under the Act. In executing this CAFO, Respondent certifies that the information it has supplied concerning this matter was at the time of submission, and is at the time of signature to this CAFO, truthful, accurate, and complete; and that Respondent has corrected the violations alleged in Section I.C of this CAFO.