RESPONDENT SELF-REPORTED 114 VIOLATIONS OF CERCLA PARA 103 AND 288 VIOLATIONS OF EPCRA PARA 304. THE AUDIT POLICY WAS FOUND TO BE APPLICABLE THE GRAVITY-BASED PORTION OF THE PENALTY WAS WAVIED, AND RESPONDENT AGREED IN A CONSENT AGREEMENT/CONSENT ORDER TO PAY $52,653 FOR THE ENCONOMIC BENEFIT PORTION OF THE PENALTY. THE CURRENT OWNER/OPERATOR OF THE FACILITY CERTIFIED URRENT COMPLIANCE WITH CERCLA PARA 103 AND EPCRA.