THE GREATER CLEVELAND REGIONAL TRANSIT AUTHORITY ( GCCRTA ) IS THE OWNER AND OPERATOR OF TWENTY UNDERGROUND STORAGE TANKS AND/OR SYSTEMS AT THREE MASS TRANSIT FACILITIES LOCATED IN CLEVELAND, OHIO. CONSEQUENT TO INFORMATION PROVIDED BY THE OHIO BUREAU OF UNDERGROUND STORAGE TANKS REGULATION, U.S. EPA COMPLIANCE INSPECTIONS AND INFORMATION REQUESTS ISSUED PURSUANT TO 42 U.S.C. SECTION 9005, U.S. EPA DETERMINED THAT THE GCRTA COMMITTED TWENTY ONE VIOLATIONS RCRA SUBTITLE I UNDERGROUND STORAGE TANK REGULATIONS, INCLUDING VIOLATIONS OF SPILL PREVENTION, RELEASE DETECTION, TESTING, NOTIFICATION, CONSTRUCTION, AND CLOSURE REQUIREMENTS. ACCORDINGLY, ON AUGUST 12, 1993, THE ASSOCIATE DIVISION DIRECTOR, U.S. EPA REGION V, ISSUED AN ADMINISTRATIVE COMPLAINT AND COMPLIANCE ORDER AGAINST THE GCRTA ALLEGING TWENTY ONE VIOLATION S OF RCRA SUBTITLE I UNDERGROUND STORAGE TANK REGULATIONS , INCLUDING SPILL PREVENTION, RELEASE DETECTION, TESTING, NOTIFICATION , CONSTRUCTION, AND CLOSURE REQUIREMENTS, AND SEEKING $222,504 IN PENALTIES.