'In April 2001 Dobson Cellular Systems and American Cellular Corporation (Respondents) notified EPA that it had possible noncompliance with EPCRA reporting, RCRA UST, and CWA (SPCC plans) requirements. From April to November, Respondents evaluated their facilities and corrected violations. Upon completion of their evaluation, they provided EPA information concerning 1) violations of EPCRA ??302, ??303, ??311, and ??312 related to the presence of sulfuric acid and lead at 23 facilities located in 15 states (KS, MO, OK, MD, GA, OH, PA, MI, AZ, CA, KY, NY, TN, WV, WI), 2) violations of CWA ??311 - SPCC related to the presence of ASTs at 4 facilities located in 3 states (OH, PA, AZ), 3) RCRA ??9002 and ??9003 - UST related to the presence of USTs at 4 facilities located in MN, and 4) CAA ??110 - SIP related to the presence of back-up generators at 3 facilities located in 3 states (PA, AZ, CA).
The administrative settlement requires Respondents to pay a civil penalty of $9,843 which represents the economic benefit, and to fully comply with EPCRA ($7,319), RCRA ($1,309), CWA ($1,062), and CAA ($153). The gravity component of the civil penalty would have been $677,735