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RCRA CIVIL PENALTY POLICY RCRA Enforcement Division Office of Regulatory Enforcement Office of Enforcement and Compliance Assurance EPA June 2003 RCRA CIVIL PENALTY POLICY TABLE OF CONTENTS I. SUMMARY OF THE POLICY .. 1 II. INTRODUCTION .. 4 III. RELATIONSHIP TO AGENCY PENALTY POLICY .. 6 IV. DOCUMENTATION AND RELEASE OF INFORMATION .. 7 A. DOCUMENTATION FOR PENALTY SOUGHT IN ADMINISTRATIVE LITIGATION .. 7 B. DOCUMENTATION OF PENALTY SETTLEMENT AMOUNT .. 9 OF INFORMATION .. 9 V. RELATIONSHIP BETWEEN PENALTY AMOUNT SOUGHT IN AN ADMINISTRATIVE ACTION AND ACCEPTED IN SETTLEMENT.

the circumstances, and (2) for days of violation after the first 180, as needed to achieve deterrence. Where a company has derived significant savings or profits by its failure to …

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