THIS CASE IS ONE OF TWELVE ENFORCEMENT ACTIONS FOR CASES INVOLVING VIOLATIONS BY VARIOUS GAS STATIONS LOCATED IN ALLEGHENY COUNTY, PA OF THE ALLEGHENY COUNTY REGULATIONS WHICH CONTAIN THE REQUIREMENTS FOR GAS STATIONS SUBJECT TO THE CLEAN AIR ACT'S STAGE II VAPOR RECOVERY PROGRAM. A SUPER CONSENT AGREEMENT AND FINAL ORDER WAS DEVELOPED BY REGION III TO FORMALIZE INDIVIDUAL SETTLEMENTS PURSUANT TO AN EXPEDITED SETTLEMENT AGREEMENT STRATEGY. PURSUANT TO THE ESA STRATEGY, EACH VIOLATION FACILITY WAS SENT A STREAMLINED SUPER CAFO WHICH SETS FOR ALLEDGED VIOLATONS AND A PROPOSED CIVIL PENALTY. THE CIVIL PENALITES FOR EACH CAS WERE CALCULATED IN ACCORDANCE WITH CONSIDERATION OF THE PENALTY ASSESSMENT CRITERIA.