IN FEB. 1998, SWBT, NOTIFIED EPA THAT IT HAD IDENTIFIED, THR OUGH ITS CORPORATE DUE DILIGENCE POLICY, POSSIBLE VIOLATIONS OF THE SPCC REGULATIONS OF THE CWA. SWBT IDENTIFIED 117 SI TES OUT OF COMPIANCE. THE FACILITIES ARE LOCATED IN AR (19) , KS (9), MO (21), OK (16) AND TX (52). RESPONDENT FAILED TO PREPARE AN SPCC PLAN AT ALL OF THESE FACILITIES.