This is a consolidated case involves violations of both the CWA and RCRA. Defendant has failed to comply with cathodic protection, release detection, and record-keeping requirements for UST systems under Section 9003 of RCRA, and has failed to prepare and fully implement an SPCC plan for its above ground storage tanks under Section 311 of CWA. We are seeking compliance, within a set timeframe, for both the UST (30 days)and SPCC (90 days) violations that were found at Erie's facilities, and payment of a penalty.