United States             National Enforcement
              Environmental Protection        Training Institute
              Agency                Washington, DC 20460
v>EPA      Litigating  Civil  Penalties

                  D  Strategies
                  D  Techniques
                  D  Tools
              Selected Resource  Materials
                     Internet Address (URL) •http://www.epa.gov

          Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (20% Postconsumer)

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                 PLEADING & LITIGATING CIVIL PENALTIES

            Administrative Law Desk Guide: Index of Resource Materials
               Regulations, guidance, policy and other important desk references
                           for all EPA administrative practitioners.
       This desk reference is intended to serve EPA administrative practitioners as a tool in
developing, litigating and/or settling cases.  This desk reference provides a list and a hard copy,
where appropriate, of regulations, EPA guidance documents, EPA policies and other materials that
are essential to the administrative practice of environmental law at EPA. There are numerous
policies, guidances, rules and statutes that have not been included on the list which may be
pertinent to  an individual case. These can be obtained in your regional library or via the EPA or
OECA internet homepage. The purpose of this desk reference is to provide the general essentials
for administrative practice at EPA.

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            INDEX OF SELECTED RESOURCE MATERIALS
(1) The Administrative Litigation Practice Network - EPA newsletter which reports on ALJ
and EAB decisions on a monthly basis. A sample copy is included	Page
(2) Procedural Rules

       (A) 40 CFR Part 22	page 8

       (B) The proposed "technical amendments and refinements" to 40 CFR Part 22, published
           in the federal register on February 25,1998. This proposed rule includes the new
           non-APA procedural rule, Subpart I. A copy of Subpart I is provided	page 39


(3) EPA Penalty Policies

    (A) General - The general penally policies are not media-specific but provide agency-wide
guidance for media programs to use in developing ERPs.. They discuss the EPA goal in proposing
and assessing penalties and provides a framework for the development of media-specific penally
policies.

             (I) Statutory Penalty Section Regarding
                Penalty Assessment	page 44

             (II) GM  21 "Policy on Civil Penalties"	page 46

             (III)  GM 22 "A Framework for Statute-Specific Approaches to Penalty
                Assessments"	page 55

             (TV)  Guidance on the Use of Penalty Policies in Administrative Litigation.
                  12/15/95. Gives language to insert into Complaints to reflect WAUSAU
                  decision	page 86

             (V)  "Impact on WAUSAU on Use of Penalty Policies" 3/19/97	page 90

             (VI)   "Modifications to EPA Penalty Policies to Implement the Civil Monetary
                    Penalty Inflation Rule(Pursuant to the Debt Collection Improvement Act
                    of 1996)" 5/9/97	page 92

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     (B) Statute Specific - The statute specific penalty policies (also called "Enforcement Response
Policies" or "ERPs") generally serve two distinct purposes. The policies explain how to calculate a
penalty for the purpose of proposing a penalty in the complaint.  Most of the policies also explain
the factors that may be considered in settling a case and explain how to calculate a settlement figure.
       (I) Clean Air Act - Mobile Sources
              1.  Volatility Civil Penalty Policy.  12/1/89
              2.  Interim Diesel Civil Penalty Policy. 2/8/94
              3.  Regulation of Fuels and Fuel Additives. 8/29/75
              4.  Manufacturers Program Branch Interim Penalty Policy. 3/31/93
              5.  Tampering and Defeat Device Civil Penalty Policy for Notices of Violations.
                     2/28/94
              6.  Lead Banking Penalty Policy and Revisions of Lead Usage and Reporting
                     Penalty Policy. 12/18/87

       (II) Clean Air Act - Stationary Sources
              1.  Clarifications to the 10/25/95 CAA Stationary Source Civil Penalty Policy.
                     1/17/92
              2.  Stationary Source Civil Penalty Policy. 10/25/91

       (III) RCRA
              1.  Civil Enforcement Response Policy.  3/15/96
              2.  RCRA Civil Penalty Policy. 10/90
              3.  Final U.S. EPA Penalty Guidance for Violations of UST Regulations. 11/14/90

       (IV) TSCA - Title I
              1.  Enforcement Response Policy for TSCA Section 4 Test Rules.  5/28/86
              2.  TSCA Good Laboratory Practices Regulations.  4/9/85
              3.  Amended TSCA Section 5 Enforcement Response Policy.  6/8/89
              4.  Recordkeeping and Reporting Rules TSCA Sections 8,12 and 13.  5/15/87
              5.  PCB Penalty Policy. 4/9/90

       (V) TSCA - Title II
              1.  Interim Final ERP for AHERA. 1/31/89
              2.  ERP for Asbestos Abatement Projects: Worker Protection Rules. 11/14/89

       (VI) TSCA - Title X
              1.  Residential Lead-Based Paint Hazard  Reduction Act of 1992;
                 Interim Enforcement Response Policy.                        1 /2/98
                                            ill

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       (VII) FIFRA
              1.  FIFRA Response Policy.  7/2/90
              2.  FIFRA Section 7(c) ERP.  2/10/86
              3.  FIFRA ERP Good Laboratory Practices. 9/30/91
              4.  FIFRA Worker Protection Standards.   Interim Final (12/97)

       (VIII) EPCRA
              1.  ERP for Section 313 of EPCRA and Section 6607 of the Pollution Prevention
                     Act. 8/10/92
              2.  Final Penalty Policy for Sections 302, 303, 304, 311, and 312 of EPCRA and
                     Section 103 of CERCLA. 6/13/90

       (IX) CERCLA
              1.  Final Penalty Policy for Sections 302, 303, 304, 311, and 312 of EPCRA and
                     Section 103 of CERCLA. 6/13/90

       (X) Safe Drinking Water Act
              1.  Interim Final UIC Program Judicial and Administrative Order Settlement
                     Penalty Policy — Underground Injection Control Guidance No. 79.
              9/27/93
              2.  New Public Water System Supervision Program Settlement Penalty Policy.
                     5/25/94

       (XI) Clean Water Act
              1.  Revised Interim Clean Water Act Settlement Penalty Policy.  2/28/95
              2.  Guidance on the Distinctions Among Pleading, Negotiating, and Litigating Civil
                    Penalties for Enforcement Cases Under CWA.  1/19/89
(4) Audit Policy - This series of guidance documents embody EPA's position on the granting of
enforcement discretion to entities that voluntarily discover, disclose and correct violations of
environmental requirements. The Audit Policy is intended for use solely in cases of settlement and
are not intended for cases which are litigated.

       (A)  "Restatement of Policies Related to Environmental Auditing" Federal Register
              7/28/94. Provided as background	page 116

       (B)  "Voluntary Environmental Self-Policing and Self-Disclosure Interim Policy
              Statement" Federal Register 4/3/95. Provided as background	page 122

       (Q  "Incentives for Self-Policing:  Discovery, Disclosure, Correction and Prevention of
             Violations" Final Policy Statement, Federal Register 12/22/95. For use by EPA
             during settlement only	page 126

          "Audit Policy Interpretive Guidance" 1/15/97
             * Qs&As	page 133

                                           iv

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(5) Supplemental Environmental Projects (SEP) Policy - In an effort to encourage pollution
prevention and environmental justice, the EPA developed a policy whereby a respondents
"willingness to conduct a "supplemental environmental project" would be considered as a penalty
reduction factor in the context of settlement.  What constitutes an acceptable project and how to
calculate the penalty reduction is set forth in the policy.

     (A) "EPA SEP Policy" 5/1/98	page 162

(6) Guidance on Enforcement for Small Businesses - The purpose of this policy is to promote
environmental compliance among small businesses by providing incentives for participation in
compliance assistance programs and encouragin g prompt correction of violations. Specifically,
EPA announced that it would exercise its enforcement discretion, under applicable media-specific
policies, to refrain from initiating an enforcement action or to mitigate penalties whenever a small
business makes a good faith effort to comply and there is no criminal behavior and no significant
health, safety or environmental threat.

     (A)  "Interim Policy on Compliance Incentives for Small Businesses" Federal Register
          6/23/95. Effectuates Clinton's 4/26/95 Executive Memo on Regulatory Reform.
          Identifies that in 1997 EPA will consider whether to continue, modify, or
          discontinue program	page 184

     (B)  "Qs and As on Interim Policy on Compliance Incentives for Small Businesses"
          9/19/95. Provides mitigation to small businesses who participate in  compliance
          assistance programs	page 191

(7) Guidance on Analyzing  "Ability to Pay" - A common statutory factor that must be
considered before the assessment of a penalty is the Respondents "ability to pay" a penalty. There
are several guidance documents intended to help  the administrative practitioner analyze this
statutory factor for use in determining Respondent's ability to pay a penalty and for use in arguing
the EPA's position in litigation.

       (A) "Guidance for Calculating the Economic Benefit of Noncompliance for a Civil
             Penalty Assessment" 11/5/84	page 198

       (B) "Guidance on Determining a Violator's Ability to Pay a Civil Penalty"
             12/16/86	page 203

       (C) "Change in Methodology for Determining the BEN Model's Discount Rate"
            10/19/92	page 208

       (D) "BEN, ABEL and CASHOUT Models on National LAN Platform"
            12/13/94	page 213

       (E) Kimberly Zanier  memos, "Financial Analysis/General Synopsis" and "Financial
           Analysis Memorandum #2", August  2,1995	page 217

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 (8) Settlement Guidance - In addition to the Audit Policy and the SEP Policy, which are for use
 only during settlement, there are several other documents pertaining to settlement which EPA
 practitioners should be familiar with as they consider negotiating settlements.

        (A) "Use of Stipulated Penalties in EPA Settlement Agreements" 1/24/90	-page 246

        (B) See the Statute Specific ERPs.

        (C) "Guidance on Certification of Compliance with Enforcement Agreements"
            7/25/88	page 254

 (9) Guidance on Prosecutorial Discretion - The Audit Policy, the SEP Policy and the Small
 Business Policy are all policies which embody an EPA position on prosecutorial discretion in
 certain circumstances.  However, there are two more guidance documents which the practitioner
 should be familiar with that have general applicability in all media.

        (A) "Processing Requests for Use of Enforcement Discretion" 3/3/95	page 261

        (B) "Policy Against 'No Action' Assurances" 11/16/84	page 264

 (10) Guidance on  Intra-Agency Process and Procedure - These guidance documents explain
 who does what and how within EPA when it comes to administrative practice.

        (A) "Procedures to Improve Coordination before the Environmental Appeals Board"
            1/25/93	page 266

       (B) "Redelegation of Authority and Guidance on Headquarters Involvement in
            Regulatory Enforcement Cases" 7/11/94	page 277

       (C) "OECA/Regional Procedures for Civil Judicial and Administrative Enforcement Case
            Redelegation" 11/8/94	page 292

       (D) "Documenting Penalty Calculations and Justifications in EPA Enforcement Actions"
           8/9/90	page 307

 (11) Delegations of authority. Available at EPA's website.

 (12) Models of complaints, settlements, documents, justification memos, etc. Models are a handy
 tool that should be  used with caution. Guard against over-reliance on models. Always double
check your models to ensure applicability in a particular case and that the model is current with
respect to EPA policy,  procedure, regulation and, of course, current case law.

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       (A) Complainant's Pre-Hearing Exchange in Celltech Media. Inc. aka Health Care
          Products. Docket Nos. FIFRA 95-H-04; FIFRA 93-H-02F and I.F.&R. VIII-90-
         279C; February 26, 1996	page 310

       (B) Complaint in GEC Precision. EPCRA Docket No. 94-T-381-E	page 336

       (C) Memo in Support of Penalty in GEC Precision	page 345

       (D) Transcript of hearing in GEC Precision.	page 351

       (E) Transcript of hearing in WAUSAU	page 364

(13) Statutes worth studying:

       (A) The Revisions to the Equal Access to Justice Act made by the Small Business
          Regulatory Enforcement Fairness Act of 1996 (SBREFA), P.L. 104-121, 110 Stat. 857-
          74. This statute authorizes certain Respondents to file an application seeking
          reimbursement from the EPA for attorneys fees and other expenses incurred in
          defending itself during the litigation. See "Interim Guidance on Administrative and
          Civil Judicial Enforcement Following Recent Amendments to the Equal Access to
          Justice Act", 5/28/96.	page 385

       (B) Paperwork  Reduction Act,  44 U.S.C. Sections 3501 et seq., amended in 1995 at
          PubLL. No. 104-13,109 Stat 163. Implementing regulations are found at 5 CFR
          Part 1320. The statute requires the EPA to get OMB approval for any regulation,
          permit, etc.  which requires the collection of information. Where EPA has failed to
          get OMB approval or has failed to otherwise comply with the PRA requirements,
          EPA may not collect a penalty for the violation of an information collection request.

       (C) Five-Year Federal Statute of Limitations, 28 U.S.C. 2462.  All of our administrative
          cases are subject to a five-year statute of limitations.  Case law should be consulted to
          determine whether a particular violation is "continuing" in nature.

       (D) Antideficiency Act, 31 U.S.C. 665 which prohibits government officials from spending
          funds in excess of Congressionally appropriated amounts or without a Congressional
          appropriation, unless authorized by law.

       (E) Miscellaneous Receipts Act, 31 U.S.C. 3302 mandates that any penalties collected by
          an agency to be returned to the treasury as miscellaneous receipts, rather than be
          retained by the agency. MRA is not applicable where there is a specific statutory
          authority to retain collected funds or to handle such funds differently.

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(14) Access to Information:

       (A)  Guidance documents, memos and policies can be accessed through the Enforcement
and Compliance Docket and Information Center located in Room 4033 of EPA s Ariel Kios
Building. E-mail address is OECA/Docket@EPAMail.Gov. Center contacts are Lee Carothers
(202) 564-2614 and Donna Williams (202) 564-2119.

       (B) Penalty Policies can be accessed through OECA's website or through LEXIS via a
special sub-library  in the environmental library called "PENLTY".

       (C) EPA Shadowlaw has an Administrative Law library containing all ALJ and EAB
decisions as well as a Policy and Guidance library.

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       ADMINISTRATIVE LITIGATION PRACTICE

                           NETWORK


     Helene C. Ambrosino - 202-564-2627 + Michael J. Walker - 202-564-2624
                                fax: 202-501-0633

                   Distributed for use to EPA administrative law practitioners;
                     fill! text bird copy documents have been «ert to each regional coordinator.

       January, 1999. Greetings to EPA administrative kw practitioners coast to coast. We
are pleased to bring you summaries of key decisions of the administrative kw judges and
Environmental Appeals Board issued since our December edition. In addition, we have
included a compilation of administrative practice developments from recent Weekly
Activity Reports. 1999, like every new year, offers fresh hope and the opportunity to
become revitalized once again. The cases diis month represent an interesting mix of issues,
some positive, some problematic.  Note in particular

       •      Full penalty awarded in CWA Wetlands case: Condor land Company
       •      Dismissal averted in Wallace Stone CWA dredge case
       •      EAB saves EPCRA Penalty Policy in Hall Signs appeal challenge
       •      EAB Remand Order supports fee award in Asbestos NESHAP appeal

       The two EAB decisions merit your special attention. EPA appealed one line in Judge
Pearlstein's Hatt Signs decision in which he held that the EPCRA ERP was "arbitrary and
inconsistent with the statute." The penalty that Judge Peadstein imposed and his method of
calcukting the penalty, which appeared to be well within the requirements of 40 CFR
22.27 (b) were not at issue: it was the act of discounting the ERP that was at issue. In the
declining to reverse, the Board held that the references to the ERP were limited to the facts in
this case, and had no broad precedential effect, noting that ALJ's do not have the authority to
"strike down" EPA penalty policies. Remember, you must read this decision in light of the
Board's ruling in Employers Insurance ofWausau. Accordingly, proper practice procedures
dictate that penalty policies must be pled and argued in conformity with the statutory
provisions for penalty assessment in each applicable statute.

       The decision in L & C Services is also well worth the attention of each an every
administrative practitioner.  In this decision die Board reversed the decision of Judge
Charneski which denied recovery of attorney fees and expenses under the Equal Access To
Justice Act Judge Charneski had dismissed EPA's CAA Asbestos NESHAPS case, finding
that samples were not taken to establish the presence of asbestos for some counts and
where samples were collected, they were not properly tested to establish that the asbestos
was "friable." The respondent sought recovery of attorney fees and expenses.. To recover
attorney fees, a respondent must demonstrate that EPA was not "substantially justified" in

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 bringing the action. In this case, because of the sheer magnitude of the asbestos abatement
 project (demolition of a refinery) the contractor elected to treat all material removed as if it
 contained asbestos. The state inspector who visited the demolition site on numerous occasions
 found insulation material improperly stored in many locations in violation of the asbestos
 NESHAPS requirements. The Court, and now the Board refused to allow a circumstantial
 inferences of asbestos mismanagment to be drawn. The bottom line to inspectors and case
 developers: when in doubt collect and test your samples.

       The case has been remanded to Judge Charneski for consideration of the fee request.
 Approximately $70,000 is being sought

 Administrative Practice Highlights

       Take some time to scan the Administrative Practice Highlights compiled from the
 regional weekly activity reports. We will continue to compile this information and to
 Highlight key developments in the administrative practice that may never result in the
 issuance of an initial or final decision. As you are aware, with the vast majority of our cases
 settling, it is vital that administrative practitioner have the ability to see the larger practice
 picture beyond the orders and decisions issued by the Environmental Appeals Board or
 Office of Administrative Law Judges. Note in particular:

       •     Inland Steel pays $248,000 to settle RCRA violations
       •     The Bureau of Indian Affairs pays $90,000 to settle RCRA violations
       •     3M Fined for not having proper RCRA training certification
       •     An AHERA training course provider is suspended
             Rhode Island DOT Pays $100,000 for SPCC & RCRA violations
       •     Realtors are cited for Lead-Paint Disclosure violations

       A great deal is happening across our multi-statute practice and this compilation of
 items will allow you to see what other practitioners are doing. You should be able to get
 some great practice ideas from this information. Don't hesitate to call the practitioner
 identified in each items for more information.

 Administrative Practice Training & Professional Development

       Several courses and meetings are on the horizon of interest to administrative
practitioners:

       From the National Enforcement Training Institute:

      Administrative Hearings & Trials;    February 24,1999 - Region 2
                                            March 17,1999 - Region 1
                                            April 21,1999 - Region 4
                                           July 14,1999-Washington, D.C.,

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       Pleading & Litigating Civil Penalties:  February 25,1999 - Region 2
                                            March 18,1999 - Region 1
                                            April 22,1999 - Region 4

       Supplemental Environmental Projects: February 18,1999 - Washington, D.C.
                                            May 6,1999 - Region 9
                                            May 19,1999 - Region 4
                                            July 28,1999 - Region 7

       Negotiation Skills Training (Advanced! April 28-29,1999 - Region 4

       9th Annual Advanced Administrative Practice Institute
       April 20-21,1999 - Region 4 (for lawyers from all regions)

       These courses are open to EPA attorneys and technical professionals. Invest
in yourself: take a NET! course.

       Also the National EPCRA Conference will take place in New York City, May 4 and
5*, 1999. This is the first rime that the "313" and "non-313" groups will be meeting
together. For more information, contact Jon Jacobs at 202-564-4037-
       On a sad note for many EPA, we regrettably announce that Judge Edward
Kuhlmann has retired. In the short time that he was assigned to work at EPA, Judge
Kuhlmann created a record of decisions, orders and "firsts" that are unparalleled in the
history of EPA. He issued an accelerated decision on liability and penalty in Oklahoma
Metal Processing that imposed a $1.3 million dollar TSCA penalty. The highest penalty ever
imposed by an administrative law judge in the history of EPA, under any statute ever...and it
was on a motion for accelerated decision.   Later Judge Kulhmann issued his decision in die
DuPont FIFRA case, where he found that DuPont had failed to print eye-protection
warnings on the label of there popular Bladex corn herbicide. Noting that FIFRA required
hi*" to consider the gravity of the violation, the appropriateness of die penalty to the size of
business and the effect of the penalty on die persons's ability to continue in business, Judge
Kuhlmann found mat the violations were significant and that a fine of $1.9 million was
appropriate to send a message to this corporate giant with $36 billion in gross sales. $1.9
million. From a statute where the maximum penalty is $5,000 per violation per day.  To
Judge Kuhlmann: best wishes and thanks for showing us what is possible.

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               * SIGNIFICANT ORDERS & INITIAL DECISIONS *

       * PnnHnr T^nd Company. Docket No. CWA-404-95-106. FULL PENALTY
 AWARDED!

       On December 8,1998 Judge Charneski issued an Initial Decision in this CWA
 Section 301 (a) case. Respondent was charged with illegally discharging a pollutant into a
 wetland without a Section 404 permit when it used bulldozers and loaders to dear and plow
 its land. The Judge rejected Respondent's argument that the land was not a wetland and
 found the three EPA witnesses on this subject persuasive. The Judge rejected Respondent's
 argument that EPA failed to correctly use its own guidance document in making the wetland
 determination on the grounds that it is merely a manual to aid field personnel.  Likewise, the
 Judge rejects Respondent's argument that a wetland does not constitute a navigable body of
 water under the CWA and, therefore, there is no jurisdiction.  The U.S. Supreme Court held
 in U.S. v Riverside Bawiew Homes. 474 U.S. 121 (1985) that, for the purposes of the CWA,
 die phrase "navigable waters" may includes wetlands. The Judge ruled that the subject
 .property in this case constituted a "wetland system contiguous with coastal waters" and,
 thus, subject to the CWA.  The Judge also rejected Respondent's argument that it did not
 "discharge" pollutants and held that the "redepositing" of material would constitute a
 "discharge". As a final  liability issue, the Judge rejected Respondent's argument that it did
 not have to get a permit due to the farming exemption contained in the CWA.  The Judge
 held that the burden of establishing the exemption was on Respondent and they failed to
 show that the illegal discharge was due to "established (Le. ongoing) farming	
 operation". Respondent had failed to raise the issue of penalty at hearing or in its post-
 hearing brief. The Judge held that the civil penalty requested by EPA is appropriate and
 assessed a $32,160 penalty. Melissa Allen Heath and Phillip G. Mancusi-Ungaro
 represented EPA Region 4 in this proceeding.

       * Wallace W. Stone. [CWA] Docket No. VII-97-0024. EPA dredges up more
 evidence to support its case and dismissal is averted!

      On December 17,1998 Judge Bullock issued an Order Denying EPA's Motion for
 Default Order and Finding that EPA's Case Should Not be Dismissed. The complaint
 alleged violation of CWA Section 301 (a) charging that Respondent's dredging operation
 caused an illegal discharge into a navigable waterway.  EPA filed a Motion for a Default
 after Respondent failed  to file a prehearing exchange. The Judge denied the Motion when
 Respondent wrote a letter indicating that he cannot afford a lawyer and would explain his
 position via a letter. The Judge indicated that more lenient standards apply to a/>ro se
 Respondent During the pendency of the motion for default, the Judge issued an Order for
 EPA to supplement its a prehearing exchange in order to show that die case should not be
 dismissed as a result of National Mining Assoc. et al. v. U.S. Army Corps of Eng'rs, pf al
No. 97-5099,1998 U.S.  App. LEXIS 13009 (D.C'Cir. 1998).  In National Mining the court
of appeals explained that a "discharge of a pollutant" under the CWA definition does NOT
include the "incidental fallback" resulting dredging activities. The Judge did not dismiss the

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case because EPA was able to supplement the preheating exchange sufficiently to show that
there will be evidence produced to demonstrate that Respondent was responsible for
"sidecasting and redepositing of material" and not merely incidental fallback. Audrey Asher
represents EPA Region 7 in diis proceeding.

      * Lipscomb Industries. Inc.. Docket No. FIFRA-VI-028-C. Untimely Answer
Results in Dismissal and Remand, but why not default?

      On November 30,1998 Judge Gunning issued an Order Dismissing die Case and
Returning File to the Regional Hearing Clerk.  Judge Barbara Gunning dismissed the case
and had it returned to the Regional Hearing Clerk after ruling that Respondent's letter did
not constitute a timely filed Answer.  The grounds for dismissing the case are a bit unclear,
as it the failure of the Court to grant a motion for default Consistent with the Rules of
Practice, the Region is filing a motion for clarification. Gary Smith represented EPA
Region 6 in diis proceeding.

      * Franklin and Leonhardt Excavating Company. Inc.. Docket No. CAA-98-011.
EPA motion to demolish Respondent's affirmative defenses postponed!

      On December 7,1998 Judge McGuire issued an Order Denying Complainant's
Motion to Strike Affirmative Defenses in this CAA Asbestos NESHAPs case.  The Judge
denied EPA's motion and ruled that motions to strike are not favored and should be denied
unless the legal insufficiency of the defense is dearly apparent  The Judge held that, since a
preheating exchange has not yet been completed, the record is largely undeveloped and any
evidence on Respondent's affirmative defenses should be heard. Specifically, Respondent
alleges in four affirmative defenses, facts intended to establish estoppel and laches against
EPA.  Respondent alleges that it is a demolition company that relied on the representations
of the State Air Pollution Control District that die building involved was free of RACM
before demolition began. The Judge opined that evidence would be needed to determine the
role and responsibility of the state in the proceeding and pursuant to CAA Sections 112(1)
and (8).

      * United States Air Force Tinker Air Force Base. Docket No. UST-6-98-002-
AO-L EPA's Argument to consolidate grounded in air force cases.

      On December 17,1998 Judge Gunning issued an Order Denying Complainant's
Motion to Consolidate EPA's motion requested the consolidation of two cases against
Respondent that arose out of the same inspection. The instant case alleges violations of
RCRA Section 9006 and the UST regulations.  The other case alleges violations of the CAA.
In denying EPA's request, the Judge held that consolidation is authorized by 40 CFR 22.12
which allows for consolidation only if the record supports a finding that there "exists
common questions  of fact or law, consolidation would expedite and simplify consideration
of the issues, and consolidation would not adversely affect the rights of parties engaged in

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 otherwise separate proceedings". The Judge felt that the record did not support such a
 finding.

       * Hallar Enterprises. Inc.. Docket No. RCRA-VI-815-H. Judge rejects RGRA
 Test method challenges for now; to be raised later at trial.

       On January 20,1999 Judge Nissen issued an Order in this RCRA 3008 case.
 Respondent was charged with several RCRA counts involving the disposal and storage of
 hazardous waste without a permit Respondent has denied diat any waste was hazardous
 and argues that EPA's sampling was not done in  accordance with accepted procedures and
 applicable rules and, thus, are not representative and should be rejected. EPA now seeks a
 ruling by the ALJ that EPA is not bound by regulation or guidance to perform sampling in
 any prescribed manner as long as it can be shown by scientifically acceptable methods that
 the sampling was representative.  Specifically, is SW-846 a required sampling method or
 merely advisory?  In coming to a decision the Judge was persuaded by EPA's deletion of a
 statement in the preface to SW-846 that had said "SW-846 test methods would be used in
 RCRA investigations."  The Judge held that the necessity is for a scientifically acceptable
 method of sampling regardless of me status of SW-846.  Finally, the Judge granted EPA's
 motion to the extent that whether sampling methods in  SW-846 are mandatory and whether
 samples taken were representative of wastes at the facility will be decided after the evidence
 is heard.

                         * EAB DECISIONS *

       * Hall Signs. Inc.. EPCRA Appeal No. 97-6.  Good sign for the EPCRA
 Section 313 Enforcement Response Policy!

       On December 16,1998 the EAB issued a Final Order in this EPCRA appeal in which
 EPA sought to reverse Judge Pearistein's holding that the EPCRA Section 313 Enforcement
 Response Policy was arbitrary and inconsistent with the  statute. The EAB was reluctant to
 rule at all holding that they do not want to be drawn routinely into parsing the language of
 an initial decision assessing a penalty when neither party has appealed the amount of the
 penalty assessment Because they felt that the question at issue could be dealt with in short
 order, they decided to address it  The EAB concluded that the opinion of the ALJ need not
 be vacated because the Initial Decision does not establish a precedent that undermines the
 validity of the ERP. The EAB held that the ALJs references to the  ERP as being arbitrary
 were all limited to the facts of the case and based solely on the record and, therefore, carries
 no broad, reaching precedential effect The EAB agreed diat die ALJs  do not have the
 authority to "strike down" EPA policy perse, however, they found no evidence in the record
 that Judge Peadstem had exceeded his authority in diis regard.  Ignacio L, Arrazola
represented EPA Region 5 in diis proceeding.

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      * L & C Services. Inc., EAJA Appeal No. 98-L  Hard Lessons Learned in EAJA
Appeal.

      On January 15,1999 the EAB issued a Final Decision and Remand Order concerning
Respondent's application for attorney's fees and expenses under the Equal Access to Justice
Act The underlying action involved allegations of CAA Asbestos NESHAP violations. The
case was dismissed because no samples were taken to establish the presence of asbestos for
four out of six counts and ,where samples were taken, die record did not establish that the
asbestos was "friable". The ALJ denied Respondent's request for EAJA relief and held that
EPA had been "substantially justified" in bringing die action.  On appeal, the  EAB has
reversed the ALJ and held diat EPA was not substantially justified in bringing the action.
Specifically, die EPA "had no reasonable basis in fact for its position	where the
administrative record reveals that the Region adduced neither direct evidence nor compelling
circumstantial evidence in support of key elements of its claim". The government has the
burden of proof with respect to "substantial justification" and EPA failed to meet this
burden. The EAB rejected using the Asbestos Notification Forms submitted by Respondent
which identified the presence of friable asbestos at die facility.  First, theJBAB points out
that the forms were never admitted into evidence at the hearing!  Second,, die forms can only
lend support to the fact that there was friable asbestos at the facility and does  not support
any tactual determinations as to whether the material observed by the inspector was actually
asbestos or friable. The notification forms support the legitimacy of conducting an
inspection, but not as direct or circumstantial evidence of noncompliance. The matter has
been remanded to determine the size of the award.

                   * MTSrKT.T -AMFQUS NEWS *

      On January 11,1999, OECA's Office of Regulatory Enforcement sent  out an
announcement that they have created a new position intended to enhance our ability to
coordinate implementation of the Audit Policy and related self-disclosure initiatives and have
appointed Leslie Jones as ORE's Self Disclosure Coordinator.  See enclosed memo for
details.

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        [Code of Federal Regulations]
        [Title 40, Volume 1, Parts 1 to 49}
        [Revised as of July 1, 1998]
        From the U.S. Government Printing Office via GPO Access
        [CITE: 40CFR22]

        [Page 221-227]

                          TITLE 40—PROTECTION OF ENVIRONMENT

                      CHAPTER I—ENVIRONMENTAL PROTECTION AGENCY

        PART 22—CONSOLIDATED RULES OF PRACTICE GOVERNING THE ADMINISTRATIVE ASSESSMENT OF C

        Subpart A—General

        Sec. 22.01  Scope of these rules.

           (a) These rules of practice govern all adjudicatory proceedings for:
           (1) The assessment of any civil penalty conducted under section
        14(a)  of the Federal Insecticide, Fungicide and Rodenticide Act as
        amended (7 U.S.C. 1361(a));
           (2) The assessment of any administrative penalty under sections
        113(d)(l), 205(c), 211(d) and 213(d) of the Clean Air Act, as amended
        (CAA)   (42 U.S.C. 7413(d)(l), 7524(c), 7545
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      FR 12263, Apr.  13,  1988;  54 FR 12371,  Mar.  24,  1989;  54 FR 21176, May
      16, 1989; 56  FR 3757,  Jan.  30,  1991;  57 FR  4318,  Feb.  4,  1992]

      Sec. 22.02  Use of  number and gender.

          As used in  these rules of practice, words in the singular also
      include the plural  and words in the masculine gender also include the
      feminine  and  vice versa,  as the case may require.

      Sec. 22.03  Definitions.

           (a) The following definitions apply to  part 22:
          Act means the particular statute authorizing the institution of the
      proceeding at issue.
          Administrative  Law Judge means an Administrative Law Judge appointed
      under 5 U.S.C.  3105 (see  also Pub. L.  95-251, 92 Stat.  183).
          Administrator means the Administrator of the U.S.  Environmental
      Protection Agency or his  delegate.
          Agency means the United States Environmental Protection Agency.
          Complainant means any person authorized to issue a complaint on
      behalf of the Agency to persons alleged to  be in violation of the Act.
      The complainant shall not be a member of the Environmental Appeals
      Board, the Regional Judicial Officer,  or any other person who will
      participate or  advise in  the decision.
          Complaint means a written communication, alleging one or  more
      violations of specific provisions of the Act, or regulations  or a permit
      promulgated thereunder, issued by the complainant to a person under
      Sees. 22.13 and 22.14.
          Consent Agreement means any written document,  signed by the parties,
      containing stipulations or conclusions of fact or law and a proposed
      penalty or proposed revocation or suspension acceptable to both
      complainant and respondent.
          Environmental Appeals Board means the Board within the Agency
      described in  Sec. 1.25 of this title,  located at U.S.  Environmental
      Protection Agency,  A-110, 401 M St. SW., Washington,  DC 20460.
          Final Order means (a) an order issued by the Administrator after an
      appeal of an  initial decision,  accelerated  decision,  decision to
      dismiss,  or default order,  disposing of a matter in controversy between
      the parties,  or (b) an initial decision which becomes a final order
      under Sec. 22.27(c) .
          Hearing means a hearing on the record open to the public  and
      conducted under these rules of practice.
          Hearing Clerk means the Hearing Clerk,  A-110,  U.S.  Environmental
      Protection Agency,  401 M  St. SW., Washington, DC 20460.
          initial Decision means the decision issued by the Presiding Officer
      based upon the  record of  the proceedings out of which it arises.
          Party means any person that participates in a hearing as
      complainant,  respondent,  or intervenor.
          Permit means a  permit issued under section 102 of the Marine
      Protection, Research,  and Sanctuaries Act.
          Person includes any individual, partnership,  association,
      corporation,  and any trustee, assignee, receiver or legal successor
      thereof;  any  organized group of persons whether incorporated  or not; and
      any officer,  employee, agent, department, agency or instrumentality of
      the Federal Government, of any State or local unit of government, or of
      any foreign government.
          Presiding Officer means the Administrative Law Judge designated by
      the Chief Administrative  Law Judge to

      [[Page 223]]
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      the Region's  Enforcement Division or by the Regional Division directly
      associated with  the  type of violation at issue in the proceeding. A
      Regional  Judicial  Officer shall not have performed prosecutorial or
      investigative functions  in connection with any hearing in which he
      serves  as a Regional Judicial Officer or with any factually related
      hearing.
           (c) Presiding  Officer. The Presiding Officer shall conduct a fair
      and impartial

      [[Page  224]]

      proceeding, assure that  the facts are fully elicited, adjudicate all
      issues, and avoid  delay.  The Presiding Officer shall have authority to:
           (!) Conduct  administrative hearings under these rules of practice;
           (2) Rule  upon  motions, requests, and offers of proof, dispose of
      procedural requests,  and issue all necessary orders;
           (3) Administer oaths and affirmations and take affidavits;
           (4) Examine  witnesses and receive documentary or other evidence;
           (5) For good cause,  upon motion or sua sponte, order a party, or an
      officer or agent thereof, to produce testimony, documents, or other
      nonprivileged evidence,  and failing the production thereof without good
      cause being shown, draw  adverse inferences against that party;
           (6) Admit or exclude evidence;
           (7) Hear  and decide  questions of facts, law, or discretion;
           (8) Require  parties  to attend conferences for the settlement or
      simplification of  the issues, or the expedition of the proceedings;
           (9) Issue subpoenas  authorized by the Act; and
           (10)  Do all  other acts and take all measures necessary for the
      maintenance of order and for the efficient, fair and impartial
      adjudication  of  issues arising in proceedings governed by these rules.
           (d) Disqualification; withdrawal. (1) The Administrator, the
      Regional  Administrator,  the members of the Environmental Appeals Board,
      the Regional  Judicial Officer, or the Presiding Officer may not perform
      functions provided for in these rules of practice regarding any matter
      in which  they (i)  have a financial interest or  (ii)  have any
      relationship  with  a  party or with the subject matter which would make it
      inappropriate for  them to act. Any party may at any time by motion made
      to the  Regional  Administrator request that the Regional Judicial Officer
      be disqualified  from the proceeding. Any party may at any time by motion
      to the  Administrator request that the Regional Administrator, a member
      of the  Environmental Appeals Board, or the Presiding Officer be
      disqualified  or  request  that the Administrator disqualify himself or
      herself from  the proceeding. The Administrator, the Regional
      Administrator, a member  of the Environmental Appeals Board, the Regional
      Judicial  Officer,  or the Presiding Officer may at any time withdraw from
      any proceeding in  which  they deem themselves disqualified or unable to
      act for any reason.
           (2) If the Administrator, the Regional Administrator, the Regional
      Judicial  Officer,  or the Presiding Officer is disqualified or withdraws
      from the  proceeding,  a qualified individual who has none of the
      infirmities listed in paragraph (d)(1)  of this section shall be assigned
      to replace him.  Assignment of a replacement for Regional Administrator
      or for  the Regional  Judicial Officer shall be made by the Administrator
      or the  Regional  Administrator, respectively. The Administrator, should
      he or she withdraw or disqualify himself or herself, shall assign the
      Regional  Administrator from the Region where the case originated to
      replace him or her.  If that Regional Administrator would be
      disqualified,  the  Administrator shall assign a Regional Administrator
      from another  region  to replace the Administrator. The Regional
      Administrator shall  assign a new Presiding Officer if the original
      Presiding Officer  was not an Administrative Law Judge. The Chief
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       Administrative Law Judge shall assign a new Presiding Officer from among
       available Administrative Law Judges if the original Presiding Officer
       was  an Administrative Law Judge.
            (3) The Chief Administrative Law Judge, at any stage in the
       proceeding, may  reassign the case to an Administrative Law Judge other
       than the  one originally assigned in the event of the unavailability of
       the  Administrative Law Judge or where reassignment will result in
       efficiency in the scheduling of hearings and would not prejudice the
       parties.
       [45  FR 24363, Apr. 9, 1980, as amended at 57 FR 5324, Feb. 13, 1992; 57
       FR 60129. Dec. 18, 1992]

       Sec.  22.05  Filing, service, and form of pleadings and documents.

            (a) Filing of pleadings and documents. (1) Except as otherwise
       provided, the original and one copy of the complaint, and the original
       of the answer and of

       [[Page 225]]

       all  other documents served in the proceeding shall be filed with the
       Regional  Hearing clerk.
            (2) A certificate of service shall accompany each document filed or
       served. Except as otherwise provided, a party filing documents with the
       Regional  Hearing Clerk, after the filing of the answer, shall serve
       copies thereof upon all other parties and the Presiding Officer. The
       Presiding officer shall maintain a duplicate file during the course of
       the  proceeding.
            (3) When the Presiding Officer corresponds directly with the
       parties,  the original of the correspondence shall be sent to the
       Regional  Hearing Clerk, a copy shall be maintained by the Presiding
       Officer in the duplicate file, and a copy shall be sent to all parties.
       Parties who correspond directly with the Presiding Officer shall in
       addition  to serving all other parties send a copy of all such
       correspondence to the Regional Hearing Clerk. A certificate of service
       shall accompany  each document served under this subsection.
            (b) Service  of pleadings and documents—(1) Service of complaint.
       (i)  Service of a copy of the signed original of the complaint, together
       with a copy of these rules of practice, may be made personally or by
       certified mail,   return receipt requested, on the respondent  (or his
       representative).
            (ii>  Service upon a domestic or foreign corporation or upon a
       partnership or other unincorporated association which is subject to suit
       under a common name shall be made by personal service or certified mail,
       as prescribed by paragraph (b)(1)(i)  of this section, directed to an
       officer,  partner, a managing or general agent, or to any other person
       authorized by appointment or by Federal or State law to receive service
       of process.
           (iii)  Service upon an officer or agency of the United States shall
       be made by delivering a copy of the complaint to the officer or agency,
       or in any manner  prescribed for service by applicable regulations. If
       the agency is  a corporation,  the complaint shall be served as prescribed
       in paragraph  (b)(1)(ii)  of this section.
           (iv)  Service  upon a state or local unit of government, or a State or
       local officer, agency,  department,  corporation or other instrumentality
       shall be made by  serving a copy of the complaint in the manner
       prescribed by the law of the State for the service of process on any
       such  persons, or:
          (A) If upon a State or local unit of government, or a State or local
       department, agency, corporation or other instrumentality, by delivering
       a  copy of  the complaint to the chief executive officer thereof;



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           (B) If upon  a  state or local officer by delivering a copy to such
      officer.
           (v) Proof  of service of the complaint shall be made by affidavit of
      the person making  personal service,  or by properly executed return
      receipt.  Such  proof of service shall be filed with the complaint
      immediately upon completion of service.
           (2) Service  of documents other than complaint, rulings,  orders,  and
      decisions. All documents other than the complaint, rulings,  orders,  and
      decisions, may be  served personally or by certified or first class mail.
           (c) Form of  pleadings and documents. (1)  Except as provided herein,
      or by  order of the Presiding Officer or of the Environmental Appeals
      Board, there are no specific requirements as to the form of documents.
           (2) The first  page of every pleading, letter,  or other document
      shall  contain  a  caption identifying the respondent and the docket number
      which  is  exhibited on the complaint.
           (3) The original of any pleading,  letter or other document (other
      than exhibits) shall be signed by the party filing or by his counsel or
      other  representative.  The signature constitutes a  representation by the
      signer that he has read the pleading,  letter or other document, that to
      the best  of his  knowledge, information and belief, the statements made
      therein are true,  and that it is not interposed for delay-
           (4) The initial document filed by any person shall contain his name,
      address and telephone number. Any changes in this  information shall be
      communicated promptly to the Regional Hearing clerk, Presiding Officer,
      and all parties  to the proceeding. A party who fails to furnish such
      information and  any changes thereto shall be deemed to have waived his
      right  to  notice  and service under these rules.

      [[Page 226]}

           (5) The Environmental Appeals Board, the Regional Administrator, the
      Presiding Officer, or the Regional Hearing Clerk may refuse to file any
      document  which does not comply with this paragraph. Written notice of
      such refusal,  stating the reasons therefor, shall  be promptly given to
      the person submitting the document.  Such person may amend and resubmit
      any document refused for filing upon motion granted by the Environmental
      Appeals Board, the Regional Administrator,  or the  Presiding Officer, as
      appropriate.
      [45 FR 24363,  Apr. 9,  1980, as amended at 57 FR 5324, Feb. 13,  1992]

      Sec. 22.06  Filing and service of rulings,  orders, and decisions.

          All rulings, orders, decisions,  and other documents issued by the
      Regional  Administrator, Regional Judicial Officer, or Presiding Officer,
      as appropriate,  shall be filed with the Regional Hearing Clerk. All such
      documents issued by the Environmental Appeals Board shall be filed with
      the Clerk of the Environmental Appeals Board. Copies of such rulings,
      orders, decisions, or other documents shall be served personally, or by
      certified mail,  return receipt requested, upon all parties by the
      Environmental  Appeals Board, the Regional Administrator, the Regional
      Judicial  Officer,  or the Presiding Officer, as appropriate.
      [45 FR 24363,  Apr. 9,  1980, as amended at 57 FR 5324, Feb. 13,  1992]

      Sec. 22.07  Computation and extension of time.

           (a) Computation.  In computing any period of time prescribed or
      allowed in these rules of practice,  except as otherwise provided, the
      day of the event from which the designated period  begins to run shall
      not be included. Saturdays, Sundays, and Federal legal holidays shall be
      included. When a stated time expires on a Saturday, Sunday or legal
      holiday,  the stated time period shall be extended  to include the next



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       business  day.
            (b) Extensions of time. The Environmental Appeals Board,  the
       Regional  Administrator, or the Presiding Officer,  as  appropriate,  may
       grant an  extension of time for the filing of any pleading,  document,  or
       motion  (1)  upon timely motion of a party to the proceeding,  for good
       cause shown, and after consideration of prejudice  to  other  parties,  or
        (2) upon  its or his own motion. Such a motion by a party may only be
       made after  notice to all other parties, unless the movant can show good
       cause why serving notice is impracticable. The motion shall be filed in
       advance of  the date on which the pleading, document or motion is due to
       be  filed, unless the failure of a party to make timely motion for
       extension of time was the result of excusable neglect.
            (c) Service by mail. Service of the complaint  is  complete when the
       return receipt is signed. Service of all other pleadings and documents
       is  complete upon mailing. Where a pleading or document is served by
       mail, five  (5) days shall be added to the time allowed by these rules
       for the filing of a responsive pleading or document.
        [45 FR 24363, Apr. 9, 1980, as amended at 57 FR 5324,  Feb.  13,  1992]

       Sec. 22.OB  Ex parte discussion of proceeding.

           At no time after the issuance of the complaint shall the
       Administrator, the members of the Environmental Appeals Board,  the
       Regional  Administrator, the Regional Judicial Officer,  the  Presiding
       Officer,  or any other person who is likely to advise  these  officials in
       the decision on the case, discuss ex parte the merits of the proceeding
       with any  interested person outside the Agency, with any Agency staff
       member who  performs a prosecutorial or investigative  function in such
       proceeding  or a factually related proceeding, or with any representative
       of  such person. Any ex parte memorandum or other communication addressed
       to  the Administrator, the Regional Administrator,  the Environmental
       Appeals Board, the Regional Judicial Officer, or the  Presiding Officer
       during the  pendency of the proceeding and relating to the merits
       thereof, by or on behalf of any party shall be regarded as  argument made
       in  the proceeding and shall be served upon all other  parties.  The other
       parties shall be given an opportunity to reply

       [[Page 227]]

       to  such memorandum or communication.
       [45 FR 24363,  Apr.  9, 1980, as amended at 57 FR 5325,  Feb.  13,  1992]

       Sec. 22.OB  Examination of documents filed.

           (a)  Subject to the provisions of law restricting  the public
       disclosure of confidential information, any person may, during Agency
       business hours,  inspect and copy any document filed in any  proceeding.
       Such documents shall be made available by the Regional Hearing Clerk,
       the Hearing Clerk,  or the Environmental Appeals Board,  as appropriate.
           (b)  The cost of duplicating documents filed in any proceeding shall
       be borne by the  person seeking copies of such documents. The Agency may
       waive  this cost  in  appropriate cases.
       [45  FR 24363,  Apr.  9,  1980,  as amended at 57 FR 5325,  Feb.  13,  1992]
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       {Code of  Federal  Regulations]
       [Title  40, Volume 1,  Parts  1  to 49]
       [Revised  as  of  July 1,  1998]
       From the  U.S. Government  Printing Office via GPO Access
       [CITE:  40CFR22]

       [Page 227-228]

                          TITLE  40—PROTECTION OF ENVIRONMENT

                      CHAPTER  I—ENVIRONMENTAL PROTECTION AGENCY

       PART 22—CONSOLIDATED RULES OF PRACTICE GOVERNING THE ADMINISTRATIVE ASSESSMENT OF C

       Subpart B—Parties and  Appearances

       Sec. 22.10   Appearances.

          Any party may appear  in person or by counsel or other
       representative. A partner may appear on behalf of a partnership and an
       officer may  appear on behalf  of a corporation. Persons who appear as
       counsel or other  representative must conform to the standards of conduct
       and ethics required of  practitioners before the courts of the United
       States.

       Sec. 22.11   Intervention.

           (a) Motion. A motion  for  leave to intervene in any proceeding
       conducted under these rules of practice must set forth the grounds for
       the proposed intervention,  the position and interest of the movant and
       the likely impact that  intervention will have on the expeditious
       progress  of  the proceeding. Any person already a party to the proceeding
       may file  an  answer to a motion to intervene, making specific reference
       to the  factors  set forth  in the foregoing sentence and paragraph (c) of
       this section, within ten  (10)  days after service of the motion for leave
       to intervene.
           {b) When filed.  A motion  for leave to intervene in a proceeding must
       ordinarily be filed before  the first prehearing conference or,  in the
       absence of a prehearing conference,  before the initiation of
       correspondence  under Sec. 22.19(e),  or if there is no such
       correspondence, prior to  the  setting of a time and place for a hearing.
       Any motion filed  after  that time must include, in addition to the
       information  set forth in  paragraph (a) of this section, a statement of
       good cause for  the failure  to file in a timely manner. The intervenor
       shall be  bound  by any agreements, arrangements and other matters
       previously made in the  proceeding.
           (c) Disposition,  Leave  to intervene may be granted only if the
       movant  demonstrates that  (I)  his presence in the proceeding would not
       unduly  prolong  or otherwise prejudice the adjudication of the rights of
       the original parties;  (2) the movant will be adversely affected by a
       final order; and  (3)  the  interests of the movant are not being
       adequately represented  by the original parties. The intervenor shall
       become  a  full party to  the  proceeding upon the granting of leave to
       intervene.
          (d) Amicus  curiae.  The  motion shall identify the interest of the
       applicant and shall state the reasons why the proposed amicus brief is
       desirable. If the motion  is granted,  the Presiding Officer or
      Administrator shall issue an  order setting the time for filing such
      brief.  If the motion is granted,  the Presiding Officer or the
      Environmental Appeals Board shall issue an order setting the time for
       filing  such  brief.



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        [45 FR 24363,  Apr.  9,  1980,  as amended at  57  FR 5325,  Feb. 13, 1992]

        Sec. 22.12   Consolidation and severance.

            (a) Consolidation.  The Presiding Officer  may,  by motion or sua
        sponte, consolidate any or all matters at  issue in two or more
        proceedings  docketed under these rules of  practice where  (1)  there
        exists common  parties or common questions  of  fact  or law, (2)
        consolidation  would expedite and simplify  consideration of the issues,
        and (3) consolidation would not adversely  affect the rights of parties
        engaged in otherwise separate proceedings.
            (b) Severance.  The Presiding Officer may, by motion or sua sponte,
        for good

        [[Page 228]]

        cause shown  order  any proceedings severed  with  respect to any or all
        parties or issues.
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       [Code of  Federal  Regulations]
       [Title  40, Volume 1,  Parts 1 to 49]
       [Revised  as  of  July 1,  1998]
       From the  U.S. Government Printing Office via GPO Access
       [CITE:  40CFR22J

       [Page 228-232]

                          TITLE 40—PROTECTION OF ENVIRONMENT

                      CHAPTER  I—ENVIRONMENTAL PROTECTION AGENCY

       PART 22—CONSOLIDATED RULES OF PRACTICE GOVERNING THE ADMINISTRATIVE ASSESSMENT OF C

       Subpart C—Prehearing Procedures

       Sec. 22.13   Issuance  of complaint.

          If  the complainant  has reason to believe that a person has violated
       any provision of  the  Act,  or regulations promulgated or a permit issued
       under the Act,  he may institute a proceeding for the assessment of a
       civil penalty by  issuing a complaint under the Act and these rules of
       practice. If the  complainant has reason to believe that
           (a) A permittee violated any term or condition of the permit, or
           (b) A permittee misrepresented or inaccurately described any
       material  fact in  the  permit application or failed to disclose all
       relevant  facts  in the permit application, or
           (c) Other good cause exists for such action, he may institute a
       proceeding for  the revocation or suspension of a permit by issuing a
       complaint under the Act and these rules of practice. A complaint may be
       for the suspension or revocation of a permit in addition to the
       assessment of a civil penalty.

       Sec. 22.14   Content and amendment of the complaint.

           (a) Complaint for the assessment of a civil penalty. Each complaint
       for the assessment of a civil penalty shall include:
           (1) A statement reciting the section(s)  of the Act authorizing the
       issuance  of  the complaint;
           (2) Specific  reference to each provision of the Act and implementing
       regulations  which respondent is alleged to have violated;
           (3) A concise statement of the factual basis for alleging the
       violation;
           (4) The  amount of the civil penalty which is proposed to be
       assessed;
           (5) A statement explaining the reasoning behind the proposed
       penalty;
           (6) Notice  of respondent's right to request a hearing on any
       material  fact contained in the complaint, or on the appropriateness of
       the amount of the proposed penalty.

       A copy  of these rules of practice shall accompany each complaint served.
           (b) Complaint for the revocation or suspension of a permit. Each
       complaint for the revocation or suspension of a permit shall include:
           (I) A statement reciting the section(s)  of the Act, regulations,
       and/or  permit authorizing the issuance of the complaint;
          (2) Specific  reference to each term or condition of the permit which
       the respondent  is alleged to have violated,  to each alleged inaccuracy
       or misrepresentation  in respondent's permit application, to each fact
      which the respondent  allegedly failed to disclose in his permit
      application, or to other reasons which form the basis for the complaint;



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      Sec. 22.16  Motions.

           (a) General.  All  motions,  except those made orally on the record
      during a hearing,  shall  (1)  be in writing; (2)  state the grounds
      therefor with particularity;  (3)  set forth the relief or order sought;
      and  (4) be accompanied by any  affidavit,  certificate, other evidence,  or
      legal memorandum relied  upon.  Such motions shall be served as provided
      by Sec. 22.05(b>(2).
           (b) Response to motions. A party's response to any written motion
      must be filed within  ten (10)  days after  service of such motion, unless
      additional time  is allowed for such response.  The response shall be
      accompanied by any affidavit,  certificate, other evidence, or legal
      memorandum relied upon.  If no  response is filed within the designated
      period, the parties may  be deemed to have waived any objection to the
      granting of the  motion.  The Presiding officer,  the Regional
      Administrator, or the Environmental Appeals Board, as appropriate,  may
      set a shorter time for response,  or make  such orders concerning the
      disposition of motions as they deem appropriate.
           (o) Decision.  Except as provided in Sec.  22.04(d)(l) and
      Sec. 22.28 (a), the Regional Administrator shall rule on all motions
      filed or made before  an  answer to the complaint is filed. The
      Environmental Appeals Board shall rule on all motions filed or made
      after service of the  initial decision upon the parties. The
      Administrator shall rule on all motions filed or made after service of
      the initial decision  upon the  parties. The Presiding Officer shall rule
      on all other motions. Oral argument on motions will be permitted where
      the Presiding Officer, the Regional Administrator, or the Environmental
      Appeals Board considers  it necessary or desirable.
      [45 FR 24363, Apr. 9, 1980,  as amended at 57 FR 5325, Feb. 13, 1992;  57
      FR 60129, Dec. 18, 1992]

      Sec. 22.17  Default order.

           (a) Default.  A party may be found to  be in default  (1) after motion,
      upon failure to  file  a timely  answer to the complaint;  (2) after motion
      or sua sponte, upon failure to comply with a prehearing or hearing order
      of the Presiding Officer;  or (3)  after motion or sua sponte, upon
      failure to appear at  a conference or hearing without good cause being
      shown. No finding of  default on the basis of a failure to appear

      [[Page 230]]

      at a hearing shall be made against the respondent unless the complainant
      presents sufficient evidence to the Presiding Officer to establish a
      prima facie case against the respondent.  Any motion for a default order
      shall include a  proposed default  order and shall be served upon all
      parties. The alleged  defaulting party shall have twenty  (20) days from
      service to reply to the  motion. Default by respondent constitutes,  for
      purposes of the  pending  action only, an admission of all facts alleged
      in the complaint and  a waiver  of  respondent's right to a hearing on such
      factual allegations.  If  the complaint is  for the assessment of a civil
      penalty, the penalty  proposed  in  the complaint shall become due and
      payable by respondent without  further proceedings sixty  (60) days after
      a final order issued  upon default.  If the complaint is for the
      revocation or suspension of a  permit, the conditions of revocation or
      suspension proposed in the complaint shall become effective without
      further proceedings on the date designated by the Administrator in his
      final order issued upon  default.  Default  by the complainant shall result
      in the dismissal  of the  complaint with prejudice.
          (b) Procedures upon  default.  When Regional Administrator or



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       Presiding Officer finds a default has occurred, he shall issue a default
       order against the defaulting party. This order shall constitute the
       initial decision, and shall be filed with the Regional Hearing Clerk.
            (c) Contents of a default order. A default order shall include
       findings of fact showing the grounds for the order, conclusions
       regarding all material issues of law or discretion, and the penalty
       which is recommended to be assessed or the terms and conditions of
       permit revocation or suspension, as appropriate.
            (d) For good cause shown the Regional Administrator or the Presiding
       Officer, as appropriate, may set aside a default order.

       Sec. 22.18  Informal settlement; consent agreement and order.

            (a) Settlement policy. The Agency encourages settlement of a
       proceeding at any time if the settlement is consistent with the
       provisions and objectives of the Act and applicable regulations. The
       respondent may confer with complainant concerning settlement whether or
       not the respondent requests a hearing. Settlement conferences shall not
       affect the respondent's obligation to file a timely answer under
       Sec. 22.16.
            (b) Consent agreement. The parties shall forward a written consent
       agreement and a proposed consent order to the Regional Administrator
       whenever settlement or compromise is proposed. The consent agreement
       shall state that, for the purpose of this proceeding, respondent  (1)
       admits the jurisdictional allegations of the complaint;  (2) admits the
       facts stipulated in the consent agreement or neither admits nor denies
       specific factual allegations contained in the complaint; and  (3)
       consents to the assessment of a stated civil penalty or to the stated
       permit revocation or suspension, as the case may be. The consent
       agreement shall include any and all terms of the agreement, and shall be
       signed by all parties or their counsel or representatives.
            (c) Consent order. No settlement or consent agreement shall dispose
       of any proceeding under these rules of practice without a consent order
       from the Regional Administrator. In preparing such an order, the
       Regional Administrator may require that the parties to the settlement
       appear before him to answer inquiries relating to the consent agreement
       or order.

       Sec. 22.19  Prehearing conference.

           (a)  Purpose of prehearing conference. Unless a conference appears
       unnecessary,  the Presiding Officer, at any time before the hearing
       begins,  shall direct the parties and their counsel or other
       representatives to appear at a conference before him to consider:
           (1)  The settlement of the case;
           (2)  The simplification of issues and stipulation of facts not in
       dispute;
           (3)  The necessity or desirability of amendments to pleadings;
           (4)  The exchange of exhibits,  documents, prepared testimony,  and
       admissions  or stipulations of fact which will avoid unnecessary proof;
           (5)  The limitation of the number of expert or other witnesses;
           (6)  Setting a time and place for the hearing; and

       [[Page  231]]

           (7) Any other matters which may expedite the disposition  of the
       proceeding.
           (b) Exchange  of  witness lists and documents. Unless otherwise
       ordered by  the  Presiding Officer,  each party at the prehearing
       conference  shall  make  available to all other parties  (I) The  names of
       the expert  and  other witnesses he intends to call, together with  a brief



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      narrative  summary  of  their  expected testimony,  and (2)  copies of all
      documents  and  exhibits  which  each party intends to introduce into
      evidence.  Documents and exhibits  shall be marked for identification as
      ordered by the Presiding officer. Documents that have not been exchanged
      and witnesses  whose names have not been exchanged shall not be
      introduced into evidence or allowed to testify without permission of the
      Presiding  Officer. The  Presiding  Officer shall allow the parties
      reasonable opportunity  to review  new evidence.
           (e) Record of  the prehearing  conference.  No transcript of a
      prehearing conference relating to settlement shall be made. With respect
      to other prehearing conferences,  no transcript of any prehearing
      conferences shall  be  made unless  ordered by the Presiding Officer upon
      motion of  a party  or  sua sponte.  The Presiding Officer shall prepare and
      file for the record a written summary of the action taken at the
      conference.  The summary shall incorporate any written stipulations or
      agreements of  the  parties and all rulings and appropriate orders
      containing directions to the  parties.
           (d) Location of prehearing conference. The prehearing conference
      shall be held  in the  county where the respondent resides or conducts the
      business which the hearing  concerns, in the city in which the relevant
      Environmental  Protection Agency Regional Office is located, or in
      Washington,  DC,  unless  (1)  the Presiding Officer determines that there
      is good cause  to hold it at another location in a region or by
      telephone,  or  (2)  the Supplemental rules of practice provide otherwise.
           (e) Unavailability  of a prehearing conference. If a prehearing
      conference is  unnecessary or  impracticable,  the Presiding officer,  on
      motion or  sua  sponte, may direct  the parties to correspond with him to
      accomplish any of  the objectives  set forth in this section.
           (f) Other  discovery.  (1)  Except as provided by paragraph (b)  of this
      section,  further discovery, under this section, shall be permitted only
      upon determination by the Presiding Officer:
           (i) That such  discovery will  not in any way unreasonably delay the
      proceeding;
           (ii) That  the  information to  be obtained is not otherwise
      obtainable;  and
           (iii)  That such information has significant probative value.
           (2) The Presiding Officer shall order depositions upon oral
      questions  only upon a showing of  good cause and upon a finding that:
           (i) The information sought cannot be obtained by alternative
      methods; or
           (ii) There is  a substantial reason to believe that relevant and
      probative  evidence may  otherwise  not be preserved for presentation by a
      witness at the hearing.
           (3) Any party  to  the proceeding desiring an order of discovery shall
      make a motion  therefor.  Such  a motion shall set forth;
           (i) The circumstances warranting the taking of the discovery;
           (ii) The nature of  the  information expected to be discovered; and
           (iii)  The  proposed  time and place where it will be taken. If the
      Presiding  Officer  determines  that the motion should be granted, he shall
      issue an order for the  taking of  such discovery together with the
      conditions and terms  thereof.
           (4) When the information  sought to be obtained is within the control
      of one of  the  parties,  failure to comply with an order issued pursuant
      to this paragraph  may lead  to (i) the inference that the information to
      be discovered  would be  adverse to the party from whom the information
      was sought,  or (ii) the issuance  of a default order under Sec. 22.17(a).

      Sec. 22.20  Accelerated decision; decision to dismiss.

           (a) General. The  Presiding Officer,  upon motion of any party or sua
      sponte, may at any time render an accelerated decision in favor of the



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        complainant or the respondent as to all or any part  of  the proceeding,
        without

        [[Page 232]]

        further hearing or upon such limited additional evidence,  such as
        affidavits, as he may require, if no genuine issue of material fact
        exists and a party is entitled to judgment as a matter  of  law,  as to all
        or any part of the proceeding. In addition, the Presiding  Officer,  upon
        motion of the respondent, may at any time dismiss an action without
        further hearing or upon such limited additional evidence as he requires,
        on the basis of failure to establish a prima facie case or other grounds
        which show no right to relief on the part of the complainant.
            (b)  Effect. (1) If an accelerated decision or a  decision to dismiss
        is issued as to all the issues and claims in the proceeding,  the
        decision constitutes an initial decision of the Presiding  Officer,  and
        shall be filed with the Regional Hearing Clerk.
            (2)  If an accelerated decision or a decision to  dismiss is rendered
        on less than all issues or claims in the proceeding, the Presiding
        Officer shall determine what material facts exist without  substantial
        controversy and what material facts remain controverted in good faith.
        He shall thereupon issue an interlocutory order specifying the facts
        which appear substantially uncontroverted, and the issues  and claims
        upon  which the hearing will proceed.
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      [Code of  Federal Regulations]
      [Title 40, Volume  1,  Parts  1  to 49]
      [Revised  as of July  I,  1998]
      From the  U.S. Government  Printing Office via GPO Access
      [CITE: 40CPR22]

      [Page 232-234]

                         TITLE  40—PROTECTION OF ENVIRONMENT

                     CHAPTER  I—ENVIRONMENTAL PROTECTION AGENCY

      PART 22—CONSOLIDATED RULES OF PRACTICE GOVERNING THE ADMINISTRATIVE ASSESSMENT OF C

      Subpart D—Hearing Procedure

      Sec. 22.21  Scheduling  the  hearing.

           (a) When an answer  is filed,  the Regional Hearing Clerk shall
      forward the complaint,  the  answer,  and any other documents filed thus
      far in the proceeding to  the  Chief Administrative Law Judge who shall
      assign himself or  another Administrative Law Judge as Presiding Officer,
      unless otherwise provided in  the Supplemental rules of practice. The
      Presiding Officer  shall then  obtain the case file from the Chief
      Administrative Law Judge  and  notify the parties of his assignment.
           (b) Notice of  hearing.  If the respondent requests a hearing in  his
      answer, or one is  ordered by  the Presiding Officer under Sec.  22.15(c),
      the Presiding Officer shall serve upon the parties a notice of hearing
      setting forth a time and  place for the hearing. The Presiding  Officer
      may issue the notice of hearing at any appropriate time,  but not later
      than twenty  (20) days prior to the date set for the hearing.
           (c) Postponement of hearing.  No request for postponement of a
      hearing shall be granted  except upon motion and for good cause shown.
           (d) Location of  the hearing.  The location of the hearing shall  be
      determined in accordance  with the method for determining the location of
      a prehearing conference under Sec.  22.19(d).

      Sec. 22.22  Evidence.

           (a) General. The Presiding Officer shall admit all evidence which is
      not irrelevant, immaterial, unduly repetitious, or otherwise unreliable
      or of little probative  value,  except that evidence relating to
      settlement which would  be excluded in the Federal courts under Rule 408
      of the Federal Rules of Evidence is not admissible.  In the presentation,
      admission, disposition, and use of evidence,  the Presiding Officer  shall
      preserve  the confidentiality  of trade secrets and other commercial  and
      financial information.  The  confidential or trade secret status of any
      information shall  not,  however,  preclude its being introduced  into
      evidence. The Presiding Officer may make such orders as may be necessary
      to consider such evidence in  camera,  including the preparation of a
      supplemental initial decision to address questions of law, fact, or
      discretion which arise  out  of that portion of the evidence which is
      confidential or which includes trade secrets.
          (b) Examination  of  witnesses.  Witnesses shall be examined  orally,
      under oath or affirmation,  except as otherwise provided in these rules
      of practice or by  the Presiding officer. Parties shall have the right to
      cross-examine a witness who appears at the hearing provided that such
      cross-examination  is not  unduly repetitious.
          (c) Verified statements.  The Presiding Officer may admit an insert
      into the  record as evidence,  in lieu of oral testimony, statements  of
      fact or opinion prepared  by a witness.  The admissibility of the evidence



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       contained in the statement shall be subject to the same rules as if the
       testimony were produced under oral examination. Before any

       [[Page 233])

       such statement is read or admitted into evidence, the witness shall
       deliver a copy of the statement to the Presiding Officer, the reporter,
       and opposing counsel. The witness presenting the statement shall swear
       to or affirm the statement and shall be subject to appropriate oral
       cross-examination upon the contents thereof.
           (d) Admission of affidavits where the witness is unavailable. The
       Presiding Officer may admit into evidence affidavits of witnesses who
       are unavailable. The term ^unavailable" shall have the meaning
       accorded to it by Rule 804(a) of the Federal Rules of Evidence.
           (e) Exhibits. Where practicable, an original and one copy of each
       exhibit shall be filed with the Presiding Officer for the record and a
       copy shall be furnished to each party. A true copy of any exhibit may be
       substituted for the original.
           (f) Official notice. Official notice may be taken of any matter
       judicially noticed in the Federal courts and of other facts within the
       specialized knowledge and experience of the Agency. Opposing parties
       shall be given adequate opportunity to show that such facts are
       erroneously noticed.

       Sec. 22.23  Objections and offers of proof.

           (a) Objection. Any objection concerning the conduct of the hearing
       may be stated orally or in writing during the hearing. The party raising
       the objection must supply a short statement of its grounds. The ruling
       by the Presiding Officer on any objection and the reasons given for it
       shall be part of the record. An exception to each objection overruled
       shall be automatic and is not waived by further participation in the
       hearing.
           (b) Offer of proof. Whenever evidence is excluded from the record,
       the party offering the evidence may make an offer of proof, which shall
       be included in the record. The offer of proof for excluded oral
       testimony shall consist of a brief statement describing the nature of
       the evidence excluded. The offer of proof for excluded documents or
       exhibits shall consist of the insertion in the record of the documents
       or exhibits excluded. Where the Environmental Appeals Board decides that
       the ruling of the Presiding Officer in excluding the evidence was both
       erroneous and prejudicial, the hearing may be reopened to permit the
       taking of such evidence.
       [45 FR 24363,  Apr. 9, 1980,  as amended at 57 FR 5325, Feb. 13, 1992]

       Sec.  22.24  Burden of presentation; burden of persuasion.

           The complainant has the burden of going forward with and of proving
       that the violation occurred as set forth in the complaint and that the
       proposed civil penalty, revocation, or suspension, as the case may be,
       is appropriate.  Following the establishment of a prima facie case,
       respondent shall have the burden of presenting and of going forward with
       any defense to the allegations set forth in the complaint. Each matter
       of controversy shall be determined by the Presiding Officer upon a
       preponderance  of the evidence.

       Sec. 22.25   Filing the transcript.

          The  hearing  shall be transcribed verbatim. Promptly following the
       taking of  the  last evidence, the reporter shall transmit to the Regional
       Hearing  Clerk  the original and as many copies of the transcript of
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      testimony as  are  called for in the reporter's contract with the Agency,
      and also  shall  transmit to the Presiding Officer a copy of the
      transcript. A certificate of service shall accompany each copy of the
      transcript. The Regional Hearing Clerk shall notify all parties of the
      availability  of the transcript and shall furnish the parties with a copy
      of the  transcript upon payment of the cost of reproduction, unless a
      party can show  that the cost is unduly burdensome. Any person not a
      party to  the  proceeding may receive a copy of the transcript upon
      payment of  the  reproduction fee, except for those parts of the
      transcript  order  to be kept confidential by the Presiding Officer.

      Sec. 22.26  Proposed findings, conclusions, and order.

          Within  twenty (20) days after the parties are notified of the
      availability  of the transcript, or within such longer time as may be
      fixed by  the  Presiding Officer, any party may submit for the
      consideration of  the Presiding Officer, proposed findings of fact,
      conclusions of  law, and a proposed order, together

       [[Page  234]]

      with briefs in  support thereof. The Presiding Officer shall set a time
      by which  reply  briefs must be submitted. All submissions shall be in
      writing,  shall  be served upon all parties, and shall contain adequate
      references  to the record and authorities relied on.
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       [Code of Federal Regulations]
       [Title 40,  Volume 1, Parts 1 to 49]                                                      !!!
       [Revised as of July 1, 1998]
       From the U.S. Government Printing Office via GPO Access
       [CITE: 40CFR22]

       [Page 234]

                          TITLE 40—PROTECTION OF ENVIRONMENT

                      CHAPTER I—ENVIRONMENTAL PROTECTION AGENCY

       PART 22 — CONSOLIDATED RULES OF PRACTICE GOVERNING THE ADMINISTRATIVE ASSESSMENT OF C

       Subpart E—Initial Decision and Motion To Reopen a Hearing

       Sec. 22.27  Initial decision.

            (a) Filing and contents. The Presiding Officer shall issue and file
       with the Regional Hearing Clerk his initial decision as soon as
       practicable after the period for filing reply briefs under Sec. 22.26
       has expired. The Presiding Officer shall retain a copy of the complaint
       in the duplicate file. The initial decision shall contain his findings
       of fact, conclusions regarding all material issues of law or discretion,
       as well as reasons therefor, a recommended civil penalty assessment, if
       appropriate, and a proposed final order. Upon receipt of an initial
       decision, the Regional Hearing Clerk shall forward a copy to all
       parties, and shall send the original, along with the record of the
       proceeding, to the Hearing Clerk. The Hearing Clerk shall forward a copy
       of the initial decision to the Environmental Appeals Board.
            (b) Amount of civil penalty. If the Presiding Officer determines
       that a violation has occurred, the Presiding Officer shall determine the
       dollar amount of the recommended civil penalty to be assessed in the
       initial decision in accordance with any criteria set forth in the Act
       relating to the proper amount of a civil penalty, and must consider any
       civil penalty guidelines issued under the Act. If the Presiding Officer
       decides to assess a penalty different in amount from the penalty
       recommended to be assessed in the complaint, the Presiding Officer shall
       set forth in the initial decision the specific reasons for the increase
       or decrease. The Presiding Officer shall not raise a penalty from that
       recommended to be assessed in the complaint if the respondent has
       defaulted.
           (c)  Effect of initial decision. The initial decision of the
       Presiding Officer shall become the final order of the Environmental
       Appeals Board within forty-five (45)  days after its service upon the
       parties and without further proceedings unless (I) an appeal to the
       Environmental Appeals Board is taken from it by a party to the
       proceedings,  or (2)  the Environmental Appeals Board elects, sua sponte,
       to  review the initial decision.
       [45 FR 24363,  Apr.  9,  1980,  as amended at 57 FR 5325, Feb. 13, 1992]

       Sec.  22.28   Motion  to reopen a hearing.

           (a)  Filing and  content.  A motion to reopen a hearing to take further
       evidence must be  made no later than twenty  (20) days after service of
       the initial  decision on the parties and shall  (1) state the specific
       grounds upon  which  relief is sought,  (2) state briefly the nature and
      purpose of the evidence to be adduced,   (3) show that such evidence is
      not cumulative, and (4)  show good cause why such evidence was not
      adduced at the hearing.  The motion shall be made to the Presiding
      Officer and  filed with the Regional Hearing Clerk.



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           (b)  Disposition of motion to  reopen a hearing- Within ten  (10) days
      following the service of a motion to reopen a hearing, any other party
      to the proceeding may file with the  Regional Hearing Clerk and serve on
      all other parties an answer thereto.  The Presiding Officer shall
      announce his intent to grant or deny such motion as soon as practicable
      thereafter.  The conduct of any proceeding which may be required as a
      result of the granting of any motion allowed in this section shall be
      governed by the provisions of the applicable sections of these rules.
      The filing of a motion to reopen  a hearing shall automatically stay the
      running  of all time periods specified under these Rules until such time
      as the motion is denied or the reopened hearing is concluded.
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       [Code of Federal Regulations]
       [Title 40,  Volume 1,  Parts 1 to 49]
       [Revised as of July 1,  1998]
       From the U.S.  Government Printing Office via GPO Access
       [CITE: 40CFR22]

       [Page 234-236]

                          TITLE 40—PROTECTION OF ENVIRONMENT

                      CHAPTER I—ENVIRONMENTAL PROTECTION AGENCY

       PART 22—CONSOLIDATED RULES OF PRACTICE GOVERNING THE ADMINISTRATIVE ASSESSMENT OF C

       Subpart F—Appeals and Administrative Review

       Sec. 22.29  Appeal from or review of interlocutory orders or rulings.

           (a) Request for interlocutory appeal.  Except as provided in this
       section, appeals to the Environmental Appeals Board shall obtain as a
       matter of right

       [[Page 235]}

       only from a default order, an accelerated decision or decision to
       dismiss issued under Sec.  22.20(b)(l), or an initial decision rendered
       after an evidentiary hearing.  Appeals from other orders or rulings shall
       lie only if the Presiding Officer or Regional Administrator, as
       appropriate, upon motion of a party,  certifies such orders or rulings to
       the Environmental Appeals Board on appeal. Requests for such
       certification shall be filed in writing within six (6) days of notice of
       the ruling or service of the order,  and shall state briefly the grounds
       to be relied upon on appeal.
           (b) Availability of interlocutory appeal. The Presiding Officer may
       certify any ruling for appeal to the Environmental Appeals Board when
       (1)  the order or ruling involves an important question of law or policy
       concerning which there is substantial grounds for difference of opinion,
       and (2) either (i)  an immediate appeal from the order or ruling will
       materially advance the ultimate termination of the proceeding, or  (ii)
       review after the final order is issued will be inadequate or
       ineffective.
           (c) Decision.  If the Environmental Appeals Board determines that
       certification  was improvidently granted, or if the Environmental Appeals
       Board takes no action within thirty (30) days of the certification, the
       appeal is dismissed.  When the Presiding Officer declines to certify an
       order  or ruling  to the Environmental Appeals Board on interlocutory
       appeal, it  may be reviewed by the Environmental Appeals Board only upon
       appeal from the  initial decision,  except when the Environmental Appeals
       Board  determines,  upon motion of a party and in exceptional
       circumstances, that to delay review would be contrary to the public
       interest. Such motion shall be made within six (6) days of service of an
       order  of the Presiding Officer refusing to certify a ruling for
       interlocutory  appeal  to the Environmental Appeals Board. Ordinarily, the
       interlocutory  appeal  will  be  decided on the basis of the submissions
      made by the Presiding Officer.  The Environmental Appeals Board may,
      however,  allow further  briefs  and oral argument.
           (d)  Stay of proceedings.  The Presiding Officer may stay the
      proceedings  pending a decision by the Environmental Appeals Board upon
      an order  or  ruling  certified  by the Presiding Officer for an
      interlocutory  appeal.  Proceedings  will not be stayed except in
      extraordinary  circumstances. Where the Presiding Officer grants a stay



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      of more than thirty (30)  days,  such stay must be separately approved by
      the Environmental Appeals Board.
      [45 FR 24363, Apr.  9,  1980,  as  amended at 57 FR 5325, Feb. 13,  1992]

      Sec. 22.30  Appeal  from or review of initial decision.

           (a) Notice  of appeal. (1) Any party may appeal an adverse ruling or
      order of  the Presiding Officer  by filing a notice of appeal and an
      accompanying appellate brief with the Environmental Appeals Board and
      upon all  other  parties and amicus curiae within twenty (20) days after
      the initial decision is served  upon the parties. The notice of appeal
      shall set forth alternative findings of fact, alternative conclusions
      regarding issues of law or discretion,  and a proposed order together
      with relevant references to the record and the initial decision. The
      appellant's brief shall contain a statement of the issues presented for
      review, a statement of the nature of the case and the facts relevant to
      the issues presented for review,  argument on the issues presented, and a
      short conclusion stating the precise relief sought, together with
      appropriate references to the record.
           (2) Within  fifteen (15)  days of the service of notices of appeal and
      briefs under paragraph (a)(1)  of this section, any other party or amicus
      curiae may file and serve with  the Environmental Appeals Board a reply
      brief responding to argument raised by the appellant, together with
      references to the relevant portions of the record, initial decision, or
      opposing  brief.  Reply briefs shall be limited to the scope of the appeal
      brief. Further  briefs shall be  filed only with the permission of the
      Environmental Appeals Board.
           (b) Sua sponte  review by the Environmental Appeals Board, whenever
      the Environmental Appeals Board determines sua sponte to review an
      initial decision, the Environmental Appeals Board shall serve notice of
      such intention  on the parties within forty-five (45) days after the
      initial decision is served upon

       [[Page 236]]

      the parties. The notice shall include a statement of issues to be
      briefed by the  parties and a time schedule for the service and filing of
      briefs.
           (c) Scope of appeal or review. If the Environmental Appeals Board
      determines that issues raised,  but not appealed by the parties, should
      be argued, it shall give counsel for the parties reasonable written
      notice of such  determination to permit preparation of adequate argument.
      Nothing herein  shall prohibit the Environmental Appeals Board from
      remanding the case  to the Presiding Officer for further proceedings.
           (d) Argument before the Environmental Appeals Board. The
      Environmental Appeals Board may,  upon request of a party or sua sponte,
      assign a  time and place for oral argument after giving consideration to
      the convenience of  the parties.
       [45 FR 24363, Apr.  9,  1980,  as  amended at 57 FR 5325, Feb. 13,  1992]
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       [Code of  Federal  Regulations]
       [Title 40, Volume 1,  Parts 1 to 49]
       [Revised  as  of  July 1,  1998]
      From the  U.S. Government Printing Office via GPO Access
       [CITE: 40CFR22]

       [Page 236-242]

                          TITLE 40—PROTECTION OF ENVIRONMENT

                      CHAPTER  I—ENVIRONMENTAL PROTECTION AGENCY

      PART 22—CONSOLIDATED RULES OF PRACTICE GOVERNING THE ADMINISTRATIVE ASSESSMENT OF C

      Subpart H—Supplemental Rules

      Sec. 22.33   Supplemental rules of practice governing the administrative
                assessment of civil penalties under the Toxic Substances
                Control Act.

           (a) Scope of  these  Supplemental rules. These Supplemental rules of
      practice  shall  govern,  in conjunction with the preceding consolidated
      rules of  practice (40 CFR part 22),  all formal adjudications for the
      assessment of any civil penalty conducted under section 16(a) of the
      Toxic Substances  Control Act (15 U.S.C. 2615(a)). Where inconsistencies
      exist between these Supplemental rules and the Consolidated rules,
       (Sees. 22.01 through 22.32), these Supplemental rules shall apply.
           (b) Subpoenas.  (1)  The attendance of witnesses or the production of
      documentary  evidence may be required by subpoena. The Presiding Officer
      may grant a  request for a subpoena upon a

       [[Page 237]]

      showing of  (i)  the grounds and necessity therefor, and (ii)  the
      materiality  and relevancy of the evidence to be adduced.  Requests for
      the production  of documents shall describe the evidence sought as
      specifically as practicable.
           (2) Subpoenas shall be served in accordance with Sec. 22.05(b)(1)  of
      the Consolidated  Rules  of Practice.
           (3) Witnesses summoned before the Presiding Officer shall be paid
      the same  fees and mileage that are paid witnesses in the courts of the
      United States.  Fees shall be paid by the party at whose instance the
      witness appears.  Where  a witness appears pursuant to a request initiated
      by the Presiding  Officer,  fees shall be paid by the agency.

      Sec. 22.34   Supplemental rules of practice governing the administrative
                assessment of civil penalties under title II of the Clean Air
                Act.

           (a) Scope of  these  Supplemental rules. These Supplemental rules
      shall govern, in  conjunction with the preceding Consolidated Rules of
      Practice  (40 CFR  part 22),  all proceedings to assess a civil penalty
      conducted under sections 205(c), 211(d), and 213(d) of the Clean Air
      Act, as amended (42 U.S.C.  7524(c),  7545(d), and 7547(d)). Where
      inconsistencies exist between these Supplemental rules and the
      Consolidated Rules  (Sees.  22.01 through 22.32), these Supplemental rules
      shall apply.
          (b) Issuance  of notice. (1)  Prior to the issuance of an
      administrative  penalty  order assessing a civil penalty, the person to
      whom the  order  is to be issued shall be given written notice of the
      proposed  issuance of the order.  Such notice shall be provided by the



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       issuance of a complaint pursuant to Sec. 22.13 of the Consolidated Rules
       of Practice.
           (2) Notwithstanding Sec. 22.15(a), any answer to the complaint must
       be filed with the Hearing Clerk within thirty  (30) days after service  of
       the complaint.
           (c) Subpoenas.  (1) The attendance of witnesses or the production of
       documentary evidence may be required by subpoena. The Presiding Officer
       may grant a request for a subpoena upon a showing of;
           (i) The grounds and necessity therefor, and
           (ii) The materiality and relevancy of the evidence to be adduced.

       Requests for the production of documents shall describe with specificity
       the documents sought.
           (2) Subpoenas shall be served in accordance with Sec. 22.05(b)(1)  of
       the Consolidated Rules of Practice.
           (3) Witnesses summoned before the Presiding Officer shall be paid
       the same fees and mileage that are paid in the courts of the United
       States. Fees shall be paid by the party at whose instance the witness
       appears. where a witness appears pursuant to a request initiated by the
       Presiding Officer, fees shall be paid by EPA.
       [57 FR  4318, Feb. 4, 1992]

       Sec. 22.35  Supplemental rules of practice governing the administrative
                 assessment of civil penalties under the Federal Insecticide,
                 Fungicide, and Rodenticide Act.

           (a) Scope of these Supplemental rules. These Supplemental rules of
       practice shall govern, in conjunction with the preceding Consolidated
       Rules of Practice (40 CFR part 22), all formal adjudications for the
       assessment of any civil penalty conducted under section 14(a) of the
       Federal Insecticide, Fungicide, and Rodenticide Act as amended  (7 U.S.C.
       1261 (a)). Where inconsistencies exist between these Supplemental rules
       and the Consolidated rules, (Sees. 22.01 through 22.32), these
       Supplemental rules shall apply.
           (b) Venue. The prehearing conference and the hearing shall be held
       in the county, parish, or incorporated city of the residence of the
       person charged, unless otherwise agreed in writing by all parties.
           (c) Evaluation of proposed civil penalty. In determining the dollar
       amount of the recommended civil penalty assessed in the initial
       decision, the Presiding Officer shall consider, in addition to the
       criteria listed in section 14 (a) (3) of the Act,  (1) respondent's history
       of compliance with the Act or its predecessor statute and  (2) any
       evidence of good faith or lack thereof. The Presiding Officer must also
       consider the guidelines for the Assessment of Civil Penalties published
       in the Federal Register (39 FR 27711), and any amendments or supplements
       thereto.

       {[Page 238]]

       Sec. 22.36   Supplemental rules of practice governing the administrative
                assessment of civil penalties and the revocation or suspension
                of permits under the Marine Protection, Research, and
                Sanctuaries Act.

           (a)  Scope of these Supplemental rules. These Supplemental rules
       shall  govern,  in conjunction with the preceding Consolidated Rules  of
       Practice (40  CFR part 22), all formal adjudications conducted under
       section 105(a)  or (f)  of the Marine Protection, Research, and
       Sanctuaries Act  as amended (33 U.S.C. 1415(a) and  (f)). Where
       inconsistencies  exist between these Supplemental rules and the
       Consolidated  Rules,  (Sees. 22.01  through 22.32), these Supplemental



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      rules shall apply.
          (b) Additional criterion  for  the  issuance of a complaint for the
      revocation or suspension  of a permit.  In  addition to the three criteria
      listed in 40 CFR 22.13  for issuing  a  complaint for the revocation or
      suspension of a permit, complaints  may be issued on the basis of a
      person's failure to  keep  records  and  notify appropriate officials of
      dumping activities,  as  required by  40 CFR 224.1 and 223.2.

      Sec. 22.37  Supplemental  rules of practice governing the administrative
                assessment of civil penalties under the Solid Waste Disposal
                Act.

          (a) Scope of these  Supplemental rules.  These Supplemental rules of
      practice shall govern,  in conjunction with the preceding Consolidated
      Rules of Practice  (40 CFR part 22), all proceedings to assess a civil
      penalty conducted under section 3008  of the Solid Waste Disposal Act (42
      U.S.C. 6928)  (the  ^Act11). Where inconsistencies exist between these
      Supplemental rules and  the Consolidated Rules,  (Sees.  22.01 through
      22.32), these Supplemental rules  shall apply.
          (b) Issuance of  notice. Whenever,  on  the basis of any information,
      the Administrator determines  that any person is in violation of (I)  any
      requirement of subtitle C of  the  Act,  (2)  any regulation promulgated
      pursuant to subtitle C  of the Act,  or (3)  a term or condition of a
      permit issued pursuant  to subtitle  C  of the Act,  the Administrator shall
      issue notice to the  alleged violator  of his failure to comply with such
      requirement, regulation or permit.
          (c) Content of notice. Each notice of violation shall include:
          (1) A specific reference  to each  provision of the Act,  regulation,
      or permit term or condition which the alleged violator is alleged to
      have violated; and
          (2) A concise statement of the  factual basis for alleging such
      violation.
          (d) Service of notice. Service  of notice shall be made in accordance
      with Sec. 22.05(b)(2) of  the  Consolidated Rules of Practice.
          (e) Issuance of  the complaint.  (1) Except as provided in paragraph
       (e)(3) of this section, the complainant may issue a complaint whenever
      he has reason to believe  that any violation extends beyond the thirtieth
      day after service of the  notice of  violation.
          (2) The complaint shall include,  in addition to the elements stated
      in Sec. 22.14 of the Consolidated Rules,  an order requiring compliance
      within a specified time period. The complaint shall be equivalent to the
      compliance order referred to  in section 3008 of the Act.
          (3) Whenever a violation  is of  a  non-continuous or intermittent
      nature, the Administrator may issue a complaint,  without any prior
      notice to the violator, pursuant  to Sec.  22.14 of the Consolidated Rules
      of Practice which may also require  the violator to take any and all
      measures necessary to offset  all  adverse  effects to health and the
      environment created,  directly or  indirectly,  as a result of the
      violation.
          (4) Notwithstanding Sec.  22.15(a), any answer to the complaint must
      be filed with the Regional Hearing  Clerk  within thirty  (30) days after
      the filing of the complaint.
          (f) Subpoenas.  (1)  The attendance of  witnesses or the production of
      documentary evidence may  be required  by subpoena. The Presiding officer
      may grant a request  for a subpoena  upon a showing of (i) the grounds and
      necessity therefor,  and (ii)  the  materiality and relevancy of the
      evidence to be adduced. Requests  for  the  production of documents shall
      describe with specificity the documents sought.
          (2) Subpoenas shall be served in  accordance with Sec. 22.05(b)(1) of
      the Consolidated Rules  of Practice.
          (3) Witnesses summoned before the Presiding Officer shall be paid



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       the

       [[Page 239]]

       same fees and mileage that are paid witnesses in the courts of the
       United States. Fees shall be paid by the party at whose instance the
       witness appears. Where a witness appears pursuant to a request initiated
       by the Presiding Officer, fees shall be paid by the Agency.
            (g) Final Orders to Federal Agencies on Appeal. (1) In the case of
       an administrative order or decision issued to a department, agency, or
       instrumentality of the United States, such order or decision  shall
       become the final order for purposes of the Federal Facility Compliance
       Act, 42 U.S.C. 6961(b), in accordance with Sees. 22.27
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      accorded party status with  right of cross examination unless they
      formally move to intervene  and are granted party status under
      Sec. 22.11.
          (e) Administrative procedure and judicial review.  Action of the
      Administrator for which  review could have been obtained under section
      509(b)(I) of the Act shall  not be subject to review in an administrative
      proceeding for the  assessment  of class  II civil penalty under section
      309(g).
          (f) Petitions to set aside an order and to provide a hearing.  If no
      hearing on the complaint is held before issuance of an order assessing a
      Class II civil penalty,  any person who  commented on the complaint may
      petition the Administrator,  within 30 days after issuance of the order,
      to set aside the order and  to  provide a hearing on the complaint.  If the
      evidence presented  by the petitioner in support of the petition is
      material and was not considered in the  issuance of the order,  the
      Administrator will  immediately set aside the

      [[Page 240}]

      order and provide a hearing in accordance with the Consolidated Rules of
      Practice and these  supplemental rules of practice.  If the Administrator
      denies a hearing under section 309(g)(4)(C)  of the Act,  the
      Administrator will  provide  to  the petitioner,  and publish in the Federal
      Register, notice of and  the reasons for the denial.
      [55 FR 23840, June  12, 1990]

      Sec. 22.39  Supplemental rules of practice governing the administrative
                assessment of  administrative  penalties under section 109 of
                the Comprehensive Environmental Response, Compensation,  and
                Liability Act  of  1980, as amended.

          (a) Scope of these Supplemental rules. These Supplemental rules of
      practice shall govern, in conjunction with the preceding Consolidated
      Rules of Practice  (40 CFR part 22), administrative proceedings for the
      assessment of any civil  penalty under section 109 of the Comprehensive
      Environmental Response,  Compensation, and Liability Act of 1980, as
      amended  (42 U.S.C.  9609). Where inconsistencies exist between these
      Supplemental rules  and the  Consolidated Rules (Sees. 22.01 through
      22.32), these Supplemental  rules shall  apply-
          (b) Subpoenas.  (1) The  attendance and testimony of witnesses or the
      production of relevant papers, books, and documents may be required by
      subpoena. The Presiding  Officer may grant a request for a subpoena upon
      a showing of—
          (i) The grounds and  necessity therefor,  and
          (ii) The materiality and relevancy  of the evidence to be adduced.

      Requests for the production of documents shall describe the evidence
      sought as specifically as practicable.
          (2) Subpoenas shall  be  served in accordance with Sec. 22.05(b) (1) of
      the Consolidated Rules of Practice.
          (3) Witnesses summoned  before the Presiding Officer shall be paid
      the same fees and mileage that are paid witnesses in the courts of the
      United States. Fees shall be paid by the party at whose instance the
      witness appears. Where a witness appears pursuant to a request initiated
      by the Presiding Officer, fees shall be paid by the Agency.
          (c) Judicial review.  Any person who requested a hearing with respect
      to a Class II civil penalty under section 109 of CERCLA and who is the
      recipient of a final order  assessing a  civil penalty may file a petition
      for judicial review of such order with  the United States Court of
      Appeals for the District of Columbia or for any other circuit in which
      such person resides or transacts business. Any person who requested a



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       hearing with respect to a Class I civil penalty under section 109 of
       CERCLA and who is the recipient of a final order assessing the civil
       penalty may file a petition for judicial review of such order with the
       appropriate district court of the United States .  All petitions must be
       filed within 30 days of the date the order making the assessment was
       issued.
           (d) Payment of civil penalty assessed. Payment of civil penalties
       finally assessed by the Regional Administrator shall be made by
       forwarding a cashier's check, payable to the "EPA, Hazardous Substances
       Superfund, ' ' in the amount assessed, and noting the case title and
       docket number, to the appropriate regional Superfund Lockbox Depository.
       Notice of payment must be sent by Respondent to the Hearing Clerk for
       inclusion as part of the administrative record for the proceeding in
       which the civil penalty was assessed. Interest on overdue payments shall
       be collected pursuant to the Debt Collection Act, 37 U.S.C. 3717.
       [54 FR 21176, May 16, 1989]

       Sec. 22.40  Supplemental rules of practice governing the administrative
                 assessment of administrative penalties under section 325 of
                 the Emergency Planning and Community Right-To-Know Act of 1986
                 (EPCRA) .

           (a) Scope of these Supplemental Rules. These Supplemental rules of
       practice shall govern, in conjunction with the preceding Consolidated
       Rules of Practice (40 CFR part 22), administrative proceedings for the
       assessment of any civil penalty under section 325 for violations of the
       Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA) .
       Where inconsistencies exist between these Supplemental rules and the
       Consolidated Rules,   (Sees. 22.01

       [[Page 241]]

       through 22.32) these Supplemental rules shall apply.
           (b) Subpoenas. (1) The attendance and testimony of witnesses or the
       production of relevant papers, books, and documents may be required by
       subpoena. The Presiding Officer may grant a request for a subpoena upon
       a showing of  (i)  the grounds and necessity therefore, and  (ii) the
       materiality and relevancy of the evidence to be adduced. Requests for
       the production of documents shall describe the evidence sought as
       specifically as practicable.
           (2) Subpoenas shall be served in accordance with Sec. 22.05(b) (1) of
       the Consolidated Rules of Practice.
           (3) Witnesses summoned before the Presiding officer shall be paid
       the same fees and mileage that are paid witnesses in the courts of the
       United States. Fees  shall be paid by the party at whose instance the
       witness appears.  Where a witness appears pursuant to request initiated
       by the Presiding Officer,  fees shall be paid by the Agency.
           (c)  Judicial  review.  Any person against whom a civil penalty is
       assessed may seek judicial review in the appropriate district court of
       the United States by filing a notice of appeal and by simultaneously
       sending a copy of such notice by certified mail to the Administrator.
       The notice must be filed within 30 days of the date the order making
       such assessment was  issued. The Administrator shall promptly file in
       such court a  certified copy of the record upon which such violation Was
       found  or  such penalty imposed.
           (d)  Procedures for collection of civil penalty. If any person  fails
       to  pay  an assessment  of a  civil penalty after it has become a final and
       unappealable  order or after the appropriate court has entered final
       judgment  in  favor of  the United States, the Administrator may request
       the Attorney  General  of the United States to institute a civil action in
       an  appropriate district court of the United States to collect the
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      penalty, and such court  shall have jurisdiction to hear and decide any
      such action. In hearing  such action,  the court shall have authority to
      review the violation  and the assessment of the civil penalty on the
      record. Interest on overdue payments  shall be collected pursuant to the
      Debt Collection Act,  37  U.S.C.  3717.
      [54 FR 21176, May 16,  1989]

      Sec. 22.41  Supplemental rules of practice governing the administrative
                assessment  of  civil penalties under Title II of the Toxic
                Substances  Control Act,  enacted as section 2 of the Asbestos
                Hazard Emergency Response Act (AHERA).

           (a) Scope of the  Supplemental rules. These Supplemental rules of
      practice shall govern, in conjunction with the preceding Consolidated
      Rules of Practice  (40 CFR part 22),  all proceedings to assess a civil
      penalty conducted under  section 207 of the Toxic Substances Control Act
      (the ^Act1')  (15 U.S.C.  2647). Where inconsistencies exist between
      these Supplemental rules and the Consolidated rules (Sees.  22,01 through
      22.32), these Supplemental rules shall apply.
           (b) Collection of civil penalty.  Any civil penalty collected under
      section 207 of the Act shall be used  by the local educational agency for
      purposes of complying with Title II of the Act.  Any portion of a civil
      penalty remaining unspent after a local educational agency achieves
      compliance shall be deposited into the Asbestos Trust Fund established
      under section 5 of AHERA.
      [54 FR 24112, June 5,  1989]

      Sec. 22.42  Supplemental rules of practice governing the administrative
                assessment  of  civil penalties for violations of compliance
                orders issued  under Part B  of the Safe Drinking Water Act.

           (a) Scope of these supplemental rules. These supplemental rules of
      practice shall govern, in conjunction with the preceding Consolidated
      Rules of Practice  (40 CFR part 22),  all proceedings to assess a civil
      penalty under section 1414(g)(3)(B).  Where inconsistencies exist between
      these supplemental rules and the Consolidated rules,  these supplemental
      rules shall apply.
           (b) Definition of * *person.''  In  addition to the terms set forth in
      40 CFR 22.03(a) that  define person,  for purposes of this section and
      proceedings under section 1414(g) (3) (B) of the Safe Drinking Water Act,
      the term person shall also include

      [[Page 242]]

      any officer, employee, or agent of any corporation, company or
      association.
           (c) Issuance of complaint.  If the Administrator determines that a
      person has violated any  provision of  a compliance order issued under
      section 1414(g)(1) of the Safe Drinking Water Act, 42 U.S.C. 300g-
      3(g)(1), he may institute a proceeding for the assessment of a civil
      penalty by issuing a  complaint under  the Act and this part.
           (d) Content of the complaint.  A complaint for the assessment of
      civil penalties under this part shall include specific reference to:
           (1) Each provision of the compliance order issued under section
      1414(g)(1) of the Act, 42 U.S.C.  300g-3(g)(1), which is alleged to have
      violated; and
           (2) Each violation of a Safe Drinking Water Act regulation,
      schedule, or other requirement which  served as the basis for the
      compliance order which is alleged to  have been violated.
          (e) Scope of hearing.  Action of the Administrator with respect to
      which judicial review could have been obtained under section 1448 of the



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       Safe Drinking Water Act,  42 U.S.C.  300j-7,  shall not be subject to
       review  in an administrative proceeding  for  the assessment of a civil
       penalty under section  1414(g)(3) (B)  of  the  SDWA and this part.
       [56 FR  3757, Jan.  30,  1991]

       Sec. 22.43 Supplemental  rules of practice  governing the administrative
                  assessment of civil penalties  under section 113(d)(l) of the
                  Clean Air Act.

            (a) Scope of these Supplemental  rules.  These Supplemental rules
       shall govern, in conjunction with the preceding Consolidated Rules of
       Practice  (40 CFR part  22), all proceedings  to assess a civil penalty
       conducted under section 113(d)(1) of the Clean Air Act (42 U.S.C.
       7413(d)(l)). Where inconsistencies  exist between these Supplemental
       rules and the Consolidated Rules  (Sees.  22.01 through 22.32), these
       Supplemental rules shall  apply.
            (b) Issuance of notice.  (1) Prior to the issuance of an
       administrative penalty order assessing  a civil penalty,  the person to
       whom the  order is  to be issued shall be  given written notice of the
       proposed  issuance  of the  order. Such

       notice  shall be provided  by the issuance of a complaint pursuant to
       Sec. 22.13 of the  Consolidated Rules of  Practice.
            (2) Notwithstanding Sec. 22.15(a),  any  answer to the complaint must
       be filed  with the  Regional Hearing  Clerk within thirty (30)  days after
       service of the complaint.
            (c) Subpoenas.  (1) The attendance of witnesses or the production of
       documentary evidence may  be required by  subpoena.  The Presiding Officer
       may grant a request for a subpoena  upon  a showing of;
            (i) The grounds and necessity therefor,  and
            (ii)  The materiality  and relevancy of the evidence to be adduced.

       Requests  for the production of documents shall describe with specificity
       the documents sought.
           (2) Subpoenas  shall be served in accordance with Sec. 22.05(b)(1) of
       the Consolidated Rules of Practice.
           (3) Witnesses  summoned before the Presiding Officer shall be paid
       the same  fees and  mileage that are paid  in  the courts of the United
       States. Fees shall be paid by the party  at  whose instance the witness
       appears. Where a witness  appears pursuant to a request initiated by the
       Presiding  Officer, fees shall be paid by EPA.
       [57 FR  4318,  Feb.  4, 1992]

                Appendix  to Part 22—Addresses  of  EPA Regional Offices

       Region I—John F.   Kennedy Federal Building,  Boston,  MA 02203.
       Region II—26 Federal Plaza, New York, NY 10007.
       Region III—Curtis Building, 6th and Walnut Streets, Philadelphia, PA
       19106.
       Region IV—345 Courtland  Street NE., Atlanta,  GA 30308.
       Region V—77  West  Jackson Boulevard, Chicago,  IL 60604.
       Region VI—First International Building,  1201 Elm Street, Dallas, TX
       75270.
       Region  VII—1735 Baltimore Street, Kansas City,  MO 64108.
       Region  VIII—1860  Lincoln Street, Denver, CO 80203.
       Region  IX—215  Fremont Street,  San Francisco,  CA 94105.
       Region  X—1200  6th Avenue, Seattle, WA 98101.
       [45 FR  24363, Apr.  4,  1980,  as amended at 62 FR 1833, Jan. 14, 1997]

       [[Page  243]]
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            WELCOME  TO SUBPART I
                £IPA\ U^ 11^,-APA 0WW SU,
      The proposed amendments to 40 CFRPart 22 contain a something new - Subpart I.
Subpart I is the non-APA procedural rule which completely replaces the proposed Part 28.
Subpart I is to be used as of the effective date of the proposed Part 22 rule.  The following are
eight tips for using our new procedural rule:

       1) Subpart I relies on the use of many sections already contained in Part 22.  Therefore,
good Part 22 practitioners will also be good Subpart I practitioners!

      2) If your statute makes the proceeding subject to Section 554 of the Administrative
Procedure Act - STOP - you may not use Subpart I.  If your statute authorizes the use of non-
APA procedure you MAY use Subpart I.

      3) Your complaints must specifically state that EPA is bringing the action under Subpart I.

      4) The following provisions do not apply to Subpart I proceedings:

             22. 1 1 - There will be no intervention nor amicus curiae in Subpart I proceedings.

             22. 16(c) - The Regional Judicial Officer serves as the Presiding Officer for Subpart
                      I proceedings and will rule on all motions until an Initial Decision
                      becomes final or is appealed.

             22.2 l(a) - After an Answer is filed there is no need to forward the file to the Chief
                      Administrative Law Judge because all Subpart I proceedings will be
                      handled by the Regional Judicial Officer.

             22.29 - There is NO right to interlocutory appeal in Subpart I cases.

      5) Where Subpart I applies, it supersedes any conflicting provisions in Subparts A - G.
However, note that Subpart H (the "supplemental rules") supersedes any conflicting provisions in
Subparts I or Subparts A - G.

      6) In Subpart I cases, Respondent's have an additional obligation to  submit any
information on economic benefit, including gross revenues and delayed or avoided costs in their
prehearing exchange.

      7) In Subpart I cases, Respondent's have NO right to 22.19(e) discovery.

      8) In Subpart I cases, EPA may use 22.19(e) to discover information on Respondent's
economic benefit and/or ability to pay a penalty.

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       Subpart I - Administrative Proceedings not Governed by §554 of the Administrative
       Procedure Act
§22.50 Scope of this Subpart.
       (a) Scope.   This Subpart applies to any adjudicatory proceedings where the complainant
       designates in the complaint that Subpart I shall apply, except that the procedures of this
       Subpart shall not apply in any case where the Act makes the proceeding subject to §554 of
       the Administrative Procedure Act, 5 U.S.C. 554.
       (b) Relationship to other provisions.  Sections 22.01 through 22.45 apply to proceedings
       under this Subpart, except for the following provisions which do not apply: 22.11,
       22.16(c), 22.21(a), and 22.29. The provisions of this Subpart shall supersede any
       conflicting provisions of subparts A through G. The provisions of subpart H shall
       supersede any conflicting provisions of this subpart or of subparts A through G.
§22.51 Presiding Officer.
       The Presiding Officer shall be a Regional Judicial  Officer. The Presiding Officer shall rule
       on all motions until an initial decision has become final or has been appealed.
§22.52 Information exchange and discovery.
       Respondent's information exchange pursuant to §22.19(a) shall include information on
       any economic benefit resulting from any activity or failure to act which is alleged in the
       administrative complaint to be a violation of applicable law, including its gross revenues,
       delayed or avoided costs. Discovery under §22.19(e) shall not be authorized, except for
       discovery of information concerning respondent's economic benefit from alleged
       violations and information concerning respondent's ability to pay a penalty.
§22.53 Interlocutory orders or rulings.

       Interlocutory review as set forth in §22.29 is prohibited.

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    _   Section 22.50: Section 22.50 defines the scope of Subpart I. Subsection (a) indicates that
 the initial decision to bring a proceeding pursuant to Subpart I is made by the Agency and requires
 that the Agency indicate such decision in the complaint.  The Agency may in any case decline to
 apply Subpart I and instead give the respondent the greater process of law afforded by a
 proceeding conforming to section 554 of the APA. Subsection (a) acknowledges that the Agency
 may not apply Subpart I  where a statute requires a hearing in accordance with section 554 of the
 Administrative Procedure Act.  Examples where Congress has authorized EPA to administratively
 assess penalties through proceedings that are not subject to the requirements of section 554 in
 certain circumstances include:  CWA §309(g)(2)(A) and §31 l(b)(6)(A) & (B)(i) (33 USC
 1319(g)(2)(A) and 1321(b)(6)(A) & (B)(i)); section 109(a) of the Comprehensive Environmental
 Response, Compensation and Liability Act (CERCLA) (42 USC 9609(a)); section 325(b)(l), (c),
 and (d) of the Emergency Planning and Community Right-To-Know Act (EPCRA) (42 USC

 11045(b)(l), (c), and (d)); SDWA §1414(g)(3)(B) (42 USC 300g-3(g)(3)(B)); and CAA
 §113(d)(3),(42 USC 7413(d)(3)); and issuance of a penalty-only order or a penalty/compliance
 order under SDWA §1423(c) (42 USC 300h-2(c)). At this time, EPA does not intend to alter its
 present practice of providing the full APA process in CERCLA and EPCRA cases,  although if
 circumstances warrant, the Agency may in the future exercise its authority to assess CERCLA and
 EPCRA penalties through non-APA proceedings.  EPA welcomes comment concerning the types
 of CERCLA and  EPCRA penalty cases for which non-APA procedures would be appropriate.
        Subsection (b) describes how the Subpart works in conjunction with the preceding
 sections of the CROP, and also identifies those sections of the CROP which are inapplicable to a
 non-APA proceeding brought under Subpart I.
        Section 22.51:  The term "Presiding Officer" would be defined for  the purposes of a
 proceeding under this subpart to mean a Regional Judicial Officer, and provides that the Regional
 Judicial Officer shall rule on all motions, notwithstanding the provisions of Section 22.16(c) which
 provide that post-answer motions be ruled on by the Administrative Law Judge.
       Section 22.52:  This section defines the parameters of information exchange for purposes
 of non-APA proceedings. The Agency's goal is to encourage complete and voluntary information
 exchange by the parties and limit unnecessary motion practice.   Parties would be subject to the
 prehearing information exchange authorized in Section 22.19(a), but most additional discovery
 would be prohibited under this Subpart. The subsection would also require the respondent to
 provide in its prehearing exchange information in regard to any economic benefit it may have
 enjoyed as a result of the alleged non-compliance or a failure to act.  Requiring this  information
 up-front will help to clarify penalty issues early on, and avoid excessive and time-consuming
 motion practice.
       The proposed Section 22.52 would prohibit most additional discovery that would
 otherwise be allowed under Section 22.19(e).  Although it would prohibit  most discovery, the
 complainant would be entitled to discovery of information concerning respondent's economic
 benefit of noncompliance and of financial records probative of respondent's ability to pay a
 penalty. Under several statutes, this information must be made part of the administrative record
 supporting a penalty determination, but it generally is not available to the Agency except through
 discovery of the respondent. Accordingly, discovery of this information must be permitted in
 order to prevent respondents from avoiding enforcement by simply withholding information.
       Section 22.53: This section prohibits interlocutory appeals in proceedings under this
 Subpart. The Agency sees little value in allowing interlocutory appeals in these relatively informal
 enforcement actions, particularly since parties to a proceeding under Subpart I retain full appeal
rights once an initial decision is issued.  The Agency is particularly concerned that permitting
interlocutory appeals would slow resolution of non-APA enforcement actions considerably.

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   (A) The extent to which the petition states an issue relevant and
material to the issuance of the consent order;
   (B) Whether complainant adequately considered and responded to the
petition; and
   (C) Whether a resolution of the action by the parties is
appropriate without a hearing.
   (vi) Upon a finding by the Petition Officer that a hearing is
appropriate, the Presiding Officer shall order that the proposed
consent order be set aside and shall establish a schedule for a
hearing.
   (vii) Upon a finding by the Petition Officer that a resolution of
the action without a hearing is appropriate, the Petition Officer shall
deny the petition and:
   (A) File with the Regional Hearing Clerk;
   (B) Send copies to the parties and the commenter; and
   (C) Publish,  as required by law,  an order denying the petition and
stating the reasons for such denial.
   (viii) Upon a finding by the Petition Officer that a resolution of
the action without a hearing is appropriate, the Regional Administrator
may issue the consent order, which shall become final 30 days after
both the order denying the petition and a properly signed consent order
are filed with the Regional Hearing Clerk,  unless further petition for
review is  filed by a notice of appeal in the appropriate United States
District Court,  with coincident notice by certified mail to the
Administrator and the Attorney General. Written notice of appeal also
shall be filed with the Regional Hearing  Clerk, and sent to the
Presiding Officer and the parties.
   (ix) If judicial review of the consent order is denied, the consent
order shall become final 30 days after such denial has been filed with
the Regional Hearing Clerk.
 Sees. 22.46-22.49 [Reserved].

 Subpart I-Administrative Proceedings Not Governed by Section 554
 of the Administrative Procedure Act
Sec. 22.50 Scope of this subpart.

   (a) Scope. This subpart applies to any adjudicatory proceedings
where the complainant designates in the complaint that subpart I shall
apply, except that the procedures of this subpart shall not apply in
any case where the Act makes the proceeding subject to section 554 of
the Administrative Procedure Act, 5 U.S.C. 554.

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  (b) Relationship to other provisions. Sections 22011 through 22.45
apply to proceedings under this subpart, except for the following
provisions which do not apply: Sees. 22.11, 22.16(c), 22.21 (a), and
22.29. The provisions of this subpart shall supersede any conflicting
provisions of subparts A through G of this part. The provisions of
subpart H of this part shall supersede any conflicting provisions of
this subpart or of subparts A through G of this part.

[[Page 9494]]

Sec. 22.51 Presiding Officer.

  The Presiding Officer shall be a Regional Judicial Officer. The
Presiding Officer shall rule on all motions until an initial decision
has become final or has been appealed.


Sec. 22.52 Information exchange and discovery.

  Respondent's information exchange pursuant to Sec. 22.19(a) shall
include information on any economic benefit resulting from any activity
or failure to act which is alleged in the administrative complaint to
be a violation of applicable law, including its gross revenues, delayed
or avoided costs. Discovery under Sec. 22.19(e) shall not be
authorized, except for discovery of information concerning respondent's
economic benefit from alleged violations and information concerning
respondent's ability to pay a penalty.


Sec. 22.53 Interlocutory orders or rulings.

  Interlocutory review as set forth in Sec. 22.29 is prohibited.

Appendix A to Part 22—Addresses of EPA Regional Offices and
Headquarters

Environmental Protection Agency, Region I~John F. Kennedy Federal
Building, One Congress Street, Boston, MA 02203.
Environmental Protection Agency, Region 11-290 Broadway, New York,
NY 10007-1866.
Environmental Protection Agency, Region 111-841 Chestnut Building,
Philadelphia, PA, 19107.
Environmental Protection Agency, Region IV--Atlanta Federal Center,
100 Alabama Street, S.W., Atlanta, GA 30365.
Environmental Protection Agency, Region V--77 West Jackson

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  Statutory Penalties Sections  Requiring  Consideration of Enumerated Factors


 Commentary - The following statutory sections require consideration of enumerated factors in
          determining the amount of a civil penalty assessed.  The statutes provide the authority for
          assessing  penalties, and establish a maximum penalty that may be assessed.  However,
          only in rare instances will the maximum be assessed.   The factors that must be considered
          tend to lower assessed penalties.
                  EPA penalty policies provide detailed guidance as to how to determine penalty
          amounts and take the statutory factors into  account.  Each penalty policy is specific to
          a statute,  and may even be specific to a section within a statute.  The penalty policy for
          each statute should be checked to determine which sections  of the statute the policy
          applies to.

 I.  TSCA - section 2615(a)
 (l)Any person who violates a provision of section 2614 or 2689 of this title shall be liable to the United States for a civil penalty
          in an amount not to exceed $25,000 for each such violation.  Each day such a violation continues shall, for purposes of
          this subsection, constitute a separate violation of section 2614 or 2689 of this title.
 (2) (B)In determining the amount of a civil penalty, the Administrator shall take into account the nature, circumstances, extent,
          and gravity of the violation or violations and, with respect to the violator, ability to pay, effect on ability to continue
          business, any history of prior such violations, the degree of culpability, and such other matters as justice may require.
 (2)(C)The Administrator may compromise, modify, or remit, with or without conditions,  any civil penalty which may be
          imposed under this subsection. The amount of such penalty, when finally determined, or the amount agreed upon in
          compromise, may be deducted from any sums owing by the United States to the person charged.

 II.  RCRA - section 6928fa)(3)
          Any order issued pursuant to this subsection may include a suspension or revocation of any permit issued by the
          Administrator or a State under this subchapter and shall state with reasonable specificity the nature of the violation.
         Any penalty assessed in the order shall not exceed $25,000 per day of noncompliance for each violation of a
          requirement of this subchapter.  In assessing such a penalty, the Administrator shall take into account the seriousness
         of the violation and any good faith efforts to comply with applicable requirements.
 section 6991e (underground storage tank regulationl
 (a)(3)If a violator fails  to comply with an order under this subsection within the time specified in the order, he shall be liable for
         a civil penalty of not more than $25,000 for each day of continued noncompliance.
 (c)Any order issued under this section shall state with reasonable specificity the nature of the violation, specify a reasonable time
         for compliance, and assess a penalty,  if any, which the Administrator determines is reasonable taking into account the
         seriousness of the violation and any good faith efforts to comply with  the applicable requirements.
 section 6992d (medical waste tracking program)
 (d)Any person who violates any requirement of or regulation under this subchapter shall be liable to the United States  for a civil
         penalty in an  amount not to exceed $25,000 for each such violation.   Each day of such violation shall, for purposes of
         this section, constitute a separate violation.
 (E)Civil penalties assessed by the United States  or by the States under this subchapter shall be assessed in accordance  with the
        Administrator's "RCRA Civil Penalty  Policy", as such policy may be amended from time to time.

 III.  CERCLA - section 9609(a)(3)
        In determining the amount of any penalty assessed pursuant to this subsection, the President shall take into account the
        nature, circumstances, extent and gravity of the violation or violations and, with respect to the violator, ability to pay,
        any prior history of such violations, the degree of culpability, economic benefit or savings (if any) resulting from the
        violation, and such other matters as justice may require.

IV. EPCRTKA - section  11045
(b)(l)(C) [penalty for emergency notification] In determining the amount of any penalty assessed pursuant to this subsection, the
        Administrator shall take into account the nature, circumstances, extent and gravity of the violation or violations and,
        with respect to the violator, ability to pay, any prior history of such violations, the degree of culpability, economic
        benefit or savings (if any) resulting from the violation, and such other matters as justice may require.
                                                                                                          00004

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V.  FIFRA - section 136/faH41
         In determining the amount of the penalty, the Administrator shall consider the appropriateness of such penalty to the
         size of the business of the person charged, the effect on the person's ability to continue in the business, and the gravity
         of the violation.  Whenever the Administrator finds that the violation occurred despite the exercise of due care or did
         not cause significant harm to health or environment, the Administrator may issue a warning in lieu of assessing a
         penalty.

VI.  CAA - section 7413(e)m
         In determining the amount of any penalty to be assessed under this section or section 7604(a) of this  title, the
         Administrator or  the court,  as appropriate, shall take into consideration (in addition to such other factors as justice
         may require) the size of the business, the economic impact of the penalty on the business, the violator's full compliance
         history  and good faith efforts to comply, the duration of the violation as established by any credible evidence
         (including evidence other than the applicable test method), payment by the violator of penalties previously assessed for
         the same violation, the economic benefit of noncompliance, and the seriousness of the violation. The court shall not
         assess penalties for noncompliance with administrative subpoenas under section 7607(a) of this title,  or actions under
         section  7414 of this title, where the violator had sufficient cause to violate or fail or refuse to comply with such
         subpoena or action.
section 7524Cc'>(2)   fmotor vehicle emissionsl
         In determining the amount of any civil penalty assessed under this subsection, the Administrator shall take into
         account the gravity of  the violation, the economic benefit or savings  (if any) resulting from the violation, the size of
         the violator's business, the violator's history of compliance with this subchapter, action taken to remedy the violation,
         the effect of the penalty on the violator's  ability to continue in business, and such other matters as justice may  require.

VII.  CWA  TFWPCA1 - section 1319
(d) [ civil penalties] Any person who violates section 1311, 1312,  1316,  1317,  1318, 1328, or 1345 of this title,  or any permit
         condition or limitation  implementing any of such sections in a permit issued under section 1342 of this title by the
         Administrator, or by a State, or  in a permit issued under section 1344 of this title by a State, or any requirement
         imposed in a pretreatment program approved under section 1342(a)(3) or  1342(b)(8) of this title, and any person who
         violates any order issued by the Administrator under subsection (a) of this section, shall be subject to a civil penalty
         not to exceed $25,000 per day for each violation. In determining the amount of a civil penalty, the court shall
         consider the seriousness of the violation or violations, the economic benefit (if any) resulting from the violation, any
         history  of such violations, any good-faith efforts to comply with the applicable requirements, the economic impact of
         the penally on the violator, and such other matters as justice may require.  For purposes of this subsection, a single
         operational upset which leads to simultaneous violations of more than one pollutant parameter shall be treated  as a
         single violation.

VIII. ESA - section 1540(a)
         Any person who knowingly violates, and any person engaged in business as an importer or exporter offish, wildlife, or
         plants who violates, any provision of this chapter, or any provision of any permit or certificate issued hereunder, or of
         any regulation issued in order to implement subsection (a)(l)(A), (B), (C), (D), (E), or (F), (a)(2)(A),  (B), (C). or (D),
         (c), (d)  (other than regulation relating to  recordkeeping or filing of reports), (0 or (g) of section 1538 of this title, may
         be assessed a civil penalty by the Secretary of not more than $25,000 for each violation.  Any person who knowingly
         violates, and any person engaged in business as an  importer or exporter offish, wildlife, or plants who violates,  any
         provision under this chapter  may be assessed a civil penalty by the Secretary of not more than $12,000 for each such
         violation.  Any person  who otherwise violates any provision of this chapter, or any regulation, permit, or certificate
         issued hereunder, may  be assessed a civil penalty by the Secretary of not more than $500 for each such violation. No
         penalty  may be assessed under this subsection unless such person is given notice and opportunity for a hearing with
         respect  to such violation.  Each violation shall be a separate offense.  Any such civil penalty may be remitted or
         mitigated by the Secretary.  Upon any failure to pay a penalty assessed under this subsection, the Secretary may
         request  the Attorney General to institute a civil action in a district court of the United States for any  district in which
         such person is found, resides, or transacts business to collect the penalty and such  court shall have jurisdiction to hear
         and decide any such action.  The court shall  hear such action on the record made before the Secretary and shall sustain
         his action if it is supported by substantial evidence on the record considered as a whole.
                                                                                                              000048

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     POLICY ON CIVIL PENALTIES
EPA GENERAL ENFORCEMENT POLICY tGM - 21
           UNITED STATES ENVIRONMENTAL
                PROTECTION AGENCY .

           EFFECTIVE DATE:  hfctf I fl BR4

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                             57
                              -1-
      This document,  Policy on Civil Penalties,  establishes  a
single  set  of  goals  for penalty assessment in EPA  administrative
and  judicial enforcement actions.   These goals  - deterrence,
fair and equitable treatment of the regulated community, and
swift resolution  of  environmental  problems - are presented  here
in general  terms.  An  outline of the general process  for the
assessment  of  penalties is contained in Attachment A.

      A  companion  document, A Framework for Statute-Specific
Approaches  to  Penalty  Assessments,  will also be issued today.
This document  provides guidance to the user of  the policy on
how  to  write penalty assessment guidance specific to  the user's
particular  program.  The first part of the Framework  provides
general guidance  on  developing program-specific guidance; the
second  part contains a detailed appendix which explains the basis
for  that guidance.   Thus,  the user need only refer to the appendix
when he wants  an  explanation of the guidance in the first part of
the  Framework.

      In order  to  achieve .the above  Agency policy goals, all
administratively  imposed penalties  and settlements of civil
penalty actions should,  where possible,  be consistent with  the
guidance contained in  the  Framework document.  Deviations from     **
the  Framework * s methodology,  where  merited, are authorized as      ":
long as the reasons  for the deviations are documented.  Documen-
tation  for  deviations  from the Framework in program-specific
guidance should be located in that  guidance.  Documentation for
deviations  from the  program-specific guidance in calculating
individual  penalties should be contained in both the  case files
and  in  any  memoranda that  accompany the  settlements.

      The Agency will make  every effort to urge administrative
law  judges  to  impose penalties consistent with this policy and
any  medium-specific  implementing guidance.  For cases that go
to court, the Agency will  request  the statutory maximum penalty
in the  filed complaint.  And,  as proceedings warrant, EPA will
continue to pursue a penalty no less than that supported by the
applicable  program policy;   Of course,  all penalties must be consis-
tent with applicable statutory provisions,  based upon the number.
and  duration of the  violations at  issue.
Applicability
     This policy statement does  not  attempt to address the
specific mechanisms for achieving  the  goals set out for penalty
assessment.  Nor does it prescribe a negotiation strategy to
achieve the penalty target figures,  similarly, it does not
address differences between statutes or  between priorities of
different programs.  Accordingly,  it cannot be used, by itself,
as a basis for determining an  appropriate penalty in a specific

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                              -2-

action.  Each EPA program office, in a joint effort with the
Office of Enforcement and Compliance Monitoring, .will revise
existing policies, or write new policies as needed.  These
policies will guide the assessment of penalties under each
statute in a manner consistent with this document and, to the
extent reasonable, the accompanying Framework*

     Until new program-specific policies are issued, the
current penalty policies will remain in effect.  Once new
program-specific policies are issued, the Agency should
calculate penalties as follows:

          0  For cases that are substantially settled,.
             apply .the old policy.

          e  For cases that will require further sub-
             stantial negotiation, apply the new policy
             if that will not be too disruptive.

     Because of the unique issues associated with civil penal-
ties in certain types of cases, this policy does not apply to
the following areas:

          0  CERCLA S107.  This is an area in which
             Congress has directed a particular kind
             of response explicitly oriented toward
             recovering the cost of Government cleanup
             activity and natural resource damage.
                           %
          0  Clean Water Act S311(f) and (g).  This also
             is cost recovery in nature.  As in CERCLA
             §107 actions, the penalty assessment
             approach is inappropriate.

          0  Clean Air Act S120.  Congress has set out in
             considerable detail the level of recovery
             under this section.  It has been implemented
             with regulations which, as required by law,
             prescribe a non-exclusive remedy which
             focuses on recovery of the economic benefit
             of noncompliance.  It should be noted, how-
             ever, that this general penalty policy builds
             upon, and is consistent with the approach
             Congress took in that section.

     Much of the rationale supporting  this policy  generally
applies to non-profit institutions,  including government  entities.
In applying this policy to such entities, EPA. must exercise  judg-
ment case-by^case in deciding, for example,  how  to apply  the
economic benefit and ability to pay  sanctions,  if  at  all.   Further
guidance on the issue of seeking penalties against non-profit
entities will be forthcoming.

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Deterrence
     The  first goal  of  penalty assessment is  to  deter people  from
violating the law.   Specifically,  the penalty should  persuade the
violator  to take precautions  against falling  into  noncompliance
again  (specific deterrence) and dissuade  others" from  violating the
law  (general deterrence).  Successful deterrence is important
because it provides  the best  protection for the  environment.  In
additio'n, it reduces the resources necessary  to  administer  the
laws by addressing noncompliance before it occurs.

     If a penalty is to achieve deterrence, both the  violator and
the general public must be convinced that the penalty places the
violator  in a worse  position  than  those whp have complied in a
timely fashion.  Neither the  violator nor the general public
is likely to believe this  if  the violator is  able  to  retain an
overall advantage from  noncompliance.   Moreover, allowing a
violator  to benefit  from noncompliance punishes  those who have
complied by placing  them at a competitive disadvantage.  This
creates a disincentive  for compliance.  For these  reasons,  it
is Agency policy that penalties generally should,  at  a minimum,
remove any significant  economic benefits  resulting from failure
to comply with the law.  This amount will be  referred to as the
"benefit component"  of  the penalty.
                      *
     Where the penalty  fails  to remove  the significant economic
benefit, as defined  by  the program-specific guidance, the case
development team must explain in the case file why it fails to do
so.  The case development team must  then  include this explanation
in the memorandum accompanying each  settlement for the signature
of the Assistant Administrator of  Enforcement and Compliance
Monitoring, or the appropriate Regional official.

     The removal of  the economic benefit  of noncompliance only
places the violator  in  the same position  as he would  have been if
compliance had been  achieved  on time.   Both deterrence and funda-
mental fairness require that  the penalty  include an additional
amount to ensure that the violator is  economically worse off than
if it had obeyed the law.  This additional amount  should reflect
the seriousness of the  violation.   In  doing so,  the penalty will
be perceived-as fair.   In addition the  penalty's size will  tend
to deter other potential violators.

     In some classes of cases,  the normal gravity  calculation may
be insufficient to effect general  deterrence.  This could happen
if, for example, there  was extensive noncompliance with certain
regulatory programs  in  specific areas  of  the  United States.  This
would demonstrate that  the normal-penalty assessments had not been
achieving general deterrence.   In  such cases,  the  case development
team should consider increasing the  gravity component sufficient  to

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                               -4-

 achieve  general deterrence.  These  extra  assessments should
 balance  the other goals of  this  policy, particularly equitable
 treatment  of  the regulated  community.

      This  approach  is consistent with  the civil penalty
 provisions in the environmental  laws.  Almost all of them
 require  consideration of  the seriousness  of  the violation.
 This  additional amount which reflects  the seriousness of the
 violation  is  referred to  as the  "gravity  component".  The
 corabinajtion of the  benefit  and gravity components yields the
 "preliminary  deterrence figure."

      As  explained later in  this  policy, the  case development
 team  will  adjust this figure as  appropriate.  Nevertheless, EPA
 typically  should seek to  recover, at a minimum, a penalty which
 includes the  benefit component plus some  nonrtrivial gravity
 component.  This is important  because  otherwise, regulated
 parties  would have  a general economic  incentive to delay
 compliance until the Agency commenced  an enforcement action.
 Once  the Agency brought the action, the violator could then
 settle for a  penalty less than their economic benefit of
 noncompliance.  This incentive would directly undermine the
 goal  of  deterrence.


 Fair  and Equitable  Treatment of  the Regulated Community

      The second goal of penalty  assessment is the fair and
 equitable  treatment of the  regulated community.  Fair and
 equitable  treatment requires that the  Agency's penalties must
 display  both  consistency and flexibility.  The consistent
 application of a penalty policy  is  important because otherwise
 the resulting penalties might  be seen  as  being arbitrarily
 assessed.  Thus violators would  be more inclined to litigate
 over  those penalties.  This would consume Agency resources and
 make  swift resolution of  environmental problems less likely.

      But any  system for calculating penalties must have enough
 flexibility to make adjustments  to  reflect legitimate differences
 between  similar violations.  Otherwise the policy might be
 viewed as  unfair.  Again, the  result would be to undermine
 the goals  of  the Agency to  achieve  swift  and equitable resolu-
 tions of environmental problems.

     Methods  for quantifying the benefit  and gravity components
are explained in the Framework guidance.  These methods  signifi-
cantly further the goal of  equitable treatment of violators.
To begin with, the  benefit  component promotes equity by  re-
moving the unfair economic  advantage which a violator may have
gained over complying parties.  .Furthermore, because  the  benefit
and gravity components are  generated systematically,  they

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                               -5-

will exhibit relative consistency from case to case.   Because
the methodologies account for a wide range of relevant factors
the penalties generated will be responsive to legitimate       '
differences  between cases.

      However, not all the possibly relevant differences between
cases are  accounted for in generating the preliminary  deterrence
amount.  Accordingly, all preliminary deterrence  amounts  should
be  increased or mitigated for the following factors to account
for differences between cases:

           e   Degree of willfulness and/or negligence

           0   History of noncompliance.

           0   Ability to pay.

           *   Degree of cooperation/noncooperation.

           0   Other unique factors specific to the
              violator or the case.

Mitigation based  on these factors is appropriate  to the extent
the violator clearly demonstrates that  it is  entitled  to miti-
gation.

      The preliminary deterrence amount  adjusted prior  to the
start of settlement negotiations yields the "initial penalty
target figure".   In administrative  actions,  this  figure
generally  is .the  penalty assessed in the complaint.  In judicial
actions, EPA will use this  figure as the first settlement goal.
This settlement goal is an  internal target and should  not be
revealed to  the violator unless the case development team feels
that it is appropriate.   The initial penalty  target may be
further adjusted  as negotiations proceed and  additional
information  becomes available or as the original  information is
reassessed.
Swift Resolution of Environmental  Problems	.	

     The third goal of penalty  assessment is swift resolution
of environmental problems.   The Agency's primary mission is to
protect the environment.  As long  as  an environmental violation
continues, precious natural  resources, and possibly public
health, are at risk.  For this  reason, swift correction of
identified environmental problems  must be an important goal of
any enforcement action.  In  addition, swift compliance conserves
Agency personnel and resources.

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                               -6-

     The Agency will pursue  two  basic approaches to promoting
quick  settlements which  include  swift resolution of environmental
problems without undermining deterrence.  Those two approaches
are  as follows:

     1.  Provide incentives  to settle and institute prompt
         remedial action.

     EPA policy will be  to provide specific incentives to settle,
including  the following:
       «
       <•.
           0  The Agency  will consider reducing the
             gravity component of the penalty for
             settlements in which the violator already
             has instituted  expeditious remedies to
             the identified  violations prior to the
             commencement of litigation.JY This would
             be considered in  the adjustment factor
             called degree of  cooperation/noncoopera-
             tion discussed  above.

           0  The Agency  will consider accepting additional
             environmental cleanup, and mitigating the
             penalty figures accordingly.  But normally,
             the Agency  will only accept this arrangement
             if agreed to in pre-litigation settlement.

Other  incentives can be  used,  as long as they do not result in
allowing the violator to retain  a significant economic benefit.

     2.  Provide disincentives to delaying compliance.

     The preliminary deterrence  amount is based in part upon
the  expected duration of the violation.  If that projected period
of time is extended during the course of settlement negotiations
due  to the defendant's actions,  the case development team should
adjust that figure upward.   The  case development team should
consider making this fact known  to the violator early in the negoti-
ation  process.  This will provide a strong disincentive to delay
compliance.
_!/  For the purposes of this document,  litigation  is  deemed to
begin:
          a for administrative actions  - when  the
            respondent files a response to  an  adminis-
            trative complaint or when the time to
            file expires or

          0 for judicial actions -  when an  Assistant
            United States Attorney  files a  com-
            plaint in court.

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                              -7-
Intent of Policy and Information Requests for Penalty Calculations

     The policies and procedures set out in this document and in
the Framework for Statute-Specific Approaches to Penalty Assessment
are intended solely for the guidance of government personnel.
They are not intended and cannot be relied upon to create any
rights/ substantive or procedural, enforceable by any party in
litigation with the United States.  The Agency reserves the right
to act at variance with these policies and procedures and to change
them at any time without public notice.  In addition, any penalty
calculations under this policy made in anticipation of litigation
are exempt from disclosure under the Freedom of Information Act.
Nevertheless as a matter of public interest, the Agency may
elect to release this information in some cases.
                                    Courtney M. Price
                               Assistant Administrator for
                          Enforcement  and'Compliance Monitoring
Attachment

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                              -8-

                          ATTACHMENT A
Outline of Civil Penalty Assessment
I.   Calculate Preliminary Deterrence Amount
      «
     A.*  Economic benefit component and

     B.  Gravity component

(This yields the preliminary deterrence amount.)


II.  Apply Adjustment Factors

     A.  Degree of cooperation/noncboperation (indicated through
         pre-settlement action.)

     B.  Degree of willfulness and/or negligence.

     C.  History of noncompliance.

     D.  Ability to pay (optional at this stage.)

     E.  Other unique -factors (including strength of case,
         competing public policy concerns.)

(This yields the initial penalty target figure.)


Ill* Adjustments to Initial Penalty Target Figure After
     Negotiations Have Begun

     A.  Ability to pay (to the extent not considered in
         calculating initial penalty target.)

     B.  Reassess adjustments used in calculating initial
         penalty target.  (Agency may want to reexamine
         evidence used as a basis for the penalty in the
         light of new information.)

     C.  Reassess preliminary deterrence amount  to reflect
         continued periods of noncompliance not  reflected
         in the original calculation.

     D.  Alternative payments agreed upon prior  to the
         commencement of litigation.


(This yields the adjusted penalty target figure.)

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A FRAMEWORK FOR STATUTE-SPECIFIC APPROACHES

          TO PENALTY ASSESSMENTS;

IMPLEMENTING EPA'S POLICY ON CIVIL PENALTIES
     EPA GENERAL ENFORCEMENT POLICY #GM - 22
                  UNITED STATES ENVIRONMENTAL
                        PROTECTION AGENCY

                  EFFECTIVE  DATE:   rEB I 6 1984

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Contents
                                                             Page
    Introduction
    Writing a Program-Specific Policy                          2

         I.    Developing a Penalty Figure                     2
                                                       \
         II.   Calculating a Preliminary Deterrence Amount     2

         III.  Adjusting the Preliminary Deterrence Amount     3
               to Derive the Initial Penalty Target Figure

         IV.   Adjusting the Initial Penalty Target Figure     4
               During Negotiations
    Use of the Policy in Litigation
    Use of the Policy as a Feedback Device
    Appendix                                                   6


         Introduction                                          6

         The Preliminary Deterrence Amount                     6

         I.    The Benefit Component                           6

               A.  Benefit from delayed costs                  7
               B.  Benefit from avoided costs                  9
               C.  Benefit from competitive advantage         1C
              • D.  Settling a case for an amount less than    11
                   the economic benefit component

         II.   The Gravity Component                          13

               A.  Quantifying the gravity of a violation     13
               B.  Gravity factors                            14

         Initial and Adjusted Penalty Target Figure           16

         I.   Flexibility-Adjustment Factors            •      17

              A.  Degree of willfulness and/or negligence     17
              B.  Degree of cooperation/noncooperation        19
              C.  History 'of noncompliance                    21
              D.  Ability to pay                              23
              E.  Other.unique factors                        24

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                             11
Appendix (Con't)





     II.   Alternative Payments                           24



     III.  Promoting Consistency                          27





     Use of Penalty Figure in Settlement Negotiations     28

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                              -1-


Introduction
     This document, A  Framework  for  Statute-Specific Approaches
to Penalty Assessment, provides  guidance  to  the user of t-ha
Policy on Civil Penalties  on  how to  develop  a medium-specific
penalty policy.  Such  policies will  apply to administratively
imposed penalties and  settlements of both administrative and
judicial penalty actions.
      A

     In the Policy on  Civil Penalties,  the Environmental
Protection Agency establishes a  single  set of goals for penalty
assessment.  Those goals - deterrence,  fair  and equitable
treatment of the regulated community, and swift resolution of
environmental problems - will be substantially impaired unless
they are pursued in a  consistent fashion.  Even different
terminology could cause confusion that  would detract from the
achievement of these goals.   At  the  same  time, too much rigidity
will stifle negotiation and make settlement  impossible.

     The purpose of this document is to promote the goals of
the Policy on Civil Penalties by providing a framework for
medium-specific penalty policies.  The  Framework is detailed
enough to allow individual programs  to  develop policies that
will consistently further  the Agency's  goals and be easy to
administer.  In addition,  it  is  general enough to allow each
program to tailor the  policy  to  the  relevant statutory provi-
sions and the particular priorities  of  each  program.

     While this document contains detailed guidance, it is not
cast in absolute terms. . Nevertheless,  the policy does not
encourage deviation from this guidance  in either the development
of medium-specific policies or in developing actual penalty
figures.  Where there  are  deviations in developing medium-
specific policies, the reasons for those  changes must be
recorded in the actual policy.   Where there  are deviations from
medium-specific policies in calculating a penalty figure, the
case development team  must detail the reasons for those changes
in the case file.  In  addition,  the  rationale behind the deviations
must be incorporated in the memorandum  accompanying the settlement
package to Headquarters or the appropriate Regional official.

     This document is  divided into two  sections.  The first one
gives brief instructions to the  user on how  to write a medium-
specific policy.  The  second  section is an appendix that gives
detailed guidance on implementing each  section of the instruc-
tions and explains how the instructions are  intended to further
the goals of the policy.

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                               -2-
Writinq a Program Specific Policy
     Summarized below are those elements that should be present
in a program-specific penalty policy.  For a detailed discus-
sion of each of these ideas, the corresponding portions of the
appendix should be consulted.


I.  Developing a Penalty Figure

    The development of a penalty figure is a two step process.
First the case development team must calculate a preliminary
deterrence figure.  This figure is composed of the economic
benefit component (where applicable) and the gravity component.
The second step is to adjust the preliminary deterrence figure
through a number of factors.  The resulting penalty figure is
the initial penalty target figure.  In judicial actions, the
initial penalty target figure is the penalty amount which the
government normally sets as a goal at the outset of settlement
negotiations.  It is essentially an internal settlement goal and
should not be revealed to the violator unless the case development
team feels it is appropriate*  In administrative actions, this
figure generally is the penalty assessed in the complaint.
While -in judicial actions, the government's complaint will request
the maximum penalty authorized by law.

     This initial penalty target figure may be further adjusted
in the course of negotiations.  Bach policy should ensure that
the penalty assessed or requested is within any applicable
statutory constraints, based upon the number and duration of
violations at issue.
II.  Calculating a Preliminary Deterrence Amount
                                                       /

     Each program-specific policy must contain a section on
calculating the preliminary deterrence figure.  That section
should contain materials on each of the following areas:

          '  Benefit Component.  This section should
             explain:

             a.  the relevent measure of economic benefit
                 for various types of violations,
             b.  the information needed,
             c.  where to get assistance in computing
                 this figure and
             d.  how to use available computer systems
                 to compare a case with similar previous
                 violations.

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                               -3-

           0  Gravity Component.   This  section should  first
             rank different  types of violations according
             to the seriousness  of the act.  In creating
             that ranking, the following  factors should be
             considered:

             a.  actual or possible harm,
             b.  importance  to the regulatory
                 scheme and
             c.  availability  of data  from other
                 sources.

     In evaluating actual or possible  harm, your scheme should
consider the following facts:

             amount of pollutant,
             toxicity of pollutant,
             sensitivity of  the  environment,
             length of time  of a violation and
             size of the violator.

     The policy then should  assign appropriate dollar amounts
or ranges of amounts to the  different  ranked violations to
constitute the "gravity component".  This amount, added to the
amount reflecting economic benefit, constitutes the preliminary
deterrence figure.


III. Adjusting the Preliminary Deterrence Amount to Derive the
     Initial Penalty Target  Figure (Prenegotiation Adjustment)

     Each program-specific penalty policy should give detailed
guidance on applying the appropriate adjustments to the pre-
liminary deterrence figure.  This  is to ensure that penalties also
further Agency goals besides deterrence (i.e. equity and swift
correction of environmental  problems).  Those guidelines should
be consistent with the approach  described in the appendix.  The
factors may be separated according to  whether they can be con-
sidered before or after negotiation has begun or both.

     Adjustments (increases  or decreases, as appropriate) that
can be made.to the preliminary deterrence penalty to develop an
initial penaly target to use at  the outset of negotiation include:

          0  Degree of willfulness and/or negligence

          0  Cooperation/noncooperation through pre-
             settlement action.

          0  History of noncompliance.

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                              -4-

           0   Ability  to  pay.

           0   Other  unique  factors  (including  strength of
              case,  competing  public  policy considerations).

      The  policy  may permit consideration  of the  violator's ability
 to pay as an  adjustment  factor  before  negotiations  begin.  It
 may also  postpone consideration of that factor until  after negoti-
 ations have begun.  This would  allow the  violator  to  produce
 evidence  substantiating  its inability  to  pay.

      The  policy  should prescribe appropriate  amounts,  or ranges
 of amounts, by which  the preliminary deterrence  penalty should
 be adjusted.  Adjustments  will  depend  on  the  extent to which
 certain factors  are pertinent.  In order  to preserve  the penalty's
 deterrent effect, the policy  should  also  ensure  that,  except for
 the specific  exceptions  described  in this document, the adjusted
 penalty will: 1) always  remove  any significant economic benefit
 of noncompliance and  2)  contain some non-trivial amount as a
 gravity component.


 IV.   Adjusting the  Initial Penalty Target During Negotiations

      Each program-specific policy  should  call for periodic reas-
 sessment  of these adjustments during the  course  of  negotiations.  '
 This would occur as additional  relevant information becomes avail-
 able and  the  old evidence  is  re-evaluated in  the light of new
 evidence.  Once  negotiations  have  begun,  the  policy also should
 permit adjustment of  the penalty target to reflect  "alternative
 payments"  the violator agrees to make  in  settlement of the case.
 Adjustments for alternative payments and  pre-settlement corrective
 action are generally  permissible only  before  litigation has
 begun.

      Again, the policy should be structured to ensure that any
 settlement made after negotiations have begun reflects the
 economic  benefit of noncompliance up to the date of compliance
 plus  some  non-trivial gravity component.   This means  that  if
 lengthy settlement  negotiations cause  the violation to continue
 longer than initially anticipated, the penalty target figure
 should  be  increased.  The  increase would  be based  upon the  extent
 that  the  violations continue  to produce ongoing  environmental
 risk  and  increasing economic  benefit.
Use of the Policy In Litigation	

     Each program-specific policy  should contain a section on
the use of the policy in litigation.   Requests for penalties

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               •  .              -5-  '

should account for all  the  factors  identified  in  the relevant
statute and still allow for compromises  in  settlement without
exceeding the parameters  outlined  in  this document.  (For each
program, all the statutory  factors  are contained  in the Frame-
work either explicitly  or as part of  broader factors.)  For admin-
istrative proceedings,  the  policy should explain  how to formulate
a penalty figure, consistent with the policy.  The case develop-
ment team will put this figure in the administrative complaint.

     1-n judicial actions, the  EPA will use  the initial penalty
target figure as its first  settlement goal.  This settlement
goal is an internal target  and should not be revealed to the
violator .unless the case  development  team feels it is appro-
priate.  In judicial litigation, the  government should request
the maximum penalty authorized by law in its complaint.  The
policy should also explain  how it and any applicable precedents
should be used in responding to any explicit requests from a
court for a minimum assesment  which the Agency would deem
appropriate.


Use of the Policy as a  Feedback Device                           ~~

     Each program-specific  policy should first explain in detail
what information needs  to be put into the case file and into the
relevant computer tracking  system.  Furthermore,  each policy
should cover how to use that system t.o examine penalty assessments
in other cases.   This  would thereby  assist the Agency in making
judgments about the size  of adjustments to  the penalty for the
case at hand.  Each policy  should also explain how to present
penalty calculations in litigation  reports.
                                   Courtney M. Price
                              Assistant Administrator for
                         Enforcement and Compliance Monitoring
Attachment

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                              -6-

                            APPENDIX
 Introduction
      This  appendix contains  three  sections.   The  first two sections
 set  out guidelines for achieving the  goals  of the Policy  on Civil
 Penalties.  The first section  focuses on  achieving deterrence  by
 assuring that the penalty  first removes any  economic  benefit from
 noncorapliance.  Then it adds an amount to the penalty which reflects
 the  seriousness of the violation.  The second section provides
 adjustment factors so that both a  fair and equitable  penalty win
 result and that there will be  a swift resolution  of the environmental
 problem.  The third section  of the framework presents some practical
 advice on  the use of the penalty figures  generated by the policy.


 The  Preliminary Deterrence Amount                                ~

      The Policy on Civil Penalties establishes deterrence as an
 important goal of penalty  assessment.  More  specifically, it speci-
 fies that any penalty should,  at a minimum,  remove any significant
 benefits resulting from noncompliance.  In  addition,  it should
 include an amount beyond removal of economic benefit  to reflect
 the  seriousness of the violation.  That portion of the penalty
 which removes the economic benefit of noncompliance is referred  tc>-
 as the "benefit component;"  that part of  the penalty  which reflects-*
 the  seriousness of the violation is referred to as the "gravity
 component."  When combined,  these  two components  yield the "prelim-
 inary deterrence amount."

      This section of the document  provides  guidelines for calcu-
 lating the benefit component and the  gravity component.  It will
 also present and discuss a simplified version of  the  economic
 benefit calculation for use  in developing quick penalty deter-
 minations.  This section will  also discuss  the limited .circum-
 stances which justify settling for less  than the  benefit  component.
 The  uses of the preliminary  deterrence amount will be explained
 in subsequent portions of  this document.


 I.    The Benefit Component

      In order to ensure that penalties remove any significant
economic benefit of noncompliance, it is  necessary to have
reliable methods to calculate  that benefit.   The  existence of
reliable methods also strengthens  the Agency's position  in both
litigation and negotiation.  This  section sets out guidelines for
computing the benefit component.   It  first  addresses costs which
are delayed by noncompliance.  Then  it addresses  costs which are
avoided completely by noncompliance.   It also identifies  issues

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                               -7-
to be  considered  when computing the benefit component  for  those
violations where  the benefit of noncompliance  results  from factors
other  than cost savings.   This section concludes  with  a  discussion
of the proper  use of the  benefit component in  developing penalty
figures  and  in settlement negotiations.
      In many  instances,  the economic advantage  to be derived from
noncompliance  is  the  ability to delay making  the expenditures
necessary  to  achieve  compliance.   For example,  a facility which
fails  to construct  required settling ponds will eventually have to
spend  .the  money needed to build those ponds in  order to achieve
compliance.   But, by  deferring these one-time nonrecurring costs
until  EPA  or  a State  takes an enforcement action, that facility
has achieved  an economic benefit.   Among the  types of violations
which  result  in savings  from deferred cost are  the following:

           e .  Failure  to  install equipment needed to meet
              discharge or emission control standards.
                          *
           0   Failure  to  effect process changes  needed
              to eliminate pollutants from products or
             waste  streams.

           0  Testing  violations, where the testing still
             must be  done to demonstrate achieved com-
             pliance.

           0   Improper disposal,  where proper  disposal is
             still  required to achieve compliance.

           0   Improper storage where proper storage is still
             required to achieve compliance.

           0  Failure  to  obtain necessary permits for dis-
             charge,  where such permits would probably be
             granted.   (While the  avoided cost  for many
             programs would be negligible, there are pro-
             grams  where the the permit process can be
             expensive).

     The Agency has a substantial  amount of experience under
the air and water programs  in calculating the economic benefit
that results from delaying  costs necessary to achieve compliance.
This experience indicates that it  is possible to estimate the
benefit of delayed  compliance through the use of a simple formula.
Specifically,  the economic  benefit of delayed compliance may be
estimated at:  5% per year  of the  delayed one-time capital cost
for the period from the  date the violation began until the date

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                               -8-

 compliance was  or  is  expected to be achieved.  This  will  be
 referred  to  as  the  "rule  of  thumb  for delayed  compliance" method.
 Each  program may adopt  its own "rule of  thumb" if  appropriate.
 The applicable  medium-specific guidance  should state what that
 method is.

      The  rule of thumb  method can  usually  be used  in making
 decisions on whether  to develop a .case or  in setting a  penalty
 target for settlement negotiations.   In  using  this rule of  thumb
 method in settlement  negotiations,  the Agency  may want  to make
 the violator fully  aware  that it is  using  an estimate and not
 a  more precise  penalty  determination procedure.  The decision
 whether to reveal  this  information  is up to the  negotiators.

      The  "rule  of  thumb"  method only provides  a  first-cut estimate
 of the benefit  of delayed compliance.  For this  reason, its use
 is probably  inappropriate in situations  where  a  detailed  analysis
 of the economic effect  of noncompliance  is needed  to support or
 defend the Agency's position.   Accordingly, this "rule  of thumb"
 method generally should not  be used  in any of  the  following cir-
 cumstances:

          0  A  hearing  is likely on  the  amount of  the
             penalty.

          0  The defendant wishes  to negotiate over  the
             amount of  the economic  benefit on the basis
             of factors unique to  the financial  condition
             of the company.

          *  The case development  team has reason  to
             believe  it will produce a substantially
             inaccurate estimate;  for example, where the
             defendant  is in a highly unusual  financial
             position,  or where noncompliance  has  or will
             continue for an unusu-ally long period.

     There usually are  avoided costs associated  with this type
 of situation.   Therefore, the "rule  of thumb for avoided  costs"
 should  also  be  applied.   (See pages  9-10). For  most cases, both
 figures are  needed to yield  the major portion  of the economic
 benefit component.

     When the rule of thumb  method  is not  applicable,  the economic
 benefit of delayed compliance should be  computed using  the  Meth-
odology for  Computing the Economic  Benefit of  Noncompliance.
This document,   which  is under development, provides  a. method
 for computing the economic benefit  of noncompliance  based on a
detailed economic analysis.   The method  will  largely be a  refined
version of the  method used in the  previous Civil Penalty Policy
 issued July  8,   1980,  for  the Clean  Water Act  and Title I of the
Clean Air Act.   It will also be consistent with  the  regulations

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                               -9-

implementing Section  120  of  the  Clean Air Act.  A computer
program will be available to the Regions to  perform the analysis,
together with  instructions for its  use.  Until the Methodology
is issued,  the economic model contained in the July 8, 1980,
Civil Penalty  Policy  should  be used.  It should be noted that
the Agency  recently modified this guidance to reflect changes in
the tax law.

     B.   Benefit  from avoided costs

     Many kinds of violations enable a violator to permanently
avoid certain  costs associated with compliance.

          0 Cost  savings for operation and  maintenance of
             equipment that  the  violator failed to install..

          0 Failure  to properly operate and maintain
             existing control equipment..

          0 Failure  to employ sufficient number of
             adequately trained  staff.

          0 Failure  to establish or follow  precautionary
             methods  required by regulations or permits.

          0 Improper storage, where commercial storage is
             reasonably available.

          0 Improper disposal,  where redisposal or cleanup
             is not possible.

          0 Process,  operational,  or maintenance savings
             from  removing pollution equipment.

          0 Failure  to conduct  necessary testing.

     As with the benefit  from delayed costs, the benefit com-
ponent for  avoided costs  may be  estimated by another "rule of
thumb" method.  Since these  costs will never be incurred, the
estimate is the expenses  avoided until the date compliance is
achieved less any  tax savings.   The use of this "rule of thumb"
method is subject  to  the  same limitations as those discussed in
the preceding section.

     Where  the "rule  of thumb for avoided costs" method cannot
be used, the benefit  from avoided costs must be computed using
the Methodology for Computing the Economic Benefit of Noncom-
pliance.  Again, until the Metholology is issued, the method
contained in the July 8,  1980, Civil Penalty Policy should be
used as modified to reflect  recent  changes in the tax law.

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                             -10-

     C.   Benefit from competitive advantage

     For most violations/ removing the savings which accrue  •
from noncompliance will usually be sufficient to remove the
competitive- advantage the violator clearly has gained from
noncompliance.  But there are some situations in which noncom-
pliance allows the violator to provide goods or services which
are not available elsewhere or are more attractive to the
consumer.  Examples of such violations include:
      41
      *
          0  Selling banned products.

          0  Selling products for banned uses.

          0  Selling products without required labelling
             or warnings.

          •  Removing or altering pollution control
             equipment for a fee, (e.g., tampering with
             automobile, emission controls.)

          0  Selling products without required regula-
             tory clearance, (e.g., pesticide registra-
             tion or premanufacture notice under TSCA.)

     To adequately remove the economic incentive for such viola-
tions, it is helpful to estimate the net profits made 'from the
improper transactions (i.e. those transactions which would not
have occurred if the party had complied).  The case development
team is responsible for identifying violations in which this
element of economic benefit clearly is present and significant.
This calculation may be substantially different depending on the
type of violation.  Consequently the program-specific policies
should contain guidance on identifying these types of violations
and estimating these profits.  In formulating that guidance, the
following principles should be followed:

          0  The amount of the profit should be based on
             the best information available concerning
             the number of transactions resulting from
             noncompliance.

          0  Where available, information about the
             average profit per transaction may be used.
             In some cases, this may be available from
             the rulemaking record of the provision
             violated.

          0  The benefit derived should be adjusted  to
             reflect the present value of net profits
             derived in the past.

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                               -11-
                                          •

     It is recognized that  the methods developed  for  estimation
the profit from .those transactions will  sometimes  rely  substan-
tially on expertise rather  than  verifiable  data.   Nevertheless
the programs should make all  reasonable  efforts to ensure  that'
the estimates developed are defensible.   The  programs are  encour-
aged to work with the Office  of  Policy,  Planning and  Evaluation
to ensure that the methods  developed are consistent with the
forthcoming Methodology for Computing the Economic Benefit of
Noncompliance and with methods developed ny other  pi-ogi-amg~—=fhe
programs should also ensure that sufficient contract  funds'are
available to obtain expert  advice in this area as  needed to
support1 penalty development,  negotiation and  trial of these kinds
of cases.

     D.   Settling cases fo.r  an  amount less than the economic
          benefit"                             ~~  ~    :

     As noted above, settling for an amount which  does  not remove
the economic benefit of noncompliance can encourage* people to
wait until EPA or the State begins an enforcement  action before
complying.  For this reason,  it  is general  Agency  policy not to
settle for less than this amount.  There are  three general areas
where settling for less than  economic benefit may  be appropriate.
But in any individual case where the Agency decides to  settle for
less than enconomic benefit,  the case development  team  must detail
those reasons in the case file and in any memoranda accompanying
the settlement.

          1. Benefit component involves  insignificant amount

     It is clear that assessing  the benefit component and
negotiating over it will often represent a  substantial  commitment
of resources.  Such a commitment of resources may  not be warranted
in cases where the magnitude  of  the benefit component is not likely
to be significant, (e.g. not  likely to have a substantial  impact on
the violator's competitive positions).   For this reason, the case
development team has the discretion not  to  seek the benefit com-
ponent where it appears that  the amount  of  that component  is
likely to be less than $10,000.' (A program may determine  that
other cut-off.points are more reasonable based on  the likelihood
that retaining the benefit  could encourage  noncomplying behavior.)
In exercising that discretion, the case  development team should
consider the following fa-ctors:

        0  Impact on violator:   The likelihood that
           assessing the benefit component  as part
           of the-penalty will have a noticeable
           effect on the violator's competitive
           position or overall profits.   If no such
           effect appears likely, the benefit com-
           ponent should, probably not be pursued.

        o  The size of the gravity component: If  the
           gravity component  is  relatively  small,  it
           may not provide  a  sufficient  deterrent, by

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                              -12-
                                         •
            itself, to achieve the goals of this policy.

         0  The certainty of the size of the benefit
            component;If the economic benefit is quite
            well defined, it is not likely to require
            as much effort to seek to include it in the
            penalty assessment.  Such circumstances also
            increase the likelihood that the economic
            benefit was a substantial motivation for the
            noncompliance.  This would make the inclusion
            of the benefit component more necessary to
            achieve specific deterrence.

     It may be appropriate not to seek the benefit component in
an entire class of violation.  In that situation,  the rationale
behind that approach should be clearly stated in the appropriate
medium-specific policy.  For example, the most appropriate way
to handle a small non-recurring operation and maintenance vio-
lation may be a small penalty.  Obviously it makes little sense
to assess in detail the economic benefit for each individual
violation because the benefit is likely to be so small. . The
medium-specific policy would state this as the rationale.

         2. Compelling public concerns

     The Agency recognizes that there may be some instances where
there are compelling public concerns that would not be served by
taking a case to trial.  In such instances, it may become necessary
to consider settling a case for less than the benefit component.
This may be done only if it is absolutely necessary to preserve
the countervailing public interests.  Such settlements might be
appropriate where the following circumstances occur:

         0  There is a very substantial risk of creating
            precedent which will have a significant
            adverse effect upon the Agency's ability
            to enforce the law or clean up pollution
            if the case is taken to trial.

         0  Settlement will avoid or terminate an
            imminent risk to human health or the
            environment•  This is an adequate
            justification only if injunctive relief
            i? unavailable for some reason, and if
            settlement on remedial responsibilities
            could not be reached independent of any
            settlement of civil penalty liability.

         0  Removal of the economic benefit would
            result in plant closings, bankruptcy, or
            other extreme financial burden, and there
            is an important public interest in allow-
            ing the firm to continue  in business^

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                               -13-

              Alternative  payment plans should be  fully
              explored  before  resorting to this option.
              Otherwise, the Agency will give the  per-
              ception that shirking one's environmental
              responsibilities is a way to keep a  failing
              enterprise afloat.   This  exemption does not
              apply  to  situations where the plant  was
              likely to close  anyway, or where there is a
              likelihood of continued harmful noncompliance.

          3.  Litigation practicalities

     The Agency realizes that  in  certain cases,  it is highly unlikely
the EPA will be able to recover the economic benefit in litigation.
This.may be due to applicable  precedent,  competing public interest
considerations, or the  specific facts,  equities, or evidentiary
issues pertaining to a  particular case.   In such a situation it is
unrealistic to expect EPA  to obtain a penalty in litigation which
would remove the economic  benefit.   The case development team then
may pursue a lower penalty amount.


II.  The Gravity Component

     As noted above, the Policy on  Civil Penalties specifies that
a penalty, to achieve deterrence,  should not only  remove any eco-
nomic benefit of noncompliance, but also include an amount reflecting
the seriousness of the  violation.   This latter amount is referred
to as the "gravity component."  The purpose of this section of the
document is to establish an approach to quantifying the gravity
component. . This approach  can  encompass the differences between
programs and still provide the  basis for a sound consistent treat-
ment of this issue.

     A.   Quantifying the  gravity of a  violation

     Assigning a dollar figure  to represent the  gravity of a vio-
lation is an essentially subjective process.   Nevertheless, the
relative seriousness of different violations can be fairly
accurately determined in most  cases. This can be  accomplished
by reference to the  goals  of the  specific regulatory scheme and
the facts of each particular violation.   Thus,  linking the dollar
amount of the gravity component to  these objective factors is a
useful way of insuring  that violations  of approximately equal
seriousness are treated the same  way.

     Such a linkage  promotes consistency.  This  consistency
strengthens the Agency's position both  in negotiation and before
a trier of fact.  This  approach consequently also  encourages
swift resolution of  environmental problems.

     Each program must develop  a  system for quantifying the
gravity of violations of the laws and regulations  it administers.
                              70

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                             — 14 —

This development must occur within the context of the penalty
amounts authorized by law for that program.  That system must
be based, whenever possible, on objective indicators of the
seriousness of the violation.  Examples of such indicators are
given below.  The seriousness of the violation should be based
primarily on:  1) the risk of harm inherent in the violation at
the time it was committed and 2) the actual harm that resulted
from the violation.  In some cases, the seriousness of the
risk of harm will exceed that of the actual harm.  Thus, each
system*.should provide enough flexibility to allow EPA to consider
both factors in assessing penalties.

     Each system must also be designed to minimize the possi-
bility that two persons applying the system to the same set of
facts would come up with substantially different numbers.  Thus,
to the extent the system depends on categorizing events, those
categories must be clearly defined.  That way there is little
possibility for argument over the category in which a violation
belongs.  In addition, the categorization of the events relevant
to the penalty decision should be noted in the penalty develop-
ment portion of the case file.

     B.   Gravity Factors

     In quantifying the gravity of a violation, a program-specific
policy should rank different types of violations according to the
seriousness of the act.  The following is a suggested approach to
ranking the seriousness of violations.  In this approach to rank-
ing, the following factors should be considered:

          0  Actual or possible harm;  This factor
             focuses on whether (and to what extent)
             the activity of the defendant actually
             resulted or was likely to result in an
             unpermitted discharge or exposure.

          0  Importance to the regulatory scheme:  This
             factor focuses on the importance of the
             requirement to achieving the goal of the
             statute or regulation.  For example, if
             labelling is the only method used to pre-
             vent dangerous exposure to a chemical,
             then failure to label should result in a
             relatively high penalty.  By contrast, a
             warning sign that was visibly posted but
             was smaller than the required size would
             not normally be considered as serious.

          0  Availability of data from other sources;
             The violation of any recordkeeping or .
             reporting requirement  is a very serious
                               71 '

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                                -15-

             matter.   But  if  the involved  requirement
             is  the only source of  information,  the
             violation is  far more  serious.  By  contrast,
             if  the Agency has another  readily available
             and cheap source for the necessary  infor-
             mation,  a smaller penalty  may be appro-
             priate.   (E.g. a customer  of  the violator
             purchased all the violator's  illegally
             produced substance.  Even  though the
             violator does not have the required
             records,  the  customer  does.)

           0  Size of  violator;   In  some cases, the
             gravity  component should be increased
             where it is clear that the resultant
             penalty  will  otherwise have little
             impact on the violator in  light of the
             risk of  harm  posed by  the  violation.
             This factor is only  relevant  to the
             extent it"is  not  taken into account by
             other factors.

     The assessment of the first  gravity factor listed above,
risk or harm arising  from  a violation,  is  a complex matter.   For
purposes of ranking violations  according to seriousness, it  is
possible to distinguish  violations  within  a category on the  basis
of certain considerations, including the following:

          0  Amount of pollutant: Adjustments for the
             concentration of  the pollutant may be
             appropriate,  depending on  the regulatory
             scheme and  the characteristics of the
             pollutant.  Such adjustments need not be
             linear, especially if  the pollutant can
             be harmful  at low concentrations.

          0  Toxicity of the pollutant;   Violations
             involving highly toxic .pollutants are more
             serious and should result  in relatively
             larger penalties.

          *  Sensitivity of the environment;   This
             factor focuses on the  location where the
             violation was committed.   For example,
             improper discharge into waters near a
             drinking water intake or a  recreational
             beach  is usually more serious than dis-
             charge into waters not near any such use.

          0  The  length of  time a violation continues;
             In most  circumstances,  the  longer a
             violation continues uncorrected, the
             greater  is the risk of harm.


                               72

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                             -16-

     Although each program-specific policy should  address  each
of  the  factors  listed above, or determine why  it is  not  relevant,
the  factors  listed above are not meant  to be exhaustive.   The
programs should make every effort to  identify  all  factors  rele-
vant to assessing the seriousness of  any violation.  The programs
should  then  systematically prescribe  a  dollar  amount to yield a
gravity component for the penalty.  The program-specific policies
may  prescribe a dollar  range for a certain category  of violation
rather  than  a precise dollar amount within that range based  on
the  specific facts of an individual case.

     The process by which the gravity component was  computed must
be memorialized in the  case file.  Combining the benefit component
with the gravity component yields the preliminary  deterrence amount,

     In some classes of cases, the normal gravity  calculation may <
be  insufficient to effect general deterrence.  This  could  happen
if  there was extensive  noncompliance  with certain  regulatory
programs in  specific areas of the United States.   This would
demonstrate  that the normal penalty assessments had  not been
achieving general deterrence.  The medium specific policies  should
address this issue.  One possible approach would be  to direct the
case development team to consider increasing the gravity component
within  a certain range  to achieve general deterrence.  These extra
assessments  should be consistent with the other goals of this
policy.


Initial and  Adjusted Penalty Target Figure

     The second goal of the Policy on Civil Penalties is the
equitable treatment of  the regulated  community.  One important
mechanism for promoting equitable treatment is to  include  the
benefit component discussed above in  a  civil penalty assessment.
This approach would prevent violators from benefitting economi-
cally from their noncompliance relative to parties which have
complied with environmental .requirements..

     In addition, in order to promote equity,  the  system for
penalty assessment must have enough flexibility to account for
the  unique facts of each case.  Yet it  still must  produce  enough
consistent results to treat similarly-situated violators similarly.
This is accomplished by identifying many of the legitimate differ-
ences between cases and providing guidelines for how to  adjust
the preliminary deterrence amount when  those facts occur.   The
application  of these adjustments to the preliminary  deterrence
amount prior to the commencement of negotiation yields  the  initial
penalty target figure.  During the course of negotiation,  the case
development  team may further adjust this figure to yield the
adjusted penalty target figure.
                          73

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                                -17-
      Nevertheless,  it should  be  noted  that  equitable  treatment i«
 a two-edged sword,  while  it  means  that  a particular  violator wm
 receive no higher penalty  than a similarly^ftu^el violator' it
 also means that the penalty will be no lower.         *oA»cor, it
 I.  Flexibility-Adjustment Factors
  ^-,    PurP°se of this section of the document is to establish
 additional adjustment factors to promote flexibility and to iden-
 tify management techniques that will promote consistency.  This
 section sets out guidelines for adjusting penalties to account for
 some factors that frequently distinguish different cases.  Those
 factors are: degree of willfulness and/or negligence, degree of
 cooperation/noncooperation, history of noncompliance, ability to
•pay, and other unique factors.  Unless otherwise specified, these
 adjustment factors will apply only to the gravity component and
 not to the economic benefit component.  Violators bear the burden
 of justifying mitigation adjustments they propose based on these
 factors.

      Within each factor there are three suggested ranges of
 adjustment.  The actual ranges for each medium-specific policy
 will be determined by those developing the policy.   The actual
 ranges may differ from these suggested ranges based upon program
 specific needs.   The first, typically a 0-20% adjustment of the
 gravity component,  is within the absolute discretion of the case
 development team.  £/  The second,  typically a 21-30% adjustment,
 is only appropriate in unusual circumstances.  The  third range,
 typically beyond 30% adjustment, is only appropriate in extra-
 ordinary circumstances.   Adjustments in the latter  two ranges,
 unusual and extraordinary circumstances,  will be subject to scrutiny
 in any performance  audit.   The case development team may wish  to
 reevaluate these adjustment factors as the negotiations progress.
This allows the  team to reconsider evidence used as a basis for
 the penalty in light of  new information.

      Where the Region develops the penalty figure,  the appli-
cation of  adjustment factors will  be part of the planned Regional
audits.  Headquarters  will  be responsible for proper application
of  these factors in nationally-managed cases.  A detailed dis-
cussion of these factors follows.

     A.  Degree  of  Willfulness and/or Negligence

     Although most  of  the statutes which  EPA administers are
strict  liability statutes,  this  does not  render the violator's
I/ Absolute discretion means  that the case development team
may make penalty development  decisions independent of EPA
Headquarters.  Nevertheless  it  is understood that in all
judicial matters,  the Department of Justice can still review
these determinations if  they  so desire.   Of course the authority
to exercise the Agency's  concurrence in final settlements is
covered by the applicable deleg     is.

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                              -18-

willfulness and/or negligence irrelevant.  Knowing or willful
violations can give rise to criminal liability, and the lack
of  any  culpability may, depending upon the particular program,
indicate  that no penalty action is appropriate.  Between these
two extremes, the willfulness and/or negligence of the violator
should  be reflected in the amount of the penalty.
                                  *
      In assessing the degree of willfulness and/or negligence,
all of-.the following points should be considered in most cases:

          0  How much control the violator had over the
             events constituting the violation.

          *  The forseeability of the events consti- .
             tuting the violation.

          0  Whether the violator took reasonable
             precautions against the events con-
             stituting the violation.
                          A
          0  Whether the violator knew or should have
             known of the hazards associated with the
             conduct.

          0  The level of sophistication within the               7
             industry in dealing with compliance issues
             and/or the accessibility of appropriate
             control technology (if this information is
             readily available).  This should be balanced
             against the technology forcing nature of the
             statute, where applicable.

          0  Whether the violator in fact knew of the
             legal requirement which was violated.

      It should be noted that: this last point, lack of knowledge
of  the  legal requirement, should never be used as a basis  to
reduce  the penalty.  To do so would encourage ignorance of
the  law.  Rather, knowledge of the law should serve only to
enhance the penalty.

     The amount of control which the violator had over  how
quickly the.violation was remedied is also relevent  in  certain
circumstances.   Specifically, if correction of the environmental
problem was delayed by factors which the violator can  clearly
show were not reasonably foreseeable and out of  its  control,.the
penalty may be reduced.

     The suggested approach for this factor is for  the case
development team to have absolute discretion to  adjust the
perialty up or down by 20% of the gravity component.  Adjustments
in the _+ 21-30% range should only be made  in unusual  circumstances.
                              75

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                                -19-

Adjustments for this  factor beyond +  30%  should  be made only in
extraordinary circumstances.   Adjustments in  the unusual or
extraordinary circumstance  range will be  subject to scrutiny in
any audit of performance.

     B.  Degree of Cooperation/Koncooperation

     The degree of cooperation or noncooperation of the violator
in remedying the violation  is  an appropriate  factor to consider in
adjusting the penalty.  Such adjustments  are  mandated by both the
goals Of equitable treatment and swift resolution of environmental
problems.  There are  three  areas where this factor is relevant.

          1.  Prompt  reporting of noncompliance

     Cooperation can  be manifested by the violator promptly
reporting its noncompliance.   Assuming such self-reporting is not
required by law, such behavior should result  in  the mitigation of
any penalty.

     The suggested ranges of adjustment are as follows.  The case
development team has  absolute  discretion  on any  adjustments up to
+ 10% of the gravity  component for cooperation/noncooperation.
Adjustments can be made up  to  +; 20% of the gravity component, but
only in unusual circumstances.  . In extraordinary circumstances,
such as self reporting of a TSCA premanufacture  notice violation,
the case development  team may  adjust  the  penalty beyond the +_ 20%
factor.  Adjustments  in the unusual or extraordinary circumstances
ranges will be subject to scrutiny in any performance audit.

          2.  Prompt  correction of environmental problems

     The Agency should provide incentives for the violator to
commit to correcting  the problem promptly.  This correction must
take place before litigation is begun,  except in extraordinary
circumstances.^/  But since these incentives  must be consistent
with deterrence, they must  be  used judiciously.
2/  For the purposes of this document,  litigation is deemed to
begin:
          0 for administrative  actions  - when the
            respondent files a  response to an adminis-
            trative complaint or  when the time to
            file expires or

          e for judicial actions  - when an Assistant
            United States Attorney files a com-
            plaint in court.
                              76

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                                -20-

     The circumstances under which the penalty  is  reduced  depend
on  the  type of violation  involved and the source's  response  to
the problem.  A straightforward reduction in the amount  of the
gravity component of the  penalty is most appropriate  in  those
cases where either: 1) the environmental problem is actually cor-
rected  prior to initiating litigation, or 2) ideally,  immediately
upon discovery of the violation.  Under this approach, the reduction
typically should be a substantial portion of the unadjusted  gravity
component.
      •
     In' general, the earlier the violator instituted  corrective
action  after discovery of the violation and the more  complete
the corrective action instituted, the larger the penalty
reduction EPA will consider.  At the discretion of  the case
development team, the unadjusted gravity component may be
reduced up to 50%.  This  would depend on how long  the environ-
mental  problem continued  before correction and  the  amount  of any
environmental damage.  Adjustments greater than 50% are  permitted,
but will be the subject of close scrutiny in auditing performance.

     It should be noted that in some instances, the violator
will take all necessary steps toward correcting the problem  but
may refuse to reach any agreement on penalties.  Similarly,  a
violator may take some steps to ameliorate the problem,  but
choose  to litigate over what constitutes compliance.  In such
cases,  the gravity component of the penalty may be  reduced up
to  25%  at the discretion of the case development team.   This
smaller adjustment still  recognizes the efforts made  to  correct
the environmental problem, but the benefit to the  source is  not
as  great as if a complete settlement is reached.  Adjustments
greater than 25% are permitted, but will be the subject  of close
scrutiny in auditing performance.

     In all instances, the facts and rationale  justifying  the
penalty reduction must be recorded in the case  file and  in-
cluded  in any memoranda accompanying settlement.

          3.  Delaying compliance

     Swift resolution of  environmental problems will  be  encour-
aged if th» violator clearly sees that it will  be  financially
disadvantageous for the violator to litigate without  remedying
noncompliance.   The settlement terms described  in  the preceding
section are only available to parties who take  steps  to  correct a
problem prior to initiation of litigation.  To  some extent,  this
is an incentive to comply as soon as possible.  Nevertheless, once
litigation has  commenced, it should be clear that  the defendant
litigates at its own risk.
                          77

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                               -21-

     In addition,  the methods  for computing the benefit component
and the gravity component  are  both structured so that the penalty
target increases the longer  the  violation remains uncorrected.
The larger penalty for  longer  noncompliance is systematically
linked to the benefits  accruing  to the violator and to the con-
tinuing risk to human health and the environment.  This occurs
even after litigation has  commenced.  This linkage will put the
Agency in a strong position  to convince 'the trier of fact to
impose'such larger penalties.  For these reasons, the Policy
on Civil Penalties provides  substantial disincentives to litigat-
ing without complying.

     C.  History of noncompliance

     Where a party has  violated  a similar environmental require-
ment before, this  is usually clear evidence that the- party was
not deterred by the Agency's previous enforcement response.
Unless the previous violation  was caused by factors entirely out
of the control of  the violator,  this is an indication that the"
penalty should be  adjusted upwards.

     In deciding how large these adjustments should be, the case
development team should consider the following points:

          0  How similar the previous violation was.

          0  How recent the  previous violation was.

          0  The number of previous violations.

          0  Violator's response to previous violation(s)
             in regard  to  correction of the previous
             problem.

     Detailed criteria  for what  constitutes a "similar violation"
should be contained in  each  program-specific policy.  Neverthe-
less a violation should generally be considered "similar" if the
Agency's previous enforcement  response should have alerted the
party to a particular type of  compliance problem.  Some facts
that indicate a "similar violation" was committed are as follows:

          0  The same permit was violated.

          0  The same substance  was involved.

          *  The same process  points were the source
             of the violation.

          0  The same statutory  or regulatory provision
             was violated.
                             78

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                             -22-

          8  A similar act or omission (e.g. the failure
             to properly store chemicals) was the basis
             of the violation.

      For purposes of this section, a "prior violation" includes
any act or omission for which a formal enforcement response has
occurred (e.g. notice of violation, warning letter, complaint,
consent decree, consent agreement, or final order).  It also
includes any act or omission for which the violator has pre-
viously been given written notification, however informal, that
the Agency believes a violation exists.

      In the case of large corporations with many divisions or
wholly-owned subsidiaries, it is sometimes difficult to deter-
mine  whether a previous instance of noncompliance should trigger
the adjustments described in this section.  New ownership often
raises similar problems.  in making this determination, the case
development team should ascertain who in the organization had
control and oversight responsibility for the conduct resulting
in the violation.  In some situations the same persons or the
same  organizational unit had or reasonably should have had
control or oversight responsibility for violative conduct.  In
those cases, the violation will be considered part of the com-
pliance history of that regulated party.

      In general, the case development team should begin with
the assumption that if the same corporation was involved, the
adjustments for history of noncompliance should apply.  In
addition, the case development team should be wary of a party
changing operators or shifting responsibility for compliance to
different groups as a way of avoiding increased penalties.  The
Agency may find a consistent pattern of noncompliance by many
divisions or subsidiaries of a corporation even though the
facilities are at different geographic locations.  This often
reflects, at best, a corporate-wide indifference to environmental
protection.  Consequently, the adjustment for history of noncom-
pliance should probably apply unless the violator can demonstrate
that the other violating corporate facilities are independent.

    . The following are the Framework *s suggested adjustment
ranges.  If the pattern is one of "dissimilar" violations,
relatively few in number, the case development team has absolute
discretion to raise the penalty amount by 35%.  For a relatively
large number of dissimilar violations, the gravity component  can
be increased up to 70%.  If the pattern is one of "similar"
violations, the case development team has absolute discretion to
raise the penalty amount up to 35% for the first repeat violation,
and up to 70% for further repeated similar violations^  The  case
development team may make higher adjustments in extraordinary
circumstances, but such adjustments will  be subject to  scrutiny
in any performance audit.
                             79

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                              -23-

      D.  Ability to pay
 r-i.  ?heHA9enSy ?in 9ener?llv not request penalties that are
 clearly beyond the means of the violator.  Therefore EPA -hoiiiH
 consider the ability to pay a penalty in arriving at I specific
 ^nflP^aity assessment.  At the same tirae> ^ is important
 that the regulated community not see the violation of environ-
 mental requirements as a way of aiding a financially troubled
.business.  EPA reserves the option, in appropriate circumstances
 of seeking a penalty that might put a company out of business?
       A
      For example, it is unlikely that EPA would reduce a penalty
 ™ef* L facility refuses to correct a serious violation.  The same
 could be said for a violator with a long history of previous vio-
 lations.  That long history would demonstrate that less severe
 measures are ineffective.

      The financial ability adjustment will normally require  a
 significant amount of financial information specific to the
 violator.  If this information is available prior to commence-
 ment of negotiations, it should be assessed as part of the
 initial penalty target figure.  If it is not available, the
 case development team should assess this factor after commence-
 ment of negotiation with the source.

      The burden to demonstrate inability to pay,  as with the
 burden of demonstrating the presence  of  any mitigating circum-
 stances, rests on the defendant.   If  the violator fails to
 provide sufficient information,  then  the case development  team
 should disregard this factor in  adjusting the penalty.   The
 National Enforcement Investigations Center (NEIC)  has developed
 the  capability to assist the Regions  in  determining a firm's
 ability to pay.   Further information  on  this system will  be  made
 available shortly under separate  cover.

      When it  is  determined  that  a violator cannot  afford  the
 penalty prescribed by this  policy,  the following  options  should
 be considered:

           °  Consider a delayed payment  schedule;   Such a
             schedule might even  be contingent  upon an
             increase in sales or some other indicator  of
             improved business.   This approach  is  a real
             burden  on  the  Agency and should only  be
             considered on  rare occasions.

           0  Consider non-monetary  alternatives,  such  as
             public  service activities:   For example,  in
             the mobile source program,  fleet operators
             who  tampered with pollution  control devices

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                             -24-
                                                  «

             on their vehicles agreed to display anti-
             tampering ads on their vehicles,  similar
             solutions may be possible in other industries.

          0  consider straight penalty reductions as a last
             recourse;  If this approach is necessary, the
             reasons for the case development team's
             conclusion as to the size of the necessary
             reduction should be made a part of the formal
             enforcement file and the memorandum accompany-
             ing the settlement. Jj

          0  Consider joinder of the violator's individual
             owners:  This is appropriate if joinder is
             legally possible and justified under the
             circumstances.

Regardless of the Agency's determination of an appropriate
penalty amount to pursue based on ability to pay considerations,
the violator is still expected to comply with the law.

     E.  Other unique factors

     Individual programs may be able to predict other factors
that can be expected to affect the appropriate penalty amount.
Those factors should be identified and guidelines for their use
set out in the program-specific policies.  Nevertheless, each
policy should allow for adjustment for unanticipated factors
which might affect the penalty in each case.

     It is suggested that there be absolute discretion to adjust
penalties up or down by 10% of the gravity component for such
reasons.  Adjustments beyond the absolute discretion range will
be subject to scrutiny during audits.  In addition, they will
primarily be allowed for compelling public policy concerns or the
strengths and equities of the case.  The rationale for the reduction
must be expressed in writing in the case file and in any memoranda
accompanying the settlement.  See the discussion on pages 12 and
13 for further specifics on adjustments appropriate on the basis
of either compelling public policy concerns or the strengths and
equities of the case.


II.  Alternative Payments

   .  In the past, the Agency has accepted various environmentally
beneficial expenditures in settlement of a case and chosen not to
I/ If a firm fails to pay the agreed-to penalty  in  an  adminis-
trative or judicial final order, then the Agency must  follow
the Federal Claims Collection Act procedures  for obtaining the
penalty amount.
                                81

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                              -25-

pursue more severe penalties,   in general,  the  regulated  community
has been very receptive  to this practice,   in many cases,
violators have found  "alternative payments"  to  be more  attrac-
tive  than a traditional  penalty.   Many  useful projects  have been
accomplished with such funds.'  But in some  instances, EPA has
accepted for credit certain expenditures whose  actual environ-
mental benefit has been  somewhat  speculative.

      The Agency believes that  these alternative payment projects
should^be reserved as an incentive to settlement before litigation.
For thi-s reason, such arrangements will be  allowed only in preliti-
gation agreements except in extraordinary circumstances.

      In addition, the acceptance  of alternative payments  for
environmentally beneficial expenditures is  subject to certain
conditions.  The Agency  has designed these  conditions to prevent
the abuse of this procedure.   Most of the conditions below applied
in the past, but some are new.  All of  these conditions must be
met before alternative payments may be  accepted:^/

          0  No credits  can be given for activities
             that currently are or will be  required
             under current law or are likely to be re-
             quired, under existing statutory authority
             in the forseeable future (e.g., through
             upcoming rulemaking).

          0  The majority of the  project's  environmental
             benefit should accrue to the general public
             rather than to the source  or any particular
             governmental unit.

          0  The project cannot be something which the
             violator could reasonably  be expected to do
             as part of  sound  business  practices.
4/ In extraordinary circumstances,.the Agency may choose not to
pursue higher penalties for  "alternative" work done prior to
commencement of negotiations.   For  example, a firm may recall a
product found to be in violation despite the fact that such
recall is not required.  In  order for EPA .to forgo seeking
higher penalties, the violator  must prove that it has met the
other conditions herein stated.  If the violator fails to prove
this in a satisfactory manner,  the  case development team has the
discretion to completely disallow the credit project.  As with
all alternative projects, the case  development team has the dis-
cretion to still pursue some penalties in settlement.
                               82

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                             -26-
          *  EPA must not lower the amount it decides
             to accept in penalties by more than the
             after-tax amount the violator spends on
             the project.^/

      In all cases where alternative payments are allowed, the
case  file should contain documentation showing that each of
the conditions listed above have been met in that particular
case.  .In addition when considering penalty credits, Agency
negotiators should take into account the following points:

          0  The project should not require a large
             amount of EPA oversight for its comple-
             tion.  In general the less oversight
             the proposed, credit project would
             require from EPA to ensure proper
             completion, the more receptive EPA
             can be toward accepting the project
             in settlement.
               «
          0  The project should receive stronger
             consideration if it will result in the
             abatement of existing pollution,
             ameliorate the pollution problem that
             is the basis of the government's claim
             and involve an activity that could be
             ordered by a judge as equitable relief.
                      •
          0  The project should receive stronger
             consideration if undertaken at the
             facility where the violation took place.

          0  The company should agree that any publicity
             it disseminates regarding its funding of
             the project must include a statement that
             such funding is in settlement of a lawsuit
             brought by EPA or the state.
J5/ This limitation does not apply to public awareness  activities
such as those employed for fuel switching and tampering  violations
under the Clean Air Act.  The purpose of the limitation  is  to
preserve the deterrent value of the settlement.  But these  viola-
tions are often the result of public misconceptions about the
economic value of these violations.  Consequently, the public
awareness activities can be effective in preventing others  from
violating the law.  Thus, the high general deterrent value  of
public awareness activities in these circumstances obviates the
need for the one-to-one requirement on  penalty  credits.
                                83

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                              -27-

      Each alternative payment plan must entail an identified
 project to be completely performed by the defendant.  Under the
 plan, EPA must not hold any funds which are to be spent at EPA's
 discretion unless the relevant statute specifically provides
 that authority.   The final order, decree or judgment should
 state what financial penalty the violator is actually paying and
 describe as precisely as possible the credit project the violator
 is expected to perform.

       «
       *
 III. Promoting Consistency

      Treating similar situations in a similar fashion is central
 to the credibility of EPA's enforcement effort and to the success
.of achieving the goal of equitable treatment.  This document has
 established several mechanisms to promote such consistency.   Yet
 it still leaves enough flexibility for settlement and for tailor-
 ing the penalty to particular circumstances.  Perhaps the most
 important mechanisms for achieving consistency are the systematic
 methods for calculating the benefit component and gravity compo-
 nent of the penalty.  Toge-ther, they add up to the preliminary
 deterrence amount.  The document also sets out guidance on uniform
 approaches for applying adjustment factors to arrive at an initial
 penalty target prior to beginning settlement negotiations or an
 adjusted penalty target after negotiations have begun.

      Nevertheless, if the Agency is to promote consistency,  it
 is essential that each* case file contain a complete description
 of how each penalty was developed.  This description should cover
 how the preliminary deterrence amount was calculated and any
 adjustments made to the preliminary deterrence amount.  It should
 also describe the facts and reasons which support such adjustments.
 Only through such complete documentation can enforcement attorneys,
 program staff and their managers learn from each others' experience
 and promote the"fairness required by the Policy on Civil Penalties.

      To facilitate the use of this information, Office of Legal
 and Enforcement Policy will pursue integration of penalty infor-
 mation from judicial enforcement actions into a computer system.
 Both Headquarters and all Regional offices will have access to
 the system through terminals.  This would make it possible for
 the Regions to compare the handling of their cases with those of-
 other Regions.  It could potentially allow the Regions, as well
 as Headquarters,  to learn from each others' experience and to
 identify problem areas where policy change or further, guidance
 is needed.
                                 84

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                              -28-
Use of Penalty Figure  in Settlement Discussions                 ~~~~
                                                ^^^^^^^^^^^^^^^^         ^^^^^^"^^"^^*

    The Policy and Framework  do not seek to constrain negotiations.
Their goal is to set settlement target figures for the internal
use of Agency negotiators.  Consequently, the penalty figures
under negotiation do not necessarily have to be as low as the
internal target figures.  Nevertheless,  the final settlement
figures should go no lower  than the' internal target figures unless
either: 1) the medium-specific  penalty policy so provides or
2) the 'reasons for the deviation are properly documented.

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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON. D.C. 20460  -
                                   December 15, 1995          .            OFFICE OF
                                                                        ENFORCEMENT AND
 MEMORANDUM            ..                  '                      «>MPUANCE ASSURANCE


 SUBJECT:    Guidance on Use of Penalty Policies in Administrative Litigation
                l^uUx^nAtv  AJ-ti-txJ?*-^.
 FROM)  ,     Robert Van HeuvelenVDirector
              Office of Regulatory Enforcement    "     .       .    .
       •                          *

 TO:          Regional Counsels, Regions I - X
              Director,  Office of Environmental Stewardship, Region I
              Director,  Compliance Assurance & Enforcement Division, Region VI
              Director,  Office of Enforcement, Compliance & Environmental Justice
                    Region VIII
              Regional Enforcement Coordinators, Regions I-X
 A..    Introduction

       This document provides guidance oh how penalty amounts should be pled and argued
 in administrative litigation and how penalty policies should be used in this process.
IL     Background

       On September 29, 1995, Chief Administrative Law Judge Lotis issued iin Initial
Decision in In Re: Employers Insurance of Wausau. ruling that EPA must present evidence
other than the PCB Penalty Policy in order to support its proposed penalty.    We think the
decision in the Wausau case is inconsistent with decisions on the use of penalty policies by
the Environmental Appeals Board, in particular PIC Americas. Inc.. TSC A Appeal No. 94-2
(September 27,  1995).   The Agency is appealing the Wausau decision to the Environmental
Appeals Board.  Accordingly, this document  is being issued in response to the  Wausau
decision to provide guidance  on our administrative penalty pleading practices and use of
penalty policies.   After we receive a decision from the Environmental Appeals Board on our
appeal we may revise this guidance as  appropriate.
                                                                          ill  25  i993
                                            n^                      I . \             a Int ofl ymomt r«
                                            86

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       _   •.•--••     ,             .    page 2:    .     .,":,••;•

  £..     Use of Penalty Policies in Administrative Lirigatioq       "    /     .   ,.

         L      Federal environmental statutes set forth .various factors which EPA or a court
 . must consider in establishing penalties.  EPA's penalty policies are based on die statutory
  penally factors.  The policies provide EPA enforcement staff whh a logical calculation
  methodology for determining appropriate penalties.  The policies help EPA apply the
  smtutory penalty factors in a consistent and equitable manner so that members of the '
  regulated community are treated similarly for similar: violations* across the country.  As
  policies, they are not substantive rules under the Administrative Procedure Act.1  '

    :,    2,.    ;The penalty amount sought in the administrative complaint is based on the  ;
  relevant statutory factors. .The penalty amount pled should be calculated pursuant to any
 ^applicable penalty ptolicy and the specific facts, ojy^case.J^Jf there: is.no applicable policy,
 •diepenalty iamouht robe pled in the coniplaint^shoiSdibe:.b^j^!ph"m^.sc^rary'facii6lrs''v'*'':''
  governing penalty assessment, case kw interpreting such factors, and the'facts jof the
  particular case.?. C . ^     '          •  -'.  "'-•'•-'•••'-•*•  ••'•-^•-  "•'  •'      "•--•'    -•  "-"
       - 3o    - The administrative complaint should explain that the penalty requested is based
  on the statutory provisions governing penalty assessment and it was calculated using a policy
  that applies the statutory facrors.  Accordingly, the administrative complaint should contain
  a paragraph similar to this model:  .         ^7^?; ^ ^ :  • _: r"     :-,. rv:;  '     •      >

        The proposed civil penalty tas been determined in accordance with [cite to
        relevant statutory penalty provision].  For purposes of determining the amount
      .  of any penalty, us be assessed, [section of the Act] requires EPA to take into
     1  The policies are a mix of legal interpretations, general policy, and procedural guidance in how -
 EPA should allocate its enforcement resources and exercise its enforcement discretion. As such, they
 are exempt from the notice and comment ruleinakingjequirements of the Administratjye Procedures
 AS.5U.S.C. §553-  .v     -'•     ,  '        ..:---.-•       ,-,.        ..  .  ,  •     •   •-
    2 Not all EPA programs have penalty policies that 'establish calculation methodologies fcjr use in
 determining the penalty .amount .to plead in an admhiistratiye complaint. For example; the May 1995
 Interim Revised Clean Water Act Settlement Policy and the May, 1994 Public Water System Supervision
 Settlement Penalty Policy only establish, how the Agency expects to calculate the minimum penalty for
 which it would be willing to settle a case; these policies are not to be used in pleading penalties, or in
 a hearing or at trial.                         ;            "    .      . ._'*•'••

    3 The Region should not use the policy in a parocular case if the penalty amount produced by the
'calculation methodology produces an amount that appears inconsistent with the statutory penalty
 factors or otherwise unreasonable.  In such a case, the Region miist consult with OECA prior to
 deviating from the policy. See Redelegation of Authority and Guidance on Headquarters Involvement
 in Regulatory Enforcement Cases, memo issued by die Assistant  Administrator, on July  11, 1994.
 especially page 3. and page 2 of the redelegation issued the same date, and subsequent program
 specific implementing guidances.          •         .
                                         87

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'. •.    '                                  page3

 -      account [enumerate statutory penalty factors]. To develop the proposed   -
  -  -   penalty in this complaint, complainant has: taken into account the particular
       facts and circumstances of this case with specific reference to EPA's [name of
       relevant penalty policy,' if applicable], a copy.of which is enclosed with mis.
       Complaint.  This policy provides a rational, consistent and equitable
  .  :.  calculation methodology for applying the statutory penalty factors enumerated
.       above to particular cases.    .-",    .               .  -
    " "". ~       -              "         * • - - ..-'    ''                           - *
  .     4..     As further support of the .penalty proposed in the complaint, a case "record"
file should document or reference all factual information on which EPA relied to develop the
penalty amount pled in the complaint.  If the Agency has an applicable penalty policy (other
than an exclusive settlement-policy), the file should contain a computation worksheet setting
forth how the penalty was calculated in the  specific case, along with a narrative description
of the  specific calculation. This  narrative description need not.be lengthy, but it should .
explain how any applicable penalty, policy methodology was applied to the specific facts in
the case.4  If there was no applicable penalty policy, the record file should contain a
narrative description of how the statutory penalty-factors were applied to develop the amount
pled in the complaint.  In short, the record  file should document the facts and rationale '  .
which  formed the basis for the penalty amount pled  in the administrative complaint.  In the
prehearing exchange, EPA counsel may provide the  respondent with* copies of relevant
documents from the case record file.5        .                         •
                    m   *                        ,

       5.      Pursuant to the Consolidated  Rules of Practice Governing the Administrative
Assessment of Civil Penalties, 40 CFR §22.24, the complainant (usually the  Region), has the
burden of presenting why die proposed penalty is appropriate. This burden of persuasion
may be subdivided into three tasks or parts:

       a) why any applicable penalty policy is a reasonable approach to use in the instant
';      case;.-;-    •    .                                         .
       b) proving the facts relevant to penalty assessment; and            .
   '•••/''      •.              •    -                    •        •
       c) why the particular facts merit the penalty proposed in the complaint.
               •                     '                                 *,
Each of these three tasks is discussed below.
   *  See. e.g.. the RCRA Civil Penalty Policy, October 1990, pages 6 to 8. 41 to 47.   .

   s The case record file only should contain final documents, and not preliminary, draft, or
confidential documents.  For example, documents evaluating the appropriate enforcement action.
planning legal strategy, .or establishing a settlement penalty amount are not pan of the record file and
should not be released.
                                         88

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                                          page 4

 a.  Presenting anv applicable penalty policy as a reasonable approach.  In the prehearing
 exchange or at the hearing, EPA counsel should briefly explain why the applicable penalty
 policy is a reasonable way to apply the statutory factors. This explanation is a legal and
 policy analysis, which can be presented primarily, if not entirely, in briefs based on the
 written policy.  Administrative law judges, however, may prefer some pans of this analysis
 to be presented "through testimony or affidavits.  If the Presiding Officer or respondent
 challenges the rationale or the basis for the penalty policy,  complainant should provide a
 detailed explanation of why the penalty policy is a fair and logical way to apply the statutory
 factors.6  Since penalty policies are not binding rules, such challenges must be responded to
 on the merits.  Counsel should explain how the penalty policy provides a consistent, fair and
 logical  framework for quantifying the statutory penalty factors to the particular circumstances
 of the instant case.   Of course, the Presiding Officer is free to adopt a different  framework
 other than the penalty policy for applying me statutory factors and ultimately arriving at a
 penalty amount.

 b.  Proving the facts relevant to penalty assessment.  In the prehearing exchange  or hearing,
 the facts relevant to determining an appropriate penalty under the particular statute should be
 presented as evidence.  The relevant facts will depend on the circumstances of the specific
 case and the statutory penalty factors.   Such facts usually include the number, duration, and
 rypes of violations, any economic benefit resulting from the violations, the pollutants
 involved, and the  environmental impact of the violations.  Some of these facts may have
 been established in proving .the violations.

 c.  Whv the particular facts merit the penalty proposed  in the complaint.  This task requires
 the complainant to persuade the Presiding Officer why the penalty requested  in the complaint
 is appropriate based on the statutory penalty factors and the facts in the case.  If  a penalty
 policy was used to calculate the penalty, an explanation of  the calculation methodology
 should be presented.  This task is primarily,  if not exclusively, a legal and policy analysis
 and should be-done through briefs or argument.  If the Presiding Officer requires testimony
 regarding such analysis, the Region may  identify'a"Regional enforcement person-experienced
 in using and understanding the applicable penalty policy, and capable of discussing the nature
 and seriousness of the violations in the instant case.  This expert should not be the counsel in
 the case.                                                                         '
       If you have any questions regarding this guidance, you may call David Hindin at 202
564-6004, or Scott Garrison at 202 564-4047.

cc:     Sylvia K. Lowrance; ORE Division Directors
       ORE Branch Chiefs; Workgroup members
   * Regions should consult with ORE on how to respond to such challenges.
                                            89

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 [signed March 19, 1997]
/r C. - /P_
                            /sr

                              ^
 MEMORANDUM

 SUBJECT:    Impact of Wausau on Use of Penalty Policies

 FROM:  .     Robert I. Van Heuvelen, Director
              Office of Regulatory .Enforcement

 TO:          Regional Counsels, Regions I - X
              Director, Office of Environmental Stewardship, Region I
              Director, Division of Enforcement and Compliance Assurance, Region
              Director, Compliance Assurance & Enforcement Division, Region VI
              Director, Office of Enforcement, Compliance & Environmental Justice,
 Region Vm
              Regional Enforcement Coordinators, Regions I-X
       On February 11,. 1997, the Environmental Appeals Board ("EAB") ruled on the Agency's
 appeal of In the Matter of Employers Insurance of Wausau and Group Eight Technology. Inc..
 TSCA Appeal No. 95-6, of the September 29, 1995, Initial Decision of the former Chief
 Administrative Law Judge Jon Lou's. The EAB reversed those portions of the Initial Decision
 concerning the validity and use of penalty policies,'endorsed the penalty policy ceneept, and
 validated the Agency's method of applying its penalty policies.

       The EAB affirmed that the Agency's penalty policies are not rules, and that the Agency
 can use penalty policies without going through, notice and comment rulemaking so long as
 Agency decisionmakers (i.e., the Presiding Officer and EAB) are under no obligation to adhere to
 a penalty policy in a particular instance. Slip op. at 36-38. The Board held that proof of
 adherence to the penalty policy can legitimately form a part of complainant's prima facie penalty
 case.as evidence that the statutory penalty factors were taken into account, provided that the
 penalty policy addresses all applicable statutory penalty factors. Moreover, where a penalty
policy is designed to enhance fairness and consistency of penalty assessments, proof of adherence
to the penalty policy provides some evidence that the proposed penalty is appropriate. Id. at 35.

       In order to establish the "appropriateness" o.f a recommended penalty, complainant must
                                           90

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demonstrate how die statutory penalty factors relate to the particular facts of the violation. Id. at
30.  The Consolidated Rules of Practice, 40 C.F.R. § 22.24, requires complainant to come
forward with evidence to show (1) that it considered each statutory factor, and (2) that its
recommended penalty is supported by its analysis of those factors.  However, nothing in TSCA,
the Consolidated Rules of Practice, or the Administrative Procedure Act requires that
complainant provide evidence supporting the findings, assumptions and determinations underlying
the penalty policy in order to make a prima facie case for the appropriateness of a proposed
penalty. Id. at 34-35. Complainant need not offer such evidentiary support in the absence of a
specific challenge by respondent or a specific request by the Presiding Officer.

        After the Agency has made its prima facie case, the Presiding Officer must be prepared to
re-examine the basic propositions upon which a penalty policy is based in any case where they are
genuinely placed in issue. Id., at 36. Indeed, even where respondent does not contest the penalty,
the Presiding Officer need not assess the proposed penalty and is not constrained by the
complainant's penalty proposal. H. at 31.  The Presiding-Officer must either (1) ensure that
complainant properly took into account the statutory penalty factors and assess the proposed
penalty, or (2) specify reasons for disagreeing with complainant's analysis and assess a different
penalty that reasonably applies the statutory penalty factors to the facts of the violation.  Id. at 32.
The EAB noted  that there is no evidence that EPA's Presiding Officers apply penalty policies so
inflexibly as to belie the EAB's repeated assurances that the penalty policies do not bind the
Presiding Officers in the manner of rules. M-  at 36-37.

        The EAB ruled that where complainant gives clear notice in its prehearing exchange that it
would rely on a penalty policy to support its penalty proposals, and where respondent does not
challenge any of the factual propositions underlying the penalty policy, it is error for a Presiding
Officer to reject  a penalty proposal for complainant's failure to offer evidence beyond that
sufficient to make its prima facie penalty case where the Presiding Officer did not demand such
evidence during  the hearing. Id. at 34-35. The Presiding Officer may demand additional
argument or evidence to support its analysis of the statutory penalty factors, but it is error to
articulate such a demand only after the hearing, when the demand could no longer be satisfied. Id
at 3 8-39.

       The EAB's decision removes the cloud cast over our administrative enforcement practice
by the initial decision in Wausau.  In the wake of that initial decision, ORE issued the attached
memorandum, "Guidance on Use of Penalty Policies in Administrative Litigation", dated •
December 15,1995, reiterating the proper application of penalty policies in administrative
litigation. As the EAB has now confirmed its approval of the Agency's use of tne penalty
policies, there is  no need to amend the December 15,1995, guidance, which shall remain in effect
until further notice.
             «                                                                           '
       If you have any questions regarding this memorandum, you may call Scott Garrison at 202
564-4047.

cc:    Sylvia K. Lowrance
       ORE Division Directors
                                                91

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      \        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
       I                       WASHINGTON. D.C. 20460
                                      -Q IQQl?                             CfrlCEOF
                                        0 IC7C"
                                                                        ENFO?CEME1*T AND
                                                                      COMPLIANCE ASSURANCE
MEMORANDUM
SUBJECT:    Modifications to EPA Penalty Policies to Implement the Civil Monetary Penalty
              Inflation Rule (Pursuant to tha Debt Collection Improvement Act of 1996)
FROM:       Steven A. He
              Assistant A

TO:          Regional Administrators

       The Environmental Protection Agency ("EPA") published a new rule in the Federal
Register -- 40 CFR Part 19, Adjustment of Civil Penalties for Inflation - implementing the Debt
Collection Improvement Act of 1996 ("DCIA"), on December 31, 1996. At the same rime, we
also published minor conforming amendments to 40 CFR Part 27, Program Fraud Civil
Remedies. The rule took effect thirty days later on January 30, 1997. This means all violations
occurring on or after January 31, 1997, are subject to the new inflation-adjusted penalty
amounts.1 We have attached a copy of the published rule", and the March 20, 1997, correction,
for your convenience.
       1   There are two sets of exceptions to the January 31,1997, date for using adjusted
penalty maximums. The first exceptions are for the four penalty provisions added or revised by
the August 1996 amendments to the SDWA which have an effective date of August 6,1996.
Those penalty provisions were not subject to inflation adjustment. The applicable unadjusted
maximums for those provisions are now included in the March 20,1997, Table 1.  These
provisions are 42 U.S.C. 300g-3(g)(3)(B), 42 U.S.C. 300g-3(g)(3)(C), 42 U.S.C.  300i(b) and
42 U.S.C. 300j-6(b)(2). The second exception is for the recently identified amendment affecting
TSCA, 15 U.S.C. 2615; through the Residential Lead-Based Paint Hazard Reduction Act of 1992
("Lead Paint Act"), 42 U.S.C. 4852d.  This portion of the Lead Paint Act and the corresponding
regulations in 40 CFR Part 745, which are enforced through TSCA 15 U.S.C. 2615, were omitted
from the December 31,1996 rule-making. EPA anticipates performing a rule-making to adjust
42 U.S.C. 4852d, Part 745, and indirectly 15 U.S.C. 2615, within the next few months.  The
effective date for these penalty provisions will be thirty days following their adjustment and
publication in the Federal Register.
           Recyctod/R«cycl«W» . Printed with Vegetable Qil Based InKs on 100% Recycled Paper (40% Posteonsumer)

                                            92

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                                                                         Page 2

       This penalty policy memorandum modifies all of our existing civil penalty policies to
conform to the DCIA and the new rale. This memorandum also provides guidance on how to
plead penalties and how to determine the new maximum penalty amounts that may be sought in
single administrative enforcement actions under the Clean Water Act ("CWA"), the Safe
Prinking Water Act ("SDWA"), and the Clean Air Act ("CAA").
OVERVIEW

       The primary purpose of the DCIA is to restore the deterrent effect of civil statutory
penalty provisions which have been eroded by inflation. In particular, the DCIA directed each
federal agency to review its respective civil monetary penalty ("CMP") provisions and to issue a
regulation adjusting them for inflation. The DCIA also requires periodic review and adjustment
of the CMP's at least once every four years.

       This first penalty inflation adjustment was limited by the DCIA to 10% above the
existing statutory provision's maximum amount.  For EPA, this meant all the penalty provision
maximums, with the exception of a few new penalty provisions added by the 1996 SDWA
amendments (which did not require any adjustment), have been adjusted upward by 10%.

       The statutory penalty provisions and the new maximum penalty amounts are found in the
attached Table 1 of 40 CFR 19.4 (as corrected on March 20,  1997).  These increases in the CMPs
apply onlv to violations which occur after the date the increases take effect on January 30.1997 -
that is. violations which occur on or after January 31.1997.2  For example, CWA Section 309
previously authorized judicial penalties of up to $25,000 per day per violation; and now, since
the new rule became effective, the^new maximum penalty amount is $27,500. Therefore, if a
violation subject to CWA section 309(d) started  on January  1,1997, and continued through
February 2,1997, the maximum statutory penalty liability would consist of 30 days of violations
at $25,000 per day, plus 3 days of violation at $27,500.
PENALTY POLICY CALCULATION CHANGES

       For the time being, we are not planning to amend the specific language, penalty matrices
or formulas in any of our existing penalty policies based on the revised penalty maximums
contained in 40 CFR Part 19. If a sufficient need to revise the particular provisions of one or
more of the policies is identified, we will consider taking such action at a later time We are,
however, by this Policy, modifying all of our existing penalty policies, to increase the initial
gravity component of the penalty calculation by 10% for those violations subject to the new
        Supra note 1.
                                            93

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                                                                           Page3

rule.3 We believe this is consistent with the Congressional intent in passing the DCIA and is
necessary to implement effectively the mandated penalty increases that we have set forth in 40
CFR Part 19.' Accordingly, each penalty policy is now modified to apply the appropriate
guidelines set forth below4.  These new guidelines apply to all penalty policies, regardless of
whether the policy is used for determining a specific amount to plead in a complaint or for
determining a bottom-line settlement amount. (A complete list of all of our existins penalty
policies is provided at the end of this memorandum.)5

       A.     If all of the violations in a particular case occurred before the effective date of the
new rule, no changes in our penalty policies are necessary.

       B.     For those judicial and administrative cases in which some, but not all. of the
violations occurred after the effective date of the new rule, the penalty policy calculations are
modified by following these five steps:

        1.     Perform the economic benefit- calculation for the entire period of the violation,
       going beyond the January 30,1997, effective date of the new .rule if appropriate.6  Do not
       apply any mitigation or adjustment factors (such as, good faith, ability to pay. litigation
       considerations or supplemental environmental projects) at this point.

       2.     Apply the gravity component of the penalty policy in the standard way (without
       economic benefit which has been covered in step 1, above) for all violations to produce
       the gravity component value. Do not apply any mitigation or adjustment factors (such as
       good faith, self-audits, ability to pay, litigation considerations or supplemental
       environmental projects) at this point.
       3 This ten percent increase should be used in virtually all cases. However, in some cases
the Region, after consulting with the applicable OECA Division,  may increase the gravity
amount by less than 10% —  e.g., only 5 % — if it believes the gravity amount prior to the
inflation is already sufficiently high to fully account for the .severity of the violations. For
example, if all of the violations that occurred after the effective date were extremely minor, the
Region may elect to inflate the gravity component for these violations by less than 10%.

       4 Where no specific penalty policy currently applies, follow the general penalty policies,
which are also modified by mis penalty policy. Likewise, all new penalty policies being
prepared should take the inflation adjustment of statutory maximums into account.

       5 Whenever a copy of a particular penalty policy is provided to someone, a copy of this
modifying policy should be provided as well.

       6  The calculation of economic benefit is not affected by the new rule. If there is no
identifiable economic benefit component in a penalty policy, then all of the penalty is considered
gravity for purposes herein.
                                        94

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                                                                            Page 4

       3.     Determine the percentage of the resulting gravity component value which
       occurred after the effective date of the penalty inflation adjustment, January 30.1997-
       Multiply the post-effective date percentage by 0.10. Next, add 1 to the resulting value,
       and this will provide the gravity adjustment factor.  For example, if approximately 40%
       of the violations hi a case occurred on or after January 31,1997, the gravity adjustment
       factor would be calculated as follows:  [0.10 x .40] + 1 = 1.040 (the resulting gravity
       adjustment factor).

       4.      Multiply the gravity component from step 2 by the gravity adjustment factor from
       step 3. This produces a gravity component that has been adjusted based on the penalty
       inflation rule.

       5.     Add the subtotals from steps 1 and 4, above.  Adjust the total, as appropriate
       pursuant to the applicable policy, for good faith, self-audits, ability to pay. litigation
       considerations, supplemental environmental projects, or other applicable mitigation
       factors.
C.     If all the violations hi a particular case occurred on or after the effective date of the new
rule, the penalty policy calculation is modified by following these three steps:

       1.     Following the existing guidance, calculate the economic benefit covering the
       entire period of the violations.  Do not apply any mitigation or adjustment factors (such
       as good faith, ability to pay, litigation considerations or supplemental environmental
       projects) at this point.
                                if
                             - ^
       2.     Apply the penalty policy hi the standard way to calculate the gravity component
       (essentially everything except economic benefit, covered in stepl, above, is gravity). Do
       not apply any mitigation or adjustment factors (such as good faith, self-audits, ability to
       pay, litigation considerations or supplemental environmental projects) at this point. After
       this calculation has been completed, multiply it by 1.10. This produces a gravity amount
       increased by 10 % hi accordance with the DCIA.

       3.     Add the adjusted gravity amount in step 2 to the  economic benefit component.
       Adjust this sum, as appropriate, pursuant to the applicable policy for good faith, self-
       audits, ability to pay, litigation considerations, supplemental environmental projects or
       other applicable mitigation factors.
PENALTY PLEADING

       If all of the violations in a particular case occurred before the effective date of the new
rule, no changes in our pleading practices are necessary. If some of the violations in a particular
                                              95

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                                                                         PageS

 case occurred after the effective date, then in judicial cases using "notice pleading" - that is
 pleading "up to the statutory maximum amount" (and in any administrative cases\vhich use
 notice pleading), the penalty amount pled should use the newly adjusted maximum amounts. For
 example, in a civil judicial complaint alleging violations of section 301 of the Clean Water Act,
 the prayer for relief would be written as follows:

       Pursuant to Section 309(d) of the Clean Water Act, 33 U.S.C. § 1319(d), and 40
       CFR Part 19, assess civil penalties against [name] not to exceed $25,000 per day
       for each violation of Section 301(a) of the Act, 33 U.S.C. §1311(a), that occurred
       prior to January 31,1997;  and $27,500 per day for each violation of Section 301
       of the Act, 33 U.S.C. § 1311, that occurred on or after January 31,1997,  up to the
       date of judgment herein. .

       If all of the violations in a particular case occurred after the effective date of the "new rule,
 then in judicial cases using "notice pleading" (and in any administrative cases which use notice '
 pleading) the penalty amount pled should use the newly adjusted maximum amounts. For
 example, hi a civil judicial complaint alleging violations of section 301 of the Clean Water Act,
 the prayer for relief would be written as follows:

       Pursuant to Section 309(d) of the Clean Water Act, 33 U.S.C. § 1319(d), and 40
       CFR Part 19, assess civil penalties against [name] not to exceed $27,500  per day
       for each violation of Section 301 of the Act, 33 U.S.C. §1311, up to the date of
       judgment herein.
 ADMINISTRATIVE PENALTY CAPS FOR CWA. SDWA. AND CAA

       The DCIA and 40 CFR Part 19 raised the maximum penalty amounts that may be sought
 for individual violations in administrative enforcement actions, as well as the total amounts that
 may be sought in a single administrative enforcement action. This increase is particularly
 relevant for administrative enforcement actions under the CWA, SDWA, and CAA which are
 limited by penalty maximums that may be sought in a single action, (commonly called "caps").
 For example, prior to the DCIA and 40 CFR Part 19, CWA Class II administrative penalties were
 authorized up to $10,000 per violation and not to exceed $125,000 in a single administrative
 action; since the effective date of the new rule, the new penalty maximums are now SI 1,000 and
 $ 137,500, respectively.  Similarly, Part 19 also raised the total penalty amounts that may be
 sought in a single administrative  enforcement action under the CAA from $200,000 to 5220,000
 (although higher amounts may still be pursued with the joint approval of the Administrator and
Attorney General).

       The new penalty maximums/caps may be used only in a single administrative
enforcement action under the CWA, SDWA, and CAA, provided the individual penalties for the
post-effective date violations equal or exceed the previous unadjusted maximums (caps). In

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                                                                        Page 6

other words, the penalties assessed can only exceed the old maximums/caps, up to the new
maximums/caps, based solely on penalties for the new violations. For example, in a C WA Class
II administrative enforcement complaint, there must have been at least 12 violations occurring
after January 30,1997, in order to exceed the previous maximum penalty of $125,000 (12
violations X $11,000 = $132.000). If there are not at least 12 violations occurring after January
30,1997, then the maximum amount which may be sought hi a CWA Class II administrative
enforcement action is still $125,000.

       As another example, in a CAA administrative enforcement action for violations of
Section 203(a)(l) of the CAA,  there must be at least eight violations that occurred after January
30,1997, for the new $220,000 maximum penalty cap to apply (8 violations X $27.500 =
220,000).  If there are not at least eight violations after January 30,1997, then the maximum
amount that may be sought in such a CAA administrative enforcement action is still S200.000
(unless otherwise increased by joint agreement of the Administrator or Attorney General).
CHALLENGES TN THE COURSE OF ENFORCEMENT PROCEEDINGS

       If a defendant should choose to challenge the validity of applying the adjusted penalty
provisions on the grounds that EPA did not have the authority to promulgate the rule which
adjusted the penalty maximums, please notify the Multimedia Enforcement Division of the
challenge, so that OECA and the Region can coordinate our response before a response is filed.
We expect our response to argue that the statutory penalties were raised by an Act of Congress,
and, therefore, the Agency merely carried out a non-discretionary ministerial duty in publishing a
rule identifying the specific provisions and applying the Congressional formula for the
adjustment.                  .  f*
FURTHER INFORMATION

       Any questions concerning the new rule and implementation can be directed to Steven
Spiegel in the Multimedia Enforcement Division, our workgroup chair, via email, or to (703)
308-8507. Additionally, offices that identify penalty policies which may need individual
modifications should send a memorandum via email to Steven Spiegel, specifying the policy and
the suggested changes.
                 LIST OF EXISTING EPA CIVIL PENALTY POLICIES
                        MODIFIED BY THIS MEMORANDUM

General

       Policy on Civil Penalties (2/14/84)
                                           97

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                                                                         Pase7
       A Framework for Statute-Specific Approaches to Penalty Assessments (2/14/84)
       Guidance on Use of Penalty Policies in Administrative Litigation, (12/15/95)

Clean Air Act - Stationary Sources

       Clean Air Act Stationary Source Civil Penalty Policy (10/25/91) (This is a generic policy
       for stationary sources.)
       Clarifications to the October 25,1991 Clean Air Act Stationary Source Civil Penaltv
       Policy (1/17/92)

       There are a series of appendices that address certain specific subprograms within the
stationary source program.
       Appendix I - Permit Requirements for the Construction or Modification of Major
       Stationary Sources of Air Pollution (Not Dated)
       Appendix H - Vinyl Chloride Civil Penalty Policy (Not Dated)
       Appendix III - Asbestos Demolition and Renovation Civil Penalty Policy (Revised
       5/5/92")
       Appendix IV - Volatile Organic Compounds  Where Reformulation of Low Solvent
       Technology is the Applicable Method of Compliance (Not Dated)
       Appendix V - Air Civil Penalty Worksheet
       Appendix VI - Volatile Hazardous Air Pollutant Civil Penalty Policy ("Revised 3/2/8 S')
       Appendix VH - Residential Wood Heaters (Not Dated)
       Appendix VIII - Manufacture or Import of Controlled Substances in Amounts Exceeding
       Allowances Properly Held Under Protection of Stratospheric Ozone (11/24/89)
       Appendix IX - Clean Air Act Civil Penalty Policy Applicable to Persons Who Perform
       Service for Consideration oh a Motor Vehicle Air Conditioner Involving the Refrigerant
       or Who Sell Small Containers of Refrigerant in Violation of 40 CFR Part 82, Protection
       of Stratospheric Ozone, Subpart B (Not Dated)
       Appendix X - Clean Air Act Civil Penalty Policy for Violations of 40 CFR Part 82,
       Subpart F: Maintenance, Service, Repair, and Disposal of Appliances Containing
       Refrigerant (6/1/94)
       Appendix XI - Clean Air Act Civil Penalty Policy for Violations of 40 CFR Part 82;
       Subpart C: Ban onNonessential Products Containing Class I Substances and Ban on
       Nonessential Products Containing or Manufactured with Class II Substances (Not Dated)

Clean Air Act - Mobile Sources

       Volatility Civil Penalty Policy (12/1/89)
       Civil Penalty Policy for Administrative Hearings (1/14/93)
       Manufacturers Programs Branch Interim Penalty Policy  (3/31/93)
       Interim Diesel Civil Penalty Policy (2/8/94)
       Tampering and Defeat Device. Civil Penalty Policy for Notices of Violation (2/28/94)
      ' Draft Reformulated Gasoline and Anti-Dumping Settlement Policy (6/3/96)   ,
                                          98

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                                                                       PageS

 TSCA

       Guidelines for the Assessment of Civil Penalties Under Section 16 of TSCA (7,7/80)
       (Published in Federal Register of 9/10/80. Note that the first PCB penalty policy was
       published along with it. but the PCB policy is now obsolete.)  This is a generic policy for
       TSCA sources. There are a series of policies that address certain specific subprograms
       within TSCA. They are as follows:

             Record keeping and Reporting Rules TSCA Sections 8,12, and 13
             (8/5/96)
             PCB Penalty Policy (4/9/90)
             TSCA Section 5 Enforcement Response Policy (6/8/89), amended (7/1.93)
             TSCA Good Laboratory Practices Regulations Enforcement Policy (4/9/85)
             TSCA Section 4 Test Rules (5/28/86)
             TSCA Title n - Asbestos Hazard Emergency Response Act (AHERA)
             Interim Final ERP for the Asbestos Hazard Emergency Response Act (1/31/89)
             ERP for Asbestos Abatement Projects; Worker Protection Rule (11/14/89)

 Safe Drinking Water Act - UIC

       Interim Final UIC Program Judicial and Administrative Order Settlement Penalty Policy -
       - Underground Injection Control Guidance No. 79 (9/27/93)

 Safe Drinking Water Act - PWS

       New Public Water System-Supervision Program Settlement Penalty Policy (5/25/94)
 EPCRA
       Final Penalty Policy for Sections 302,303,304,311, and 312 of EPCRA and Section 103
       of CERCLA (6/13/90)
       Enforcement Response Policy for Section 313 of EPCRA and Section 6607 of the
       Pollution Prevention Act (8/10/92); Low Volume Alternate Threshold ERP Revisions
       (12/18/96)
Clean Water Act
       Revised Interim Clean Water Act Settlement Penalty Policy, February 28,1995
       Clean Water Act Section 404 Civil Administrative Penalty Actions Guidance on
       Calculating Settlement Amounts
RCRA
                                                  99

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                                                                            Page 9

       RCRA Civil Penalty Policy (October 1990)

UST

       U.S. EPA Penalty Guidance for Violations of UST Regulations (November 1990)
       Guidance for Federal Field Citation Enforcement (OSWER Directive- No 9610-16")
       (October 1993)

CERCLA

       Final Penalty Policy for Sections 302,303,304,311, and 312 of EPCRA and Section 103
       of CERCLA (6/13/90)
       General FIFRA Enforcement Response Policy (7/2/90)
       FIFRA Section 7(c) ERP (2/10/86)
       Enforcement Response Policy for the Federal Insecticide, Fungicide and Rodenticide Act:
       Good Laboratory Practice (GLP) Regulations (9/30/91)

Attachments

cc:     (w/attachments)
       OECA Office Directors
       ORE Division Directors
       OSRE Division Directors
       Regional Counsels, Regions I - }£
       Director, Office of Environmental Stewardship, Region I
       Director, Division of Enforcement and Compliance Assurance, Region II
       Director, Compliance Assurance & Enforcement Division, Region VI
       Director, Office of Enforcement, Compliance & Environmental Justice, Region VIII
       Regional Enforcement Coordinators, Regions I - X'
       Chief, EES, DOJ
       Deputy and Assistant Chiefs, EES, DOJ
       CMP Workgroup Members:
             Mike Northridge, OSRE
             Bob Ward, OGC-CCID
             Susan Dax, OCFO/OC/FMD
             Anthony Britten, OPPE
             David Drelich, ORE, WED
             Richard Ackerman, ORE-AED
             Jocelyn Adair, ORE-AED
             Charlie Garlow, ORE- AED
             Robin Lancaster, ORE-TPED
             Ann Pontius, OECA /OPPA
             Gary Secrest, ORE-AED
             Mary Andrews, ORE-RED
                                            100

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                                                                 Paae 10
Nancy Ketcham-Colwill, OGC-ARD
Lone Schmidt, OGC-CCID
Richard Witt, OGC-WD
Robert Friedrich, OGC-IGD
Lynn Johnson, OSWER/OPM/PARMS
David R .Williams, OPPTS
Edie Goldman, Region 1 ORC
Wilkey Sawyer, Region 2 ORC
Judith Katz, Region 3
Leif Palmer, Region 4 ORC
Will Waisner, Region 4
Evan L. Pearson, Region 6
Alma Eaves, Region 7
Kim Muratore, Region 9
                                   101

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          Tuesday
          December 31, 1996
r s

L i
 =  =.
Part V


Environmental

Protection Agency

40 CFR Parts 19 and 27
Civil Monetary Penalty Inflation
Adjustment Rule; Final Rule
           102

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69360  Federal Register / Vol. 61. No. 252 / Tuesday. December 31.  1996 / Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY

40 CFR Parts 19 and 27
[FRL-5671-1]

Civil Monetary Penalty Inflation
Adjustment Rule
AGENCY: Environmental Protection
Agency (EPA).
ACTON: Final rule.	

SUMMARY: The Environmental Protection
Agency ("EPA") is issuing this final
Civil Monetary Penalty Inflation
Adjustment Rule as mandated by the
Debt Collection Improvement Act of
1996 to adjust EPA's civil monetary
penalties ("CMPs") for inflation on a
periodic basis. Prior to this new law.
EPA's penalties had never been adjusted
for inflation. This rule will allow EPA's
penalties to keep pace with inflation
and thereby maintain the deterrent
effect Congress intended when it
originally specified penalties.
  This first mandatory adjustment
increases almost all of EPA's penalty
provisions by ten percent (except for
new penalty provisions enacted into law
in 1996. which are not being increased).
The Agency is required to review its
penalties again at least once every four
years thereafter and to adjust them as
necessary for inflation according to a
specified formula.
EFFECTIVE DATE: January 30.1997.
FOR FURTHER INFORMATION CONTACT:
Steven M. Spiegel. Office of Regulatory
Enforcement. Multimedia Enforcement
Division. Mail Code 2248W. 401M
Street, SW. Washington. D.C. 20460. or
at (703) 308-8507. Further information
may also be requested by electronic mail
(e-mail) to:
spiegeljteven0epamail.epa.gov.
SUPPLEMENTARY INFORMATION: Pursuant
to the Federal Civil Penalties Inflation
Adjustment Act of 1990 (28 U.S.C. 2461
note; Pub. L. 101-410. enacted October
5.1990; 104 Stat 890). as amended by
the Debt Collection Improvement Act of
1996 (31  U.S.C. 3701 note; Public Law
104-134. enacted April 26.1996; 110
Stat 1321). ("DCIA'l each Federal
agency is required to issue regulations
adjusting for inflation the maximum
civil monetary penalties that can be
imposed pursuant to such agency's
statutes. With the  adoption of this rule
implementing these statutes, all
violations which take place after
January 30.1997 will be subject to the
new statutory maximum civil penalty
amounts.
  With the exception of the new penalty
provisions added by the 1996
amendments to the Safe Drinking Water
Act. all of the statutory penalty
provisions administered by EPA are
being increased. All of these increases
are for die maximum allowed, ten
                 	    ^	   _-|_
percent. The affected penalty provisions
and their statutory maximum amounts
are set out in Table 1 of the new 40 CFR
19.4.

  Section 5 of the DCIA sets forth the
formula for adjusting the penalties for
inflation:

  The inflation adjustment described under
section 4 shall be determined by increasing
the maximum CMP or the range of minimum
and maximum CMPs. as applicable, for each
CMP by the cost-of-Uving adjustment. * • *
The term "cost-of-living" adjustment is the
percentage for each CMP by which the
Consumer Price Index (CPQ for the month of
June of the calendar year preceding the
adjustment exceeds the Consumer Price
Index for the month of June of the calendar
year in which the amount of such CMP was
last set or adjusted pursuant to law. Any
increase determined under this amendment
shall be rounded* * V

  However, the DCIA also sets a ten
percent cap on the first adjustment for
inflation. Since EPA's penalties have
never previously been adjusted  for
inflation, this first statutorily required
adjustment will be limited to ten
percent Table A below sets forth each
CMP provision which is being increased
pursuant to die DCIA and die
intermediate calculations performed to
arrive at the adjusted final maximum
penalty contained in the last column
and in today's rule.
                  TABLE A.—SUMMARY OF CIVIL MONETARY PENALTY INFLATION ADJUSTMENT CALCULATIONS
U.S. Coda
* * * • — —
cnauon
7 U S C 1361 Ml
7U.S.C. 1361 (2) _
46110?* ^£ 4 C

15 U.S.C. Zo47(a) ..
91 U.S.C.
3802(axi).
31 U.S.C.
3802(aX2}.
33 U.S.C. 1319(d) -..
33 U.S.C.
«T9(9)(2}(A).
Civil monetary penalty
description
FEDERAL INSECTICIDE FUN-
GICIDE. & ROOENTICIOE ACT
CIVIL PENALTY—GENERAL—
COMMERCIAL APPLICATORS.
ETC.
FEDERAL INSECTICIDE. FUN-
GICIDE. & RODENT1CIOE ACT
CIVIL PENALTY— PRIVATE AP-
PLICATORS— 1ST & SUBSE-
QUENT OFFENSES OR VIOLA-
TIONS.
TftYM* Ql !RCTAKIC£S COMTROL
ACT CIVIL PENALTY.
A CBCCTSVf UA7ABD FAJPR-
GENCY RESPONSE ACT CIVIL
PENALTY.
BD/"\f*D AU iTDAI m ft\Jtl RFU»
EDIES ACT/VIOLATION IN-
VOLVING FALSE CLAIM.
PROGRAM FRAUD CIVIL REM-
EDIES ACT/VIOLATION IN-
VOLVING FALSE STATEMENT.
CLEAN WATER ACT VIOLATION/
CIVIL JUDICIAL PENALTY.
CLEAN WATER ACT VIOLATION/
ADMINISTRATIVE PENALTY
PER VIOLATION AND MAXI-
MUM.
Yearpen-
. ally
amount
.was last
' set by
law
1978
1978
•
1976
1986
19£6
1986
1987
1987
Maximum pen-
alty amount set
by law as of
10/23/96
55.000
500/1.000 	
25 000
5000
5000
5.000 	
25.000 	
10.000/25.000 ..
Inflation factor cal*
eulation'
456.7/195 3
456.7/195.3
456.7/170.1
456 7/327 9
456 7/327 9
456.7/327.9
456.7/340.1
456.7/340.1
Maximum pen-
alty increase
amount after
P.L. 101-410
rounding1
$7000
700/1,000 ™_
40 000 	 _.
7iYin
jnnn
2.000 	
10.000 —._._.
3.000/10.000 __
Maximum pen-
any amount
after increase
and P.L 101-
410 rounding
J 12.000 _
1.200/2.000 —
65000 	
7000
7000
7000
• fvf**** *•— '- n • *••• " r™"
35.000 	 '.
13.00005.000 ..
Maximum pen-
ally amount
anerP.I_I01-
410 rounding
and 10% limit
S5.500
550/1.100
27.500
5.500
5.500
5.500
27.500
11,000/27.500
                                                            103

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 Federal  Register / Vol.  61. No. 252 / Tuesday. December 31. 1996 / Rules and Regulations  69361
WfRfffB&iBi^^f^^R^^^^^^^R^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^i^BBi^^^^^^B^BfBBRB^^^^^^^^^^^^^^^^BBt^iii^nBfRfi^^^^^

     TABLE A.—SUMMARY oe CIVIL MONETARY PENALTY INFLATION ADJUSTMENT CALCULATIONS—Continued
U.S. Cod*
citation
33 U.S.C.
1319(8X2X3).


33 U.S.C.
1321(6X9X8X0-


33 UJ5.C.
1321(6X6X8X1).


33 U.S.C.
1321(bX7XA).



33 U.S.C.
1321(6X7X8).

33 USC
*F*f V»1V*V*
1321(6X7) «.

33 U.S.C.
1321(6X7X0).



33 U.S.C. 14146(d)


33 U.S.C. 1415(a) -



42 U.S.C. 3000-
3(6).

42 U.S.C. 300g-3(C)


42 U.S.C. 300g-
3(g)(3)(A).

42 U.S.C. 300g-
3(g)(3XB).


42 U.S.C. 300h-
2(6X1).


42 U.S.C. 300h-
2(c)(1).



42 U.S.C. 300h-
2(eX2).



42 U.S.C. 300h-
3W).

42 U.S.C. 300O-
3(c)(2).

42 U.S.C. 300i-1(6)



42 U.S.C. 300XeX2)


42 U.S.C. 300H(e)

CM monetary pena-y
description
CLEAN WATER ACT VIOLATION/
ADMINISTRATIVE PENALTY
PER VIOLATION AND MAXI-
MUM.
CLEAN WATER ACT VIOLATION/
ADMIN PENALTY OF SEC
311(6X3) & 0 PER VIOLATION
AND MAXIMUM.
CLEAN WATER ACT VIOLATION/
ADMIN PENALTY OF SEC
311(6X3) * (D PER VIOLATION
AND MAXIMUM.
CLEAN WATER ACT VIOLATION/
CIVIL JUDICIAL PENALTY OF
SEC 311(6X3)-PER VIOLA-
TION PER DAY OR PER BAR-
REL OR UNIT.
CLEAN WATER ACT VIOLATION/
CIVIL JUDICIAL PENALTY OF
SEC311(c)4(eX1X8).
CLEAN WATER ACT VIOLATION/
CIVIL JUDICIAL PENALTY OF
SEC 3110.
CLEAN WATER ACT VIOLATION/
MINIMUM CIVIL JUDICIAL
PENALTY OF SEC 311(6X3)—
PER VIOLATION OR PER BAR-
RBJUNIT.
MARINE PROTECTION. RE-
SEARCH AND SANCTUARIES
ACT VIOL SEC 104b(d).
MARINE PROTECTION. RE-
SEARCH AND SANCTUARIES
ACT VIOLATIONS— FIRST &
SUBSEQUENT VIOLATIONS.
SAFE DRINKING WATER ACT/
CML JUDICIAL PENALTY OF
SEC 1414(6).
SAFE DRINKING WATER ACT/
CIVIL JUDICIAL PENALTY OF
SEC 1414(e).
SAFE DRINKING WATER ACT/
CIVIL JUDICIAL PENALTY OF
SEC. 1414
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69362
Federal Register / Vol. 61. No. 252 / Tuesday. December 31, 1996 / Rules and Regulations
           TABLE A.—SUMMARY OF CIVIL MONETARY PENALTY INFLATION ADJUSTMENT CALCULATIONS—Continued
U.S. Code
citation
42 U.S.C. 300J-
23(d).
42U.S.C.
6928(aX3).
42U.S.C.6928(C) _
42 U.S.C. 6928(g) -
42 U.S.C.
692801X2).
42 U.S.C. 6934{e) _
42 U.S.C. 6973(0) _
42 U.S.C.
6991e(aX3).
42 U.S.C.
6991e(d)(1).
42 U.S.C. 6931e(d)
P).
42 U.S.C. 6992(0)
m-
42 U.S.C. 6992d(a)
w.
42 U.S.C. 6992d(d)
42 U.S.C. 7413(6) _
42U.S.C.
7413(dX1).
42 U.S.C.
7413(dX3).
« U.S.C. 7S24(a) „
42 U.S.C. 7524(a) „
42 U.S.C. 7S24(e) _
«2U.S.C.7545(d) ..
42 U.S.C.
9604
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          Federal Register / Vol. 61. No. 252  / Tuesday. December 31. 1996  / Rules and Regulations   69363

              TABLE A.—SUMMARY OF CIVIL MONETARY PENALTY INFLATION ADJUSTMENT CALCULATIONS—Continued
U.S. Cod*
citation
*
cubfioni
456.7/327.9


456.7/327.9

456.7/327.9


456.7/327.9



456.7/327.9




458.7/327.9



456.7/327.9



456.7/327.9



456.7/327.9


Maximum pen-
alty increase
amount after
Pi. 101-410
rounding1
^nonn


30000

10000


30.000 	 '_


"
10.000 	




30000



10.000 	



4.000 	



10.000 	


Maximum pen-
alty amoun
after increase
and P.L. 101-
4iOrouncrg
^,wlJV


27.500



11.000



27,'SO


  < The Inflation factor it the result of dividing the June 1995 CPI by the CPI for June of the year the penally
  z The penalties must be rounded after me inflation adjustment pursuant to Public Law 101-410 Sec. SA.
                                      was last set or adjusted.
   Future adjustments also be made in
 accordance with the statutory formula.
 Since today's inflation adjustments are
 being made in December 1996, the next
 scheduled adjustment will cover
 inflation from June 1996 to June of the
 year in which the next adjustment is
 made. The DCIA requires that penalties
 be adjusted for inflation at least once
 every four years.
 Procedural Requirements
 /. Administrative Procedure Act
  In accordance with 5 U.S.C. 553(b).
 the Administrative Procedure Act
 ("APA"). EPA generally publishes a rule
 in a proposed form and solicits public
 comment on it before issuing the rule in
 final/However. 5 U.S.C. 553(b)(3)(B), of
 the APA provides an exception to the
 public comment requirement if the
 agency finds good cause to omit
 advance notice and public participation.
 Good cause is shown when public
 comment is "impracticable,
 unnecessary, or contrary to the public
 interest".
  Accordingly, EPA finds that providing
an opportunity for public  comment
 prior to publication of this rule is not
necessary because EPA is  carrying out a
ministerial, non-discretionary duty
specified in an Act of Congress. This
rule incorporates requirements
specifically set forth in the DCIA
requiring EPA to issue a regulation
implementing inflation adjustments for
alHts civil penalty provisions by
October 23.1996. The formula for the
amount of the penalty adjustment is
prescribed by Congress in the DCIA as
well. Prior notice and opportunity to
comment are therefore unnecessary in
this case because these changes are not
subject to the exercise of discretion by
EPA. These technical changes, required
by law. do not substantively alter the
existing regulatory framework nor in
any way affect the terms under which
civil penalties are assessed by EPA.

II. Small Business Regulatory
Enforcement Fairness Act

  Under 5 U.S.C. 801(a)(l)(A). as added
by the Small Business Regulatory
Enforcement Fairness Act of 1996
("SBREFA"). EPA submitted a report
containing this rule and other required
information to the U.S. Senate, the U.S1
House of Representatives and the
Comptroller General of the United
States prior to publication of the rule in
today's Federal Register. This rule is a
not a "major rule" as defined bv 5
U.S.C. 804(a).

III. Executive Order 12865-Regulatory
Review

  Under Executive Order 12866. (58 FR
51735 (October 4.1993)). the Agency
must determine whether the regulatory
action is "significant" and therefore
subject to Office of Management and
Budget ("OMB") review and the
requirements of the Executive Order.
The  Executive Order defines
"significant regulatory action" as one
that  is likely to result in a rule that may:
  (1) have an annual effect on the economy
of S100 million or more or adversely affect
in a material way the economy, a sector of
the economy, productivity, competition, jobs.
the environment, public health or safety, or
State, local, or tribal governments or
communities?
  (2) create a serious inconsistency or
otherwise interfere with an action taken or
planned by another agency:
  (3) materially alter the budgetary impact of
entitlements, grants, user fees, or loan
programs or the rights and obligations of
recipients thereof: or
  (4) raise novel legal or policy issues arising
out of legal mandates, the President's
priorities, or the principles set forth in the
Executive Order.
                                                              106

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69364   Federal Register
                      Tuesday. December 31. 1996
     Rules and Regulations
  EPA has determined that this rule is
not a "significant regulatory action"
under the terms of Executive Order
12866 and is therefore not subject to
OMB review.
IV. Unfunded Mandates Reform Act
  Title n of the Unfunded Mandates
Reform Act of 1995 ("UMRA"). Public
Law 104-4. establishes requirements for
Federal agencies to assess the effects of
certain regulatory actions on State.
local, and tribal governments and the
private sector. Under sections 201.202
and 205 of the UMRA, EPA generally
must assess effects and prepare a
written statement of economic and
regulatory alternatives analyses for
proposed and final rules with Federal
mandates, as defined by the UMRA. that
may result in expenditures to State.
local, and tribal governments, in the
aggregate, or to the private sector, of
$100 million or more in any one year.
  UMRA Section 201 excepts agencies
from assessing effects on State, local or
tribal governments or the private sector
of rules that incorporate requirements
specifically set forth in law. Since this
rule incorporates requirements
specifically set forth in the DCIA. EPA
is not required to assess its regulatory
effects under Section 201. Further, the
section 202 and 205 requirements do
not apply to today's action because they
apply only to- rules for which a general
notice of proposed rulemaking is
published, and such notice was not
published for this rule since it was not
required based on the finding of good
cause contained in Section I above.
Additionally, today's action contains no
Federal mandates for State, local or
tribal governments or for the private
sector because it does not impose any
enforceable duties on these entities.
  In addition, even if the assessment
requirements of UMRA Title n
otherwise applied to this rule, the
requirements of section 203 of UMRA
(requiring EPA to develop a small
government agency plan before EPA
establishes any regulatory requirements
that may significantly or uniquely affect
small governments, including tribal
governments) would not apply here.
This rule contains no regulatory
           requirements that might significantly or
           uniquely affect small governments
           because the prescribed inflation
           adjustments do not change a small
           government's regulatory obligations.
           Additionally, this rule will have a
           similar effect on all individuals and
           entities subject to civil monetary
           penalties.

           V. Regulatory Flexibility Act
             In accordance with 5 U.S.C. 603. the
           Agency has determined that the
           regulation being issued today is not
           subject to the Regulatory Flexibility Act
           C'RFA"). which generally requires an
           agency to conduct a regulatory
           flexibility analysis of any significant
           impact the rule will have on a
           substantial number of small entities. By
           its terms, the RFA applies only to rules
           subject to notice-and-comment
           rulemaking requirements under the
           APA or any other statute. Today's  rule
           is not subject to notice and comment
           requirements under the APA or any
           other statute because it is exempted. As
           discussed in Section I, while the rule is
           subject to the APA. the Agency has
           invoked the "good cause" exemption
           from the APA notice and comment
           requirements.
             The Agency nonetheless has assessed
           die potential oT this rule to adversely
           impact small entities. This rule contains
           no regulatory requirements that might
           significantly or uniquely affect small
           entities because the prescribed inflation
           adjustments have similar effect on all
           entities subject to civil monetary
           penalties and does not substantively
           •alter die existing regulatory framework.
           VI. Paperwork Reduction Act
             This action contains no reporting or
           record keeping requirements for any
           non-federal persons or entities and
           consequently.is not subject to the
           Paperwork Reduction Act. 44 U.S.C.
           3501etseq.
           List of Subjects
           40CFRPanl9
             Environmental protection.
           Administrative practice and procedure.
           Penalties.
 40CFRPart27

  Administrative practice and
 procedure. Assessments. False claims.
 False statements. Penalties.
  Dated: December 20.1996.
 Carol M. Browner.
 Administrator.
  For the reasons set out in the preamble.
 title 40. chapter 1 of the Code of Federal
 Regulations is amended bv adding a new part
 19 as follows:         "            *

  1. By adding a new pan 19 to read as
 follows:

 PART 19—ADJUSTMENT OF CIVIL
 MONETARY PENALTIES FOR
 INFLATION

 Ste.
 19.1  Applicability.
 19.2  Effective Date.
 19.3  [Reserved].
 19.4  Penalty Adjustment and Table.
  Authority: Pub. 1_ 101-410.104 Stat. 890.
 28 U.S.C. 2461 note: Pub. I_ 104-134.110
 Stat. 1321,31 U.S.C. 3701 note.

 PART 19—ADJUSTMENT OF CIVIL
 MONETARY PENALTIES FOR
 INFLATION

 §19.1  Applicability.

  This part applies to each statutory
 provision under the laws administered
by die Environmental Protection Agency
concerning the maximum civil
monetary penalty which may be
assessed in either civil judicial or
administrative proceedings.

§19.2 Effective DaU.

  The increased penalty amounts set
forth in this rule apply to all violations
under the applicable statutes and
regulations which occur after January
30.1997.

§19.3  [Reserved]-

§ 19.4  Penalty Adjustment and Table.

  The adjusted statutory penalty
provisions and their maximum
applicable amounts are set out in Table
 1. The last column in the table provides
the newly effective maximum penalty
amounts.
                  TABLE 1 OF SECTION 19.4.—CML MONETARY PENALTY INFLATION ADJUSTMENTS
     U.S. Code citation
                     Civil monetary penalty description
                      New maximum
                      penalty amount
7 U.S.C. 138

7 U.S.C. 136(2)

.15 U.S.C. 2615 	^
Mi U.O.C. ^bA^a) ....~
31 U.S.C. 3802(a)(1)	
                           FEDERAL INSECTICIDE. FUNGICIDE. & RODENTICIDE ACT CIVIL PENALTY— S5.500
                                 IRAL—COMMERCIAL APPLICATORS. ETC.
                                               .FUNGICIDE. 4 RODE
                                                      SENALTY-PRI-
FEDERAL	       	
  VATE /irn irnTorrTTTrrrtT iwriprnrniirrrT OFFENSES OR VIOLATIONS.
           ANCES CONTROL ACT CIVil
ASBESTOS HAZARD EMERGENCY RESPONSE ACT CIVIL i
PROGRAM FRAUD CIVIL REMEDIES ACT/VIOLATION INVOLVING FALSE CLAl
                    550/1.000

                    27.500
                    5.500
                                                        107

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         Federal Register / Vol.  61. No. 252 / Tuesday.  December 31.  1996 / Rules and Regulations  69365
            TABLE 1 OF SECTION 19.4.—CML MONETARY PENALTY INFLATION ADJUSTMENTS—Continued
      U.S. Code citation
                                              CM monetary penalty description
                                                                                               New maxmum
                                                                                               penalty amount
31 U.S.C. 3802(a)(2)......~	

33 U.S.C. 1319(d)	
33 U.S.C. 1319{g){2)(A)	

33 U.S.C. 1319(g)(2)(B) .._

33 U.S.C. 1321(b)(6)(B)(l)

33 U.S.C. 1321(b)(6)(B)(ii)	

33 U.S.C. 1321(b)(7)(A)	

33 U.S.C. 1321(b)(7)(B)	

33 U.S.C. 1321(b)(7)(C)	
33 U.S.C. 1321(b)(7)(D)	

33 U.S.C. 1414b(d)	
33 U.S.C. 1415(a)	

42 U.S.C. 300g-3(b)	
42 U.S.C. 300g-3(c) 	
42 U.S.C. 300g-3(g)(3)(A)	
42 U.S.C. 300g-3(g)(3)(B)	

42 U.S.C. 300h-2{b)(1)	

42 U.S.C. 300h-2(c)(1)	

42 U.S.C. 300h-2(c)(2)	

42 U.S.C. 300h-3(c)(1)	
42 U.S.C. 300h-3(c)(2)	
42 U.S.C. 3001-1 (b)	
42 U.S.C. 300j(e)(2)
42 U.S.C..300j-*(c) 	
42 U.S.C. 300j-23(d)		
42 U.S.C. 6928(a)(3)	

42 U.S.C. 6928(c) 	

42 U.S.C. 6928{g)	
42 U.S.C. 6928(h){2)		
42 U.S.C. 6934(e) 	
42 U.S.C. 6973{b)	
42 U.S.C. 6991e(a)(3)	
42 U.S.C. 6991e(d)(1)	
42 U.S.C. 6991e(d)(2)	
42 U.S.C. 6992d(a)(2) —..	

42 U.S.C. 6992d(a)(4)	
42 U.S.C. 6992d(d)	
42 U.S.C. 7413(b) 	

42 U.S.C. 7413(d)(1)	

42 U.S.C. 7413(d)(3)	.....

42 U.S.C. 7524(a)	

42 U.S.C. 7524(a) 	

42 U.S C. 7524{c) 	

42 U.S.C. 7545(d) 	
42 U.S.C. 9604(e)(5)(B)	
                           PROGRAM FRAUD CIVIL REMEDIES ACT/VIOLATION INVOLVING FALSE STATE-  5.500
                            MENT.                                                           I
                           CLEAN WATER ACT VIOLATION/CIVIL JUDICIAL PENALTY	  27.500
                           CLEAN WATER ACT VIOLATION/ADMINISTRATIVE PENALTY  PER VIOLATION ] 11.000/27.500
                            AND MAXIMUM.
                           CLEAN WATER ACT VIOLATION/ADMINISTRATIVE PENALTY  PER VIOLATION  11.000/137.500
                            AND MAXIMUM.
                           CLEAN WATER ACT VIOLATION/ADMIN PENALTY OF SEC 311 (B)(3)&(J) PER VIO-  11,000/2/500
                            LATION AND MAXIMUM.
                                 WATER ACT VIOLATION/AOMIN PENALTY OF SEC 311 (B)(3)&(J) PER VIO-  11 .OJJ6/137.500
                                ION AND MAXIMUM.
                                 WATER ACT VIOLATION/CIVIL JUDICIAL PENALTY OF SEC 311(b)(3)—  rf.OOO or 1.100 per
                            PER ^OLATION PER DAY OR PER BARREL OR UNfT.                    /  barrel or unit
                           CLEAN  WfATER  ACT  VIOLATION/CIVIL  JUDICIAL  PENALTY  OF   SE2  27.500
' VIOLATION/CIVIL JUDICIAL PENALTY OF SEC 311(j) ..../..	
                                                                                            - 27.500
                                                                           3ROUND INJECTION  27.500

                                                                     PER VIOLATION AND MAX!- ; 11.000/137.500

                                                                     PER VIOLATION AND MAXI- . 11.000
                           JECTION WELL 	
                                I INJECTION WELI	i
                                 SYSTEM/CIVIL JUOI-
                                                                                             5.500
                                                                                             11.000
                                                                                             22.000/55.CCO
CLEANWA'
CLEAN WATER>\CT VIOLATION/MINIMUM CML JUDICIAL PENALTY Of SEC  11.000 or 3.300
  311 (b)(3)—PER VIOLATION OR PER BARREL/UNIT.                /        per barrel or unit
MARINE PROTECTK5N. RESEARCH & SANCTUARIES ACT VIOL SEC td4b(d) ..	  660
MARINE  PROTECTION\RESEARCH AND SANCTUARIES ACT  VIOLATIONS—  55.000/137.500
  FIRST AND SUBSEQUENT VIOLATIONS.
SAFE DRINKING WATER AOTCML JUDICIAL PENALTY OF SEC/f414(b)	  27.500
SAFE DRINKING WATER ACT>KML JUDICIAL PENALTY OF SEC 1414(c)	  27.500
SAFE DRINKING WATER ACT/CML JUDICIAL PENALTY OF SEC. 1414(g)(3Xa) _...  27.500
SAFE DRINKING WATER ACT/MAXIMUM ADMINISTRATIVE PENALTY PER SEC.  5.500
  1414(gJ(3XB).
CML JUDICIAL PENALTY/VIOLATIONS\OF REQ!
  CONTROL (UIC).
CML ADMIN PENALTY/VIOLATIONS  OF UftS^RB
  MUM.
CML ADMIN PENALTY/VIOLATIONS  OF UIC
  MUM.
VIOLATION/OPERATION OF NEW UNDERGROUND
WILLFUL VIOLATION/OPERATION OF NEW UNDERGRl
ATTEMPTING TO OR TAMPERING WITH PUBLIC WA
  CIAL PENALTY.
FAILURE TO COMPLY W/ORDER J3SUED UNDER SEC. 1441&M)  	I 2.750
REFUSAL TO COMPLY WITH REQS. OF SEC. 1445(a) OR (b) J\-	- : 27.500
VIOLATIONS/SECTION 1463(bV^FIRST OFFENSE/REPEAT OFFENSE	i 5.500/55.000
RESOURCE CONSERVATION  & RECOVERY ACT/VIOLATION SUBTITLE C AS- • 27.500
  SESSED PER.ORDER. /                                 \         I
RES. CONS.  4 REC.yfcT/CONTINUED NONCOMPL1ANCE OF  COMPLIANCE I 27.500
  ORDER.
RESOURCE CONSERVATION 4 RECOVERY ACT/VIOLATION SUBTITLE C ...V..... « 27.500
RES. CONS. 4 RBZ. ACT/NONCOMPUANCE OF CORRECTIVE ACTION ORDERV. : 27.500
RES. CONS. 4 REC. ACT/NONCOMPUANCE WITH SECTION 3013 ORDER  	..SsJ 5.500
RES. CONS. 4/REC. ACT/VIOLATIONS OF ADMINISTRATIVE ORDER		 >6.500
RES. CONS/4 REC. ACT/NONCOMPUANCE WITH UST ADMINISTRATIVE ORDER ! 2
RES. CONS. 4 REC. ACT/FAILURE TO NOTIFY OR SUBMIT FALSE INFO 	'11.0
VIOLATIONS OF SPECIFIED UST REGULATORY REQUIREMENTS 	i 11.0
NONCCMPLIANCE W/MEDICAL WASTE TRACKING ACT ASSESSED THRU ADMIN ! 27.500
  OJKDER.                                                          i
     OMPL1ANCE  W/MEDICAL  WASTE TRACKING  ACT  ADMINISTRATE' 27.500
  ORDER.
VIOLATIONS OF MEDICAL WASTE TRACKING ACT—JUDICIAL PENALTIES	  27.500
CLEAN AIR ACT/VIOLATION/OWNERS  4 OPS OF STATIONARY AIR POLLUTION  27.500
  SOURCES—JUDICIAL PENALTIES.
CLEAN AIR ACT/VIOLATION/OWNERS 4 OPS OF STATIONARY AIR POLLUTION  27.500/220.000
  SOURCES—ADMINISTRATM; PENALTIES PER VIOLATION 4 MAX.
CLEAN AIR ACT/MINOR VIOLATIONS/STATIONARY AIR POLLUTION SOURCES— 5.500
  FIELD CITATIONS.
TAMPERING OR MANUFACTURE/SALE OF DEFEAT DEVICES IN VIOLATION OF 2.750
  7522(a)(3)(A) OR (a)(3XB)-BY PERSONS.
VIOLATION OF 7522(a)(3)(A) OR (a)(3)(B)—BY MANUFACTURERS OR DEALERS: 27.500
  ALL VIOLATIONS OF 7522(a)(1). (2), (4). & (5) BY ANYONE.
ADMINISTRATIVE PENALTIES AS SET IN 7524(a) 4 (7545(d) WJTH A MAXIMUM 220.000
  ADMINISTRATE PENALTY.
VIOLATIONS OF FUELS REGULATIONS			 27.500
SUPERFUND AMEND.  4  REAUTHORIZATION ACT/NONCOMPLIANCE W/RE- 27.500
  QUEST FOR INFO OR ACCESS.
                                                        108

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69366   Federal Register / Vol.  61. No. 252 / Tuesday. December 31. 1996 / Rules and  Regulations

             TABLE 1 OF SECTION 19.4.—CML MONETARY PENALTY INFLATION AojusTMENrs-Continued
      U.S. Code citation
                     Civil monetary penalty description
                      New maximum
                      penalty amount
42 U.S.C. 9606(0)	

42 U.S.C. 9609(a) & (b)	

42 U.S.C. 9609(b)	
42 U.S.C. 9609(c) 		
42 U.S.C. 9609(C) 	

42 U.S.C. 11045(a) & (b)(1>. (2)
  &(3).
42 U.S.C. 11045(0) & (2)(3) 	

42 U.S.C. 11045(0(1)	

42 U.S.C. 11045(0(2)	

42 U.S.C. 11045(d) & (2)(3)	
  JPERFUND/WORK   NOT   PERFORMED    W/1MMINENT.   SUBSTANTIAU

SUPERFTWO/ApMIN. PENALTY VIOLATIONS UNDER 42 U.S.C. SECT. 9603 9608
  OR 9622.   ^»>
SUPERFUND/ADMINTPENALTY VIOLATIONS—SUBSEQUENT
SUPERFUND/CIVtL JUDICteb^ENALTY/VIOLATIONS OF SECT. 96Q3-S608 9622
SUPERFUNO/CML JUDICIAL PENALTY/SUBSEQUENT VIOLATIONS OF SECT
  9603.9608.9622.             ^                ^
EMERGENCY PLANNING AND COMMUNnTHygHKfc-KNOW ACT CLASS I & II
  ADMINISTRATIVE AND CIVIL PENALTIP"   ^^
EPCRA CLASS I &  II ADMINISTRATiye-ffND CIVIL PeNALTlES—SUBSEQUENT
  VIOLATIONS.
EPCRA CIVIL AND ADMINJSWAT1VE REPORTING PENALTIES FbR-AflOLATIONS
  OF SECTIONS 1102*0R11023.
EPCRA CIVIL ANer-ADMINISTRATIVE REPORTING PENALTIES FOR VIOLATi
  OF SECBCNS 11021 OR 11043(b).
              .OUS TRADE SECRET CLAIMS—CML  AND ADMINISTRATIVE
   'ENALTtES.
                    27.500

                    27.500

                    S2.500
                    27.500
                    82.500

                    27.500

                    82:500

                    27.500

                    11.0CO

                    27.500
 PART 27—[AMENDED]

   2. The authority citation for part 27 is
 revised to read as follows:
   Authority: 31 U.S.C. 3801-3812: Pub. U
 101-410.104 Star. 890. 28 U.S.C 2461 note:
 Pub. L 104-134. 110 Stat. 1321.31 U.S.C.
 3701 note.
   4. Section 27.3 is amended by revising
 paragraphs (a)(l) and (b)(l) to read as
 follows:
 §27.3  Basis for civil penalties and
 assessments.
   (a) Claims. (1) Except as provided in
 paragraph (c) of this section, any person
 who makes a claim that the person
 knows or has reason to know—
   (i) Is false, fictitious, or fraudulent:
   (ii) Includes or is supported by any
 written statement which asserts a
 material fact which is false, fictitious, or
 fraudulent:
   (iii) Includes, or is supported by. any
 written statement that—
             (A) Omits a material fact:
             (B) Is false, fictitious, or fraudulent as
           a result of such omission: and
             (C) Is a statement in which the person
           making such statement has a duty to
           include such material fact; or
             (iv) Is for payment for the provision
           of property or services which the person
           has not provided as claimed, shall be
           subject, in addition to any other remedy
           that may be prescribed by law, to a civil
           penalty of not more than $5.500' for
           each such claim.
           •     m     *     *     *

             (b) Statements. (1) Except as provided
           in paragraph (c) of this section, any
           .person who makes a written statement
           "that—
             1 As adjusted In accordance with the Federal
           Civil Penalties Inflation Adjustment Act of 1990
           Pub. L. 101-410.104 Stat. 890). as amended by the
           Debt Collection Improvement Act of 1996 (Pub. L.
           104-134.110 Stat. 1321).
  (i) The person knows or has reason to
know—
  (A) Asserts a material fact which is
false, factitious, or fraudulent: or
  (B) Is false, factitious, or fraudulent
because it omits a material fact that the
person making the statement has a duty
to include in such statement: and
  (ii} Contains, or is accompanied by, an
express certification or affirmation of
the truthfulness and accuracy of the
contents of the statement, shall be
subject, in addition to any other remedy
that may be prescribed by law, to a civil
penalty of not more than 55.500: for
each such statement.
m    m    m    *    *

[FR Doc. 96-3297Z Filed 12-30-96:8:45 am]
BILLING CODE tSfO-SO-f
  1 As adjusted In accordance with the Federal
Civil Penalties Inflation Adjus=%nt Act of 1990
(Pub. L. 101-410.104 Scat. S9C). as amended by the
Debt Collection Improvement Ac of 1996 (Pub. L.
104-134. llOStat 1321).
                                                                       109

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          Thursday
          March 20, 1997
n  i
          Part VIII


          Environmental

          Protection Agency

          40 CFR Parts 19 and 27
          Civil Monetary Penalty Inflation
          Adjustment Rule; Final Rule
          110

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 13514    Federal Register / Vol. 62. No.  54 / Thursday. March 20. 1997 / Rules and Regulations
 ENVIRONMENTAL PROTECTION
 AGENCY

 40 CFR Parts 19 and 27
 rFRL-5711-7]

 Civil Monetary Penalty Inflation
 Adjustment Rule
 AGENCY: Environmental Protection
 Agency (EPA).
 ACTION: Corrections To final rule.	

 SUMMARY: This document contains
 corrections to the Civil Monetary
 Penalty Inflation Adjustment Rule, final
 regulations (FRL-5671-1), which were
 published Tuesday. December 31.1996.
 (61 FR 69359). The regulations adjusted
 the Environmental Protection Agency's
 ("EPA'7 civil monetary penalties
 ("CMPs") for inflation as mandated by
 the Debt Collection Improvement Act of
 1996 ("DCIA"). A corrected version of
 Table 1. from 40 CFR 19.4. which now
 lists all but one of the EPA's civil
 monetary penalty authorities, appears
 near the end of this notice.
 EFFECTIVE DATE: January 30.1997.
 FOR FURTHER INFORMATION CONTACT: For
 further information, contact Steven M.
 Spiegel. Office of Regulatory
 Enforcement. Multimedia Enforcement
 Division. Mail Code 2248W. 401 M
 Street, SW. Washington. D.C. 20460. or
 at (703) 308-8507. Further information
 may also be requested by electronic mail
 (e-mail) to:
 spiegel.steven@epamail.epa.gov. The
 December 31,1996 Final Rule and this
 Correction are also available on the
 Office of Enforcement and Compliance
 Assurance's Web page at http//
 www.epa.gov/oeca.
 SUPPLEMENTARY INFORMATION:
 Need For Correction
  As published, the preamble and final
 regulations contain errors which may
 prove misleading and are in need of
 clarification. The changes made through
 these corrections are all technical in
 nature and can be broken down into
 three categories. First, there were five
 instances in which the exact section of
 a statute was not cited correctly in the
 preamble (which errors were repeated in
 the rule). Second, there were two errors
 in the new maxi—um penalty figures.
 Third, there are ccher minor non-
 substantive changes, as well as the
 addition of explanatory information
 which does not affect the original rule.
but provides a more complete and
 understandable document and rule to
the public. The additions concern the
August 1996 amendments to the Safe
Drinking Water Act. which went into
 effect on August 6.1996. For purposes
 of clarity and providing the public with
 one table that lists all of EPA's civil
 penalty authorities, the four new civil
 penalty provisions from the August
 1996 amendments to the Safe Drinking
 Water Act have been added to Table 1
 in Section 19.4 (even though these
 penalty provisions are not subject to
 adjustment for inflation pursuant to the
 DCIA at this time). These additions are
 identified below. Thus the revised Table
 1  of Section 19.4 now provides a list of
 all but one of the applicable statutory
 provisions and maximum civil
 penalties. There is one statutory
 provision which has not yet been
 adjusted. EPA anticipates performing a
 rule-making to adjust 15 U.S.C. 2615, as
 amended by the Residential Lead-Based
 Paint Act of 1992. 42 U.S.C. 4852d, and
 the corresponding regulations in 40 CFR
 Part 745. which were omitted from the
 December 31.1996 rule-making.
 Effect of Correction
   Since all of the corrections are
 technical in nature and do not affect the
 substance of the rule, the original
 effective date of January 30,1997.
 applies to those corrected provisions, as
 well as to the other original provisions
 of the final rule which did not require
 correction. The identified corrections to
 Table A in the preamble correspond to
 the corrections and additions to Table 1
 in Section 19.4. A corrected version of
 Table 1. 40 CFR 19.4, which now lists
 all but one of EPA's civil monetary
 penalty authorities, appears near the
 end of this notice.
    »
•Correction of Publication
   Accordingly, the publication on
 December 31,1996 of the preamble and
 final regulations (FRL-5671-1) which
 were the subject of F.R. Doc. 96-32972.
 are corrected and added to as follows:.
 Preamble [Corrected]
   On page 69360. Table A.—Summary
 of Civil Monetary Penalty Inflation
 Adjustment Calculations, the first
 column, is corrected as follows:
   7 USC 1361(1) is corrected to read 7
 USC 136L(a)(l)—(the number 136, is
 followed by the letter "1". not the
 number one).
   7 USC 1361(2) is corrected to read 7
 USC 1361.(a)(2)—(the number 136. is
 followed by the letter "1", not the
 number one).
   15 USC 2615 is corrected to 15 USC
 2615(a).
   On page 69361, Table A. is corrected
 as follows:
   33 U.S.C. 1321(b)(7)(A) in the first
 column is correct, but the fourth column
 figure of "10.000", is corrected to
"25,000". The sevendi column figure of
15,000. is corrected to 30.000. The
eighth column figure of "11.000" is
corrected to "27.500".
  33 U.S.C. 1321(b)(7)(D) in the first
column is correct, but die eighth
column figure of "11.000" is corrected
to "110,000".
  42 U.S.C. 300i-l(b) is corrected to 42
U.S.C. 300i-l(c).
  On page 69362. for 42 U.S.C. 6934(e),
the fourth column, the figure "25.000"
is corrected to read "5.000".
  On page 69363. 42 U.S.C.
11045(d)(2)(3) is corrected to 42 U.S.C.
11045(d)  (1).
  In the first column, first sentence.
insert "will" so the sentence reads
"Future adjustments also will be made
in accordance with the statutory
formula."

Preamble [Additions]
  Supplementary Information. On page
69360. in the third column, in the first
full sentence, add die phrase ", along
with the new penalty amounts set by the
1996 amendments to die Safe Drinking
Water Act" between die words
"statutory maximum amounts" and "are
set out in Table 1"  • '"
  On page 69361.42 U.S.C. 300g-
3(g)(3)(B), in the first column is correct:
for the second column, change the word
"penalty" to "penalties": third column.
replace "1986" with "1996": fourth
column, replace "5.000" with "5.000/
25.000": replace the figures in the fifth,
sixth and seventh columns with "N/A";
and in the eighth column, replace
"5.500" with "5.000/25.000".
  Following 42 U.S.C. 300g-3(g)(3)(B).
add a new row starting widi 42 U.S.C.
300g-3(g)(3)(C) in the first column; for
the second column. «sert SAFE
DRINKING WATER ACT/ THRESHOLD
REQUIRING CIVIL JUDICIAL ACTION
PER SEC. 1414(g)(3)(B) & (C): third
column, insert "1996": fourth column.
insert "25.000": insert "N/A" for the
figures in the fifth, sixth and seventh
columns: and in die eighth column.
"25.000".
  Following 42 U.S.C. 300h-3(c)2. add
a new row for 42 U.S.C. 300i(b); for the
second column, insert SAFE DRINKING
WATER ACT/ FAILURE TO COMPLY
WITH IMMINENT AND SUBSTANTIAL
ENDANGERMENT ADMIN. ORDER:
third column, insert "1996": fourth
column,  insert "15.000": insert "N/A"
for the figures in the fifth, sixth and
sevendi columns; and in die eighth
column,  insert "15.000".
  Following 42 U.S.C. 300j^}(c). add a
new row for 42 U.S.C. 300j-6(b)(2): for
the second column, insert SAFE
DRINKING WATER ACT/ FAILURE TO
COMPLY WITH ADMIN. ORDER
                                                           111

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FederalReglster / Vol. 6Z. No. 54 / TlninKiay. March  20.  1997 ; Rutes  md Relations    13515
   ISSUED TO FED. FACILITY; third
   column, insert "1996"; fourth column.
   insert "25,000"; insert "N/A" for the
''•  figures in the fifth, sixth and seventh
   columns; and in the eighth column.
   insert "25.000".

   Procedural Requirements

   /. Small Business Regulatory
   Enforcement Fairness Act

     In the December 31,1996 notice. EPA
   found good cause, pursuant to 5 U.S.C.
   553{b)(3)(B) of the Administrative
   Procedure Act ("APA"). that soliciting
   public comment prior to publication of
   the rule was not necessary because EPA
   is carrying out a ministerial, non-
   discretionary duly per direction of an
   Act of Congress. EPA finds that good
   cause continues to apply to this rule.
   and therefore the effective date
                            provisions of the Small Business
                            Regulatory Enforcement Fairness Act of
                            1996 ("SBREFA"). do not govern the
                            effective date of today's action as welL
                            Additionally, the fact that these changes
                            are technical and do not affect the
                            substance of the previously issued rule
                            also meets the "good cause" exception
                            to the effective date requirements of
                            section 553(d) of the Administrative
                            Procedure Act as \velL
                             Under Executive Order 12866 (58 F.R.
                            51735, October 4,1993). this action is
                            not a "significant regulatory action"
                            and. is therefore not subject to review by
                            the Office of Management and Budget.
                            In addition, this action does not impose
                            any enforceable duty or contain any
                            unfunded mandate as described in the
                            Unfunded Mandates Reform Act of 1995
                            (PL. 104-4). Because this action is not
                            subject to notice-and-comment
requirements under the APA or any
other statute, it is not subject to the
provisions of the Regulatorv Flexibility
ActfSU.S.C.eOlerseq.).  *
  Under 5 U.S.C. 801(a)(l)(A). as added
by SBREFA. EPA submitted a resort
containing this rule and other required
information to the U.S. Senate, the U.S.
House of Representatives and the
Comptroller General of the United
States prior to publication of the rule in
today's Federal Register. This rule is a
not a "major rule" as defined bv 5
U.S.C. 804(a).

PART 19 [CORRECTED WITH
ADDITIONS]

  Beginning on page 69364. Table 1 of
Section 19.4—Civil Monetary Penalty
Inflation Adjustments, is corrected to
read as follows:
        TABLE 1 OF SECTION 19.4.—CML MONETARY PENALTY INFLATION ADJUSTMENTS
U.S. Code citation
7U.S.C. 1361.(a)(1) 	

7U.S.C. 13S1.{a)(2) 	


15 U.S.C. 261 5(a) 	 	
15 U.S.C. .2647(3) 	
31 U.S.C. 3802(a)(1) 	

31 U.S.C. 3802(a)(2) 	

33U.S.C. 1319(d) 	
33U.S.C. 1319(g)(2)(A) —

33 U.S.C. 13l9(g)(2)(B) 	

33 U.S.C. 1321(b)(6)(B)(l) ..

33 U.S.C. 1321(b)(6)(B)(B) „

33 U.S.C. 1321(a){7)(A) —

33 U.S.C. 1321{b)(7)(B) —
33 U.S.C. 1321(b)(7)(C) 	
33 U.S.C. 132T(b)(7)(D) —

33 U.S.C. 1414b(d) 	
33 U.S.C. 141 5(a) 	

42 U.S.C. 300g-3(b) 	
42 U.S.C. 300g-3(c) 	
42 U.S.C. 300g-3(g)(3)(A) ..
42 U.S.C. 300g-3(g)(3)(B) ..

42 U.S.C. 300g-3(g)(3)(C)

42 U.S.C. 300h-2(b)(1) 	

42 U.S.C. 300h-2(c)(1) 	

42 U.S.C. 300h-2(c)(2) 	

42 U.S.C. 300h-3(c)(1) 	
42 U.S.C. 300h^3(c)(2) 	

Civil monetary penalty description
FEDERAL INSECTICIDE, FUNGICIDE. & RODENT1CIDE ACT CIVIL PENALTY-
GENERAL— COMMERCIAL APPLICATORS. ETC.
FEDERAL INSECTICIDE. FUNGICIDE. & RODENTICIDE ACT CIVIL PENALTY-
PRIVATE APPLICATORS— FIRST AND SUBSEQUENT OFFENSES OR VIOLA-
TIONS.
TOXIC SUBSTANCES CONTROL ACT CIVIL PENALTY 	
ASBESTOS HAZARD EMERGENCY RESPONSE ACT CIVIL PENALTY 	 	
PROGRAM FRAUD CIVIL REMEDIES ACT/VIOLATION INVOLVING FALSE
CLAIM.
PROGRAM FRAUD CIVIL REMEDIES ACT/VIOLATION INVOLVING FALSE
STATEMENT.
CLEAN WATER ACT VIOLATION/CIVIL JUDICIAL PENALTY 	 . 	
CLEAN WATER ACT VIOLATION/ADMINISTRATIVE PENALTY PER VIOLATION
AND MAXIMUM.
CLEAN WATER ACT VIOLATION/ADMINISTRATIVE PENALTY PER VIOLATION
AND MAXIMUM. *
CLEAN WATER ACf-VlOLATlON/AOMIN PENALTY OF SEC 311(b)(3)4(D PER
VIOLATION AND MAXIMUM.
CLEAN WATER ACT VIOLATION/AOMIN 'PENALTY OF SEC 311(b)(3)4Q) PER
VIOLATION AND MAXIMUM.
CLEAN WATER ACT VIOLATION/CIVIL JUDICIAL PENALTY OF SEC 311(b)(3)—
PER VIOLATION PER DAY OR PER BARREL OR UNIT.
CLEAN WATER ACT VIOLATION/CIVIL JUDICIAL PENALTY OF SEC
CLEAN WATER ACT VIOLATION/CIVIL JUDICIAL PENALTY OF SEC 31 1(j) 	
CLEAN WATER ACT VIOLATION/MINIMUM CIVIL JUDICIAL PENALTY OF SEC
311{b)(3>— PER VIOLATION OR PER BARREL/UNIT.
MARINE PROTECTION. RESEARCH & SANCTUARIES ACT VIOL SEC 104b(d) ...
MARINE PROTECTION RESEARCH AND SANCTUARIES ACT VIOLATIONS-
FIRST & SUBSEQUENT VIOLATIONS.
SAFE DRINKING WATER ACT/CIVIL JUDICIAL PENALTY OF SEC 1414(b) 	
SAFE DRINKING WATER ACT/CIVIL JUDICIAL PENALTY OF SEC 1414(c) 	
SAFE DRINKING WATER ACT/CIVIL JUDICIAL PENALTY OF SEC 1414{g)(3)(a) _
SAFE DRINKING WATER ACT/MAXIMUM ADMINISTRATIVE PENALTIES PER
SEC 1414(g)(3)(B).
SAFE DRINKING WATER ACT/THRESHOLD REQUIRING CML JUDICIAL AC-
' TION PER SEC 1414(g)(3)(C).
SDWA/CIVIL JUDICIAL PENALTY/VIOLATIONS OF REQS— UNDERGROUND IN-
JECTION CONTROL (UIC).
SDWA/CIVIL ADMIN PENALTY/VIOLATIONS OF UIC REQS— PER VIOLATION
AND MAXIMUM.
SDWA/CIVIL ADMIN PENALTY/VIOLATIONS OF UIC REQS— PER VIOLATION
AND MAXIMUM. •
SDWA/VIOLATION/OPERATION OF NEW UNDERGROUND INJECTION WELL ....
SDWA/WILLFUL VIOLATION/OPERATION OF NEW UNDERGROUND INJECTION
WELL.
New maximum penalty
amount
55,500.

S5SO/S1.CCO.


527.500.
55.500.
55.500.

S5.5CO.

S27.SCO.
S11.OOaS27.5CO.

S11.00C/S-.37.5CO.
-
511.000/527.500.

S11.00C/S137.5DO.

S27,£COcrS1.lCOs«r bar-
rel er unit
527,500.
S27.5CO.
51 10.000 or 53,200 per
barrel cr unit
5660.
S55.0GO/S137.5CO.

527,500.
527.500.
527.500.
55.000/525.000.

525.000.

527.500.

S11.0CO/S137.500.

.55.500/5137.500.

S5.5CO. '
511.000.

                                             112

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13516    Federal Register / Vol. 62. No. 54 / Thursday. March 20. 1997 / Rules and Regulations



           TABLE 1 OF SECTION 19.4.—CML MONETARY PENALTY INFLATION ADJUSTMENTS—Continued
U.S. Code citation
42 U.S.C. 300i(b) 	
42 U S C 300i-1(e) 	
42 U S C 300j(e)(2)
42 U.S.C. 300j-«(c) — 	
42 U.S.C. 300J-6(b)(2) 	
42 U S C 300j-23(d) 	
42 U.S.C. 6928(a)(3) 	
42 U.S.C. 6928(6) _ 	
42 U.S.C. 6928(g) 	
42 U.S.C. 6928(h)(2) 	
42 U S C 6934(e) 	
42 U.S.C. 6973(6) 	
42 U.S.C. 6991e(a)(3) ........
42 U.S.C. 6991e(dX1) 	
42 U.S.C. 6991e(d){2) 	
42 U.S.C. 6992d(a)(2) 	
42 U.S.C. 6992d(a)(4) 	
42 U.S.C. 6992d(d) 	
42 U S C 741 3(b) 	
42 USC 7413(d)(1) 	
42 U.S.C. 7413(d){3) 	
42 U.S.C. 7524(a) 	
42 U.S.C. 7524(a) 	
42 U.S.C. 7524(c) 	
42 U.S.C. 7545(d) 	 	
42 U.S.C. 9604(e)(5)(B) . —
42 U S C 9606(b)(1) 	
42 U.S.C. 9609 (a) & (b) ....
42 U.S.C. 9609(b) 	
42 U.S.C. 9609{c) 	
42 U.S.C. 9609(c) 	
42 U.S.C. 11045 (a) & (b)
' (1), (2) & (3).
42U.S.C. 11045(b){2)&
(3).
42U.S.C. 11045(C)(1) 	
42 U.S.C. 11045(C)(2) 	
42 U.S.C. 11045(d)(1) 	
Civil monetary penalty description
SDWA/FAILURE TO COMPLY WITH IMMINENT AND SUBSTANTIAL
ENDANGERMENT ORDER.
SDWA/ATTEMPTING TO OR TAMPERING WITH PUBLIC WATER SYSTEM/CIVIL
JUDICIAL PENALTY.
SDWA/FAILURE TO COMPLY W/ORDER ISSUED UNDER SEC. 1441(c)(1) 	
SDWA/REFUSAL TO COMPLY WITH REQS. OF SEC. 1445(a) OR (b) 	
SDWA/FAILURE TO COMPLY WITH ADMIN. ORDER ISSUED TO FEDERAL FA-
CILITY.
SDWA/VIOLATIONS/SECTION 1463(b)-FIRST OFFENSE/REPEAT OFFENSE .....
RESOURCE CONSERVATION & RECOVERY ACT/VIOLATION SUBTITLE C AS-
SESSED PER ORDER.
RES. CONS. 4 REC. ACT/CONTINUED NONCOMPUANCE OF COMPLIANCE
ORDER.
RESOURCE CONSERVATION & RECOVERY ACT/VIOLATION SUBTITLE C 	
RES. CONS. & REC. ACT/NONCOMPLIANCE OF CORRECTIVE ACTION ORDER
RES. CONS. & REC. ACT/NONCOMPLIANCE WITH SECTION 3013 ORDER 	
RES. CONS. & REC. ACT/VIOLATIONS OF ADMINISTRATIVE ORDER 	
RES. CONS. & REC. ACT/NONCOMPLIANCE WITH UST ADMINISTRATIVE
ORDER.
RES. CONS. & REC. ACT/FAILURE TO NOTIFY OR FOR SUBMITTING FALSE
INFORMATION.
RCRA/VIOLATIONS OF SPECIFIED UST REGULATORY REQUIREMENTS 	
RCRA/NONCOMPL1ANCE W/MEDICAL WASTE TRACKING ACT ASSESSED
THRU ADMIN ORDER.
RCRA/NONCOMPLIANCE W/MEDICAL WASTE TRACKING ACT ADMINISTRA-
TIVE ORDER.
RCRA/VIOLATIONS OF MEDICAL WASTE TRACKING ACT-JUDICIAL PEN-
ALTIES.
CLEAN AIR ACT/VIOLATION/OWNERS & OPERATORS OF STATIONARY AIR
POLLUTION SOURCES— JUDICIAL PENALTIES.
CLEAN AIR ACT/VlOLATION/OWNERS & OPERATORS OF STATIONARY AIR
POLLUTION SOURCES-ADMINISTRATIVE PENALTIES PER VIOLATION &
MAX.
CLEAN AIR ACT/MINOR VIOLATIONS/STATIONARY AIR POLLUTION
SOURCES— FIELD CITATIONS.
TAMPERING OR MANUFACTURE/SALE OF DEFEAT DEVICES IN VIOLATION
OF 7522(a)(3)(A) OR (a)(3)(B>-BY PERSONS.
VIOLATION OF 7522(a)(3)(A) OR (a)(3)(B>-8Y MANUFACTURERS OR DEAL-
ERS; ALL VIOLATIONS OF 7522(a)(1).(2). (4).4(5) BY ANYONE.
ADMINISTRATIVE PENALTIES AS SET IN 7524(a) & 7545(d) WITH A MAXIMUM
ADMINISTRATIVE PENALTY.
VIOLATIONS OF FUELS REGULATIONS 	 : 	
SUPERFUND AMEND. & REAUTHORIZATION ACT/NONCOMPLIANCE W/RE-
QUEST FOR INFO OR ACCESS.
SUPERFUND/WORK NOT PERFORMED W/1MMINENT SUBSTANTIAL
ENDANGERMENT.
SUPERFUND/ADMIN. PENALTY VIOLATIONS UNDER 42 U.S.C. SECT. 9603
9608. OR 9622,
SUPERFUND/ADMIN. PENALTY VIOLATIONS— SUBSEQUENT 	
SUPERFUND/CIVIL JUDICIAL PENALTY/VIOLATIONS OF SECT. 9603. 9608
9622.
SUPERFUND/CML JUDICIAL PENALTY/SUBSEQUENT VIOLATIONS OF SECT
9603. 9608. 9622.
EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT CLASS 1 & II
ADMINISTRATIVE AND CML PENALTIES.
EPCRA CLASS 1 & 11 ADMINISTRATIVE AND CIVIL PENALTIES— SUBSEQUENT
VIOLATIONS.
EPCRA CIVIL AND ADMINISTRATIVE REPORTING PENALTIES FOR VIOLA-
TIONS OF SECTIONS 11022 OR 1 1023.
EPCRA CIVIL AND ADMINISTRATIVE REPORTING PENALTIES FOR VIOLA-
TIONS OF SECTIONS 11021 OR 11043(b). .
EPCRA— FRIVOLOUS TRADE SECRET CLAIMS— CIVIL AND ADMINISTRATIVE
PENALTIES.
New maximum penalty
amount
S 15.000.
S22.000/S55.000.
52.7*0.
S27.5CO.
S25.000.
55.500/555.000.
527.500.
527.500.
S27.500.
S27.500.
55.500.
55,500.
S27.5CO.
S11.0CO.
511.000.
527.500.
527.500.
S27.5CO.
527 £00
S27.50C.S220 000.
55.500.
52.750.
527.500.
5220.000.
527 SCO
S27.500.
527 eOO
527.500.
582.500.
527.500.
582.500.
527,500.
S82.500.
527.500.
511.000.
527.500.
                                                 113

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          Federal Register / Vol. 62. No. 54 / Thursday. March 20. 1997  /  Rules and Regulations    13517


PART 27—{CORRECTED]

  On page 69366. in the first column.
the amendatory instruction identified as
number "4" is corrected to "3".
Michael M. Stahl.
Deputy Assistant Administrator. Office of
Enforcement and Compliance Assurance.
{FR Doc 97-7069 Filed 3-19-97; 8:45 ami
BUJNC CODE tStO-SO-f
                                                         114

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fc>-'^i-> '
*- '—
Federal Register / Vol. 59. No. 144 / Thursday. July 28. 1994 / Notices
i '/ f
384S5
FOB FURTHER INFORMATION COWTACT: upcn activation of substitution plan: • IFRL-S021-5J
-i
4.
Contact the following persons for more
information about a permit listed in this
  Mice:
  For plants in New York. Carry
DeCaetano. (212) 264-6685. EPA Region
2,
  For plants in Florida and Kentucky.
Scon Davis. (404) 347-5014. EPA
Region 4 (address above).  .-•
  For plants in Missouri. Jon Knodel.
(913) 551-7622. EPA Region 7.
SUPPLEMENTART tNFORHATlON: Title IV of
the Dean Air Act directs EPA to
fg»^iKch a program to reduce the
adverse effects of acidic deposition by
promulgating rules and issuing permits
to emission sources subject to the
program. On January 11.1993. EPA •
promulgated final rules1 implementing
the program. Subsequently, several
parties filed petitions for review of the
rules with the U.S. Court of Appeals fat
the District of Columbia Circuit. OB
November 18.1993. EPA published a
notice of proposed revisions to rules
regarding Phase I substitution and
reduced utilization plans [sections 404
(b) and (c) and 408(c)(l)(B) of the Actt.
On May 4.1994. EPA and other parties
signed a settlement agreement
addressing the substitution and reduced
utilization issues.
  In today's action. EPA is issuing
  ermits that are consistent with the May
4.1994 settlement. Except as noted
below. EPA approves for 1995rt999 all
compliance options for which EPA
deferred action for 1996-1999 in the
draft permits. In addition, except as
noted below, the numbers of
substitution and compensating unit
allowances allocated to each unit .far
/1995-1999 are identical to the numbers
of allowances allocated to each unit for
 1995 in the draft permits. The
additional allowances discussed below
are a one-time only allocation pursuant
to the settlement. Upon activation of
conditionally-approved plans.
substitution or compensating unit
allowances are allocated for  the
remaining years the plan is in effect.*
EPA issues the following permits:
   Northport in New York.
   Port Jefferson in New York.
   Big Bend in Florida.
   F} Cannon in F1c?ida: No  change for _
 unit CB01:4.581 substitution
allowances for each year and 9
additional allowances to unit GB02
 upon activation of substitution plan:
 7.003 substitution allowances for each
year and 437 additional-allowances to
 unit CB03 upon  activation of
  tbstitution plan: 7.570 substitution
allowances for each year and 450;
additional allowances to unit CB04
10.^95 substitution allowances for each
year and 520 additional allowances to
unit CBOS upon activation of
substitution plan: 16.107 substitution
allowances for each year and 377
additional allowances to unit CB06
upon activation of substitution plan.
  Hookers Point in Florida: 0
substitution allowances for each year
and 27 .additional allowances to unit
HB01 upon activation of substitution
plan: 31 substitution allowances for
each year and 3 additional allowances
to unit HB02 upon activation of
substitution plan: 92 substitution
allowances for each year and 9
additional allowances to unit HB03
upon activation of substitution plan:
14S substitution allowances for each
year and 15 additional allowances to
unit HB04 upon activation of
'substitution plan: 124 substitution .
allowances for each year and 13
additional allowances to unit HBOS
upon activation of substitution plan:
207 substitution allowances for each
year and 13 additional allowances to
unit HBOS upon activation of
substitution plan.    '•
  Big Sandy in Kentucky.
  Coleman in Kentucky.
  Cooper in Kentucky.               *
  Dale in Kentucky: 2.115 substitution
allowances fort
, year and 226
                    Restatement of Policies Related to
                    Environmental Auditing

                    AGENCY: Environmental Protection
                    Agency (EPAJ.
                    ACTION: Notice.	

                    SUMMARY: The EPA Environmental
                    Auditing Policy Statement ("1985
                    Policy**} was originally r"K>JThtd in the
                    Federal Register on July 9.1986 (51FR
                    25004). The 1986 Policy states that
                    "(c)larification of EPA's position
                     egarding auditing may help encourage
                    regulated entities to establish audit
                    programs or upgrade systems already in
                    place.** The goal of this notice is to
                    clarify EPA's current potidas on and
                    approach, to auditing,-This notice *
                    summarizes salient points torn the 1988
                   .Policy, which remains in efieo. In
                    addition, this notice update* the
                    Agency's activities with, respect to'
                    auditing and auditing policy and
                    references pertinent language from other
                    relevant policy-documents, in
additional allowances to unit 3 upon
activation of substitution plan, and 226
additional allowances if the unit
becomes affected for NO*; 1.729
substitution allowances for each year
and 166 8*JdfHnnal _3flm»f«n>-tt^ J0 nnj^ 4
upon activation of substitution plan.
and 166 additional allowances Lf the
unit becomes affected for NO..
  East Bend in Kentucky.
  H L Spuriock in Kentucky: 14206
substitution allowances for each year
and 1.593 additional allowances to unit
2 upon activation of substitution plan,
and 1.593 additional allowances if the  .
unit becomes affected for NO.:
  R D Green in Kentucky: No change for
unit Gl;~5'ra27 substitution allowances
for each year and 492 additional
allowances to unit G2.
  Sibley in Missouri: 2.782 substitution
allowances for each year and 28
additional allowances to unit 1:3.332
substitution allowances for each year
and 130 additional allowances to unit 2.
  Dated: July 14.1994.*
BriaaJ.McUu.
Director. Acid Rain Division. Office of
Atmospheric Programs. Office of Air and
Radiation.
IFR Doc 94-18323 Filed 7-27-94: 6:45 am)
KUJMC COOC MM 10  •
anticipation of the public meeti
auditing scheduled for July 27-24.
This notice does not represent a netfj '
EPA policy or position on   '     "*
environmental auditing: all existing
policies- remain, in afTeo.           •
                             ge of
                                   fc Meeting:
                      •The response* to EPA's announcement
                    (59 FR 31914. Jane 20.1994) to hold a
                    public sieeting OB auditing an jury 27-
                    28.1994 has been overwhelming. Due to-
                    the expected size of the audience.
                    therefore, the Agency has changed the
                    location of this event Tbeaew location •
                    is the Stoufier Mayflower Hotel in
                    Washington. DC at 1127 Connecticut  '
                    Avenue. NW. Phone (202) 347-3000.
                    H. The Auditing PoUcylUaaaeaeat
                      In response to a request by
                    Administrator Carol M. Browner, die
                    Office of Enforcement and Compliance
                    Assurance (OEGA) is teas
                            ogthe
                    Agency's currant policy regarding
                    environmental auditing and self-
                    evaluation by the regulated community.
                    ' EPA h»< committed to investigating the
                    perceived problems relating to auditing.
                    self-evaluation, and disclosure through
                    an empirical, iufi
                     effort. The Agency must develop an
                     adequate information base to give
                     serious consideration to any policy
                     options and to ensure that any decision
                     to either reinforce, change, or
                     supplement «m'tring policy is informed
                     by fact.
                       EPA hopes to collect such relevant
                     data through the implementation* of four
                     actions this summer. First, the Agency
                                                             116
                                                                                                        1*^1?
                                                                                                        Iw-J-.

-------
38*56
Federal Renter /  V-.I. .VJ.  No.  144  .-'  Th::^.:.,,. ...jv 2y  ,.
                                                                                      :)04
will convene a publir rr.«ling en July
27-fc8.1994. as an opportunity to obtain
s wide variety of views and tn sharpen
the forus on these issues. The range of
issues appropriate for discussion &t the
public meeting i.idude: the
implementation of the 1986 Policy;
specific suggestions for auditing policy
options: State audit privilege legislation:
auditing in the context of criminal
enforcement: and advances in the field
of auditing since 1986. Interested panics
are encouraged to read the Federal
Register notice dated June 20.1994 (59
FR 31914) fotmore details on the public
meeting.'     '   .       .   '
  Second. EPA published in the June
21.1994 Federal Register (59 FR 32062)
a notice requesting proposals for
Environmental Leadership-Program
(ELP) pilot projects. EPA expects that    "
these pilot projects will generate useful
data oc auditing methodology and
measures, and may also serve as  .
vehicles for experimenting with policy-
driven incentives.
•  Third. EPA will encourage the private
sector to collect data and survey
auditing practices in order to gauge the
effect of enforcement policies on self-
evaluation and disclosure in the
regulated community. The Agency will
also sack input on auditing and related
issues from States; environmental and
public interest groups, and trade and
professional associations.
  Finally, in this Federal Register
notice. EPA is reseating salient points
from the 1986 Policy and reviewing its
activities and other policies relating to
environmental auditing. The goal of this
notice :s to clarify EPA's current
policies on and approach to auditing, in
order :o ensure a well-informed policy
d«ha:e.              __
HI. Review of General EPA Policy on
Environmental Auditing
A. EPA Ssvtiuftrgn the Use ttf
.Err. :T9tKR?sisi Auditing
  EPA h£< Trtvehr encouraged and
. pa.tu::p*:*J ;•> the development of
fnv:n;::r.f-:.il .inditing and improved
ttnv;rc3;2..**!f^;l management practices.
ttmvethe r.i:d-:0*JOs. In feet, the 1186
Policy has *w»ed as the basis for
defining the pmu-ce and profession of
environmental auditing. The 1986
Piiltu clearly sta'ss EPA stippdrt'for
  Ei':V::ivr cnvi
 1:1 h^ncr Mvi-ls of overall compliance and
 fl-duo-H mk in huran health and th*.
 wivirunraiT.!  EPA endorses the practice of
 ••••••.-.rs.-.nu'ntal auditing and supports its
 •« •-.«-.-rj:.-J U.-"* by regulated emi:.*s to h«*lp
 '•••-. me goals of redtsral. state and
                       Auaiting serves as a ipjahr.
                     • aw k to heip improve the eiTovtivrr
                     has* environmental mxndijemeat !iy
                     v«--r:rytng that management practicr* jru in
                     pl*r.e. functioning and adequate.
                     Environmental audits evaluate, and are not a
                     tubkiiiute for. direct compliance activities
                     «uchi as obtaining permits, installing controls.
                     monitoring compliance, reporting violations.
                     Mil keeping records. Environmental auditing
                     .•nay verily but does not include activities '
                     rrtiuired by law. regulation, or permit (e.g..
                     continuous emissions monitoring, composite
                     currectioa plus at wastewater treatment
                     plantj, etc.L Audits do a« in any way,
                     replaceregulatory agency icspeaions.
                     However, environmental audits can imptove
                     cnmpiiiince by complementing coomm(ional
                     reuVfwl, state aad local oversight.
                     • •   •     • •   •    .»
                                -           r              *
                       Environmental auditing has developed for
                     sound business reasons, particularly as a
                     means of helping regulated entian manage
                     pollution control affirmatively over time
                     irutrad of reacting to crises. Auditing can
                     result in improved facility environmental
                     periormaact. help communicau efieoive
                     *nts. as
                     noted below). Because enviroemnnial
                     auditing systems have been widely adopted.
                     on a voluntary basis in the past, and bet ause
                     audit quality depends to a large degree upon
                    genuine management commitment to the
                     program and its obtecrives. auditing should
                     remain a voluntary activity.

                     Because  senior managers of regulated
                     entities-are ultimately responsible for
                     taking all necessary steps 10 ensure   .
                     compliance with environmental
                     requirements. EPA believes they have a
                    strong incentive to use  reasonable
                     means, such as environmental auditing.
                     to secure reliable information about
                       .iliiy compliance status.
 B. Definition af Exvinn.'sosxl ^ -.-.„,„
 Elements of Effeaiw Envirar.meKr.i  '~
 Auditing Programs

   The 1986 Policy also defines
 environmental auditing, and ouilines
 what EPA considers to be 'the elements
 of an effective environmental auditing
 program. The 1986 Policy presents th«
 following definition:   "  -
   Environmental auditing is a systematic"
 documented, periodic aad objective review
 by regulated entities of facthry operations
 and practices related to meeting
 •environmental requirements. Audits on'be
 designed to accomplish any or all of the
 following: verify compliance with
 environmental requirement* ev*iuat0 the
 effectiveness of environmental managemmi
 systems already in placa-. or assess risks (mm
 regulated and unregulated my*«^H aod
 practices.
   An organization's auditing program
 will evolve according to its unique
 structures and circumstances. The 1986
 Policy acknowledges this fact, and.also
 states EPA's belief that effective
 environmental auditing programs
 appear to have certain discernible
 elements in common with other kinds of
 audit programs. EPA generally considers
 these elements important to ensure
 program effectiveness. This general
 description of effective, mature audit
 programs can help those starting audit
 programs, especially Federal agencies
 and smaller businesses. Regulatory
 agencies may also use these elements in
 negotiating environmental auditing
 provisions for consent decrees. Finally. :
 these elements can help guide states and
 localities considering auditing
 initiatives.  '
   As stated in the 1986 Policjyan
 effective environmental auditing system
 will likely include the following general
 elements:    _ ^
  L ExplidTlap management support for
 envtronmenta/ auditing aad commitment to
follow-up on audit findings. Management
 support may be demonstrated by a wnon
 policy articulating upper management •
 support for the auditing program, and for
 compliance with all pertinent requir*m<:n:.
-------
                 Federal Register  / VcL 59. No
                       Thursdav. Julv 28.  1994
                                                                                                        38457
 f Adequate team staffing aad-auditor
   - Environmental auditors should
   , or have ready access to the
    \ge. skills, and disciplines needed, to
    .Osh audit objectives. Each individual
   f should comply with the company's •
    tonal standards of conduct. Auditors.
    r lull-time or pan-time, should  •
    i their technical and analytical
       i through rfTntiflti'fts education
        t audit program objectives.
  I resources and frequency. At a
      . audit objectives fhffliM inlud
     i anas
     	with applicable •  .
 _    laws and evaluating the
 > of internal cornpliiiKT policies.
   and personnel mining programs
 , ~~,*n»~t rnmnlimre,
, should be btsedoo a process which
 auditors all corporate poiic"
 evaluate the information and ensure
• correction of identified problems. Procedures
 also should be in place for determining what
 internal findings are reparable to state or
 Federal agencies.
   VIL A process that includes quality
 assurance procedures to assure toe accuracy
 and thoroughness of environmental audits.
 Quality assurance may be accomplished
 through supervision, independent internal
 reviews, external reviews, or c combination
 of these approaches.

 C EPA Activities Related to Auditing
 Standards
   EPA is currently participating in two
 major non-regulatory efforts to develop
 voluntary «t»nfl«r«jf far auditing and
 environmental
    •» »••••••»• .»• ^mm . ,  f , -
    .and Federal state, and -
      i pertinent to the &tilfty: and
    « r protocols addressing specific
    i that should be evaluated by auditors.
    dt writtea audit procedures generally
    be used tnr pi«"«»8«g rf****!
                  esttblishiflg audit
            icating audit results, and
   process that collects analyses
        ' i documents iafoaaatiott
     t to acbiev* audit objectives.
       i should be collected before and
jtag an on-sita visit regarding  •
jriroameatal compliance (1) eovftonmentil
~v -• •atat effectiveness (2) and other
t    3) related to audit objectives and
— ti j^jj information ThffliH be sufficient.
jote. relevant and useful to provide a
sd basis far audit finds and   '   ,

.Su/jfcaeat information is fcctual.
quate and convincing so that a prudent.
xmed person would be likely to reach the
       mxrvn* 2s the auditors
. Reliable Information is the best
 jt«h»» through use of appropriate audit
aniques.  '               .
. Ae/evant information supports audit  '
iisgs and recommendations and is
Distent with the objectives for the audit
. Useful infaraatioa kelps the        .
inizatiOA meet its goals.
lie audit process should include a
iodic review of the re!iability-and
:grity of this information and the means
d to identify, measure, classify and report
xudit procedures, including the testing
 sampling techniques employed, should
•elected in advance, to the extent
rial, .and expanded or altered if
^umstances warrant The process of
'taing. analyzing. Interpreting and
umenting information should provide
onable assurance that audit objectivity is
ntained and audit goals are met.
I A process that includes specific
:edures to promptly prepare candid clear
 appropriate wrisen reports OR audit
 s corrective actions and schedules for
 Ir-'niation. Procedures should be in
     nsure that such information is
 mu.iicated to managers, including
 iiy and corporate management, who can
 First, *h* International Organization of  •
 Standards (ISO), based in Geneva*
 Switzerland, established in 1993 a
 Technical Committee for Environmental
 Management Standards (ISO-TC-207J.
'Subcommittee Two of TC-207 is in the
 process of developing environmental
 auditing **"i<^*rr^* The «*««H»»4^ ^]]
 into three groups: Auditing Principles.
 Auditing Procedures, and Auditor
               Second, in the U.S.. the
 reports may not shield monitoring,
 compliance or other information that
 would otherwise be reportable and/or
 accessible to EPA even if there is no
 explicit requirement to generate that
 data. Thus, the 1988 Policy does not
 alter regulated entities' existing or
 future obligations to monitor, record or
 report information required under
 environmental statutes, regulations or"
 permits, or to allow EPA access to that
 information. Nor dpes.the 1986 Policy
 alter EPA's authority to request and'
 receive any T»lo««n»'infnTmatj«i^—..
 including tttirt ^«"*«"»<*i in audit
 reports—under various environmental
 statutes or in other adnunisflstive or  • •
 Judicial proceedings.*
   EPA's authority to request an audit report.
 or relevant portions thereof, wulbe exasised.
 onacase-by-cuebasia.wheathe Ageacy   '
 din^iM1"***^ it is needed to accomplisha>
 statutory mission, or. where the Government
 deems it to be material to a criminal
 investigation. EPA expectt such jaquests to
 be limited, matt likely fecuMdon particular
. ST^ jjp^p^e^^^irf^aje neTeeaflA vefefittaiBe* t4^Wfej e4%^^ Anf^v^e*
 National Sanitation Foundation (NSF)
 in Ann Arbor. Michigan, is developing
 environmental auditing oemfaurf* that
 are intended to be compatible with and
 augment the ISO ftartdmffa Work is
 proceeding rapidly within ISO and NSF.
 with draft standards expected by the
•end of the year.                   . •
   The-proposed NSF and ISO auditing
 standards are being developed within
 the framework of overall environmental
 management systems standards. Neither
 ISO nor NSF 'ntm«4^ to fliffiiMlsh ••
                                            are
                        to provide
                                  • • • • ™ ^^r-^^» ^^^ • • • ^^HBV^% W^ ^PW^PVV^M
                                management tools that indude auditing
                                schemes and itandards. The EPA 1986
                                Policy has been a central reference •'—»*
                                document for both, the ISO and NSF
                                work. As these new documents develop,
                                fcsmn of auditor qualifications and
                                explicit management commitment to
                                audit follow-up will be of particular
                                interest to EPA.             .

                                IV. Review of EPA Policy on Specific
                                Environmental Auditing Issues

                                A. Agency Requests for Audit Reports
                               .   EPA's 1986 Policy clearly states that:
                               •  -" . . EPA believes routine Agency requests
                                for'audit reports could inhibit auditing in the
                                long run. decreasing both the quantity and
                                quality of audits conducted. Therefore, as a
                                matter of policy EPA will not routinely
                                request environmental audit reports.
                                  The 1986 policy also acknowledges
                                regulated entities' need to self-evaluate
                                environmental performance with some
                                measure of privacy. However, audit
                                                                        information i

                                                                        otherwise available to the Agency. Examples -
                                                                        would likely indadesimanons where: audits-
                                                                        are conducted under consent decrees or other
                                                                        settlement agreements; a company hat placed
                                                                        its management poetics* at lew* by raising
                                                                        them as a defenses ffrT*Mt of miad'or *nf*nt
                                                                        are a reieveBt y^Mni of inquiry, such as
                                                                        during a cnmiaal instigation. Tafc list ir
                                                                        Ulusanye rather than exhanstive^iBca
                                                                        there doubtless will be other situations. &ot
 subject to prediction, in which; audit reports
 rather than information may or required'.
 B. EPA Response to Environmental •
 Auditing
 1. General Policy .     ." -  •   .    ' ^
   The 1986 Policy states that "EPA will
 not promise to forgo inspections, reduce-
 enforcement responses, or offer other
 such incentives in exchange for
 implementation of enviro
                                         auditing or other sound environmental
                                             aagement practices.'* EPA is required
                                         by law to independently i
                                         compliance status of facilities, and
                                         cannot eliminate inspections for
                                         particular firms or classes of firms.
                                         Certain statutes (e.g. RCRA) and Agency
                                         policies establish minimum facility •
                                         inspection frequencies to which EPA
                                         will adhere. Environmental audits are in'
                                         no way a substitute for regulatory.
                                         oversight..
                                            As explained in the 1986 Policy.
                                         however. EPA will take into account a
                                         facility's effdrts to audit in setting
                                         inspection  priorities and in fashioning
                                         enforcement responses to violations:
                                            . .  . EPA will continue to address
                                         environmental problems on a priority basis

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33453
                   Federal Register /  Vc-L 59.  Nu.  K4
                  ^MBMMM^^^^^^H.^_^^^M«MM.^_^_^^_^^^^^^^^BH_
,,-jd v.,!I coamquentiy inspect feohtJrs wi__
peer environmental records and practices
mnrt srnqu«ittly. Since enVciive
«cv!ro8nv»ntai auditing helps management
UMtify and promptly correct actual ur
pU'-T.r.ai prchlems. audited &cH>fi»s'
carironro*?!'*! perfcrsanoe should iraprovn
Thai, whiie KPA inspections of *e.'f-4udiied
iolines will continue, to the extent that
          performance is coosidend in
^^•44^• ^^mw^^m ^ ^- - - • ii •" • •  • - ^— 	• • ^m-^~ ^^« *w
swung inspection priorities, facilities with a
^ood compliance hisnvy may be subject to
fewer Inspections.
  la fashioning enforcement responses to
violations. EPA poucy-is to take into account.
cm a case-by-case basis, the honest and
genuine eSors of regulated*entities to avoid
Mil promptly correct violations end
uo&riymg onvuoiQneotal problems. When
regulated entities take •~""~Mt precastii
to avoid noocomplian
comet anderiyiBg envirc
dswvsred through audit
                     •xpeditiousry.
                     (orotheri
                    i to prevent their
                        It ita discretion
                    at honest end
                                Saftl-
recurrence. EPA m
to consider such ac
genuine efforts to a	
consideration applies particularly when e
ngulated entity promptly reportt violations
oroxapliaaca data that otherwise were not '
rvquirad to be recorded or reported to EPA*
  These principles have been
incorporated into.the Agency's  '
enforcement response and civil penalty
pobcjes.

2. Audit Provisinns'as Remedies in
Enforcement Sanlemrats
  The 1986 Policy include* the
following language on audit provisions
as'remedies in enforcement settlements:
  EPA aay propose anvirai

•settlement negotiations where auditing could
provide a remedy for Identified problems and
reduce the likelihood of similar probaame
recurring in the future. Environmental
auditing previsions an most likely to be
proposed in settlement nf't?f1eTHTTrr whecB
  • A patten of violations can he asaabuted,
4 least in pert, to the absence orpoor
functioning of an environmental-znanagBaent
«vaensor          •        •  ».
  • The type-of nature of viokttens
* likelihood that similar noocompliance
problems may exist or occur ebewfaera in the
atil:*y or it other faotibac operated by the
  EPA's enforcement office issued
 funhw guidance on tfrii issu* in 1966
 in a document entitled "EPA Policy on
 the inclusion of Environmental
 Auditing Provisions in Enforcement
          ."" This guidance has been
consistently applied in enforcement
actions as appropriate, and has formed
the basis for the inclusion of audit
agreements or provisions in numerous
consent decrees. Selected text from this
document, also s$U in effect., is
included here:
 •In recast years. Agency negotiators haw*  -
•M.hieved numerous t»TTi***"p*'*f t&*t require
                                          •~ul.iu.ii entities to «adi! their op«—irinas     *r;
                                          h«w inaox-arive srtiiraiwuts hw* t^-a       ^
                                         highly tuccessful in enabling the Agency to
                                         accomplish more efieaivety ita pnmary
                                         mission, narsely. to senuc environmental
                                         complianco. Indeed, auditing provisions in
                                         -nfcrccment sertlements hav« provided
                                         werai Importam benefits to the Agency by
                                         enhancing its ability to:
                                           • Address compnance at an entire facility
                                         or at all faciiinw owned or operated by a
                                         parry ."rather than just the violations
                                         discovered during inspections and identify
                                         and correct violations that may have goae
                                         undetected (and uncorrected) otherwise;
                                           • Foeas the armntinn ol« mg..)...^ r"-*y*«
                                         toprlevel management on oBvitaoiaantal
                                         compliance; produce CTrporata policies and
                                         procedures mat enable a patty to achieve and
                                                    rpm
                                                           : end help a parry to
*~»«»n»ll» «.,-iiyii«in n, milH, OW|I • P«7 >O
manage pnHirboa conaol ammaaveiyover
tum instead of reacting to crises?
  • Provide a quanry acBiraaca check SJL
venfying that eaosting eavnoaaeatti
            practices are in place,
       ting aad adequate.
                                         w     ar     •  (  v    v
                                           It is the policy of EPA to cecd* its judicial

                                         where violators cam assure the Agency that
                                         their nonrnrrrprienra- will be (or baa been)
                                         corrected. EPA. . . considers aodttins; an
                                         appropriete part of a
                                         heignteaed manrgemn
                                         lower the pomnrial Ear
                                         foUowi«g tiro typee of
                                         should be considered lin enfaccetMat
                                         seaieraeatsi:
                                           1. CotapOaaet Audit: Aa inaependeal
                                                 at of the current status of a party's
                                                  -	-^.    w  ^ <   . - -   *  ^
                                         r^pilat^ry cenuiferoBirn Tois approach
                                         always •ntaila a requireneot tfaet effBcav*
                                         £Cttt8312ffB9 O^ CftJDaVDL ID JPCD3a9^ZV ttflOOWWOL
                                         compliaacaprobisma. sod ia most efiecttve
                                         when coupled with a requireoMat that the
                                         remedied.
                                           a. Maaagateiit Audit An jpd*pendent
                                        'evahutfOB of a party's environineBtal
                                         LUimpltarK^r poudes. ptac&cea
                                         fon(l)Afannel_r	
                                         M"TfT>l;nf^" policy, and procedures far
                                         implementation of that policy: (2)
                                         educational and training programs for
                                         employee*; (3) equipment purchase,
                                         operation and maintenance programs; (4)  -
                                         environmental compliance officer programs
                                         (or other organizational strueurs relevant to
                                         Tnr'lTt'"-''1' (5) budgeting and planning
                                         systems for environmental compliance: (6)
                                         monitoring, record keeping and reporting
                                         iystaros; 17} in-piam and community
                                         emergency plans: 18) internal
                                         communications and control systems; and (91
                                         hazard identification and risk assessment.
                                           Whether to seek a compliance audit a
                                         management audit, or both wtil depend upon
                                         the unique circunutaacss of each case. A
                                         compliance audit usually will be appropriate
                                         where die violations uncovered by Agency
                                         inspections «ei*e the likelihood that
                                                                                         rcfs:al r.ont.-nmpHiace exists
                                                                                  e!»ev,h^re within a pacty's operations. A
                                                                                  management audit should De souiht where it
                                                                                  appears that a major consibun'ng nctor to
                                                                                  noncornpliance is inadeouata (or
                                                                                  nonexistent) managerial anennon to
                                                                                  envOTttrnental ponaes. procedures or
                                                                                  stiuing. Both typee of audits should be
                                                                                  and shoRosmiags m a penyj ermronmeo^;
                                                                                  management practices need to be addmseal'
 Criminal Enforcement Polity
   Following EPA's 1986 Poficy, three. '":
 significant deraiopmenu aack the-    -':~
 evolution andiaiplementatroe of   .. ,;/
 criminal enforcement policy gowmai--'
 theuseofsetf-enditsandthevoruntar* :'
.di«3eaatne
-------
                    Federal F.-*&
                                                                                                               28439.
         factors thai .Ji
              inal investigation. With
 • respect to corporations conducting
    •ironmental audit*, the guidance
 ; ..-tes:
 •  Corporate cuipebility rear be indicated
L when * company performs an environments!
' compliance or management audit and then
f knowingly bill to promptly remedy the noo-
t enp'i*nca "^ correct any harm cone. On
?• rise other hand. EPA policy strongly
f ^courages se&moaiforing. self-disclosure.
5 tod self-correction. When self-auditing has
[ been conducted (followed up by prompt
1 jonediation of the non-compliance and any
f molting harm) and wlL complete disclosure
\ has occurred, the company's constructive
F activities should be considered as mitigating
  toots in EPA's exerdse of investigative
  loiuntarUy revealed and fully and prompdy
I noediated as pan of a corporation's
                 generally will not be a
 gram gener
the expendi
                     ture of scarce
;
[
I enJuaoon
r curfidate
F cdmiaal resources.

  D. Audit PavHege Legislation
 '  .Four States (Colorado. Indiana.   -
  Kentucky, and Oregon) have recently
  enacted legislation which, with some
  variations, creates a "self-evaluative"
  privilege far audit reports. EPA has
  consistently opposed this approach.
  principally because of the risk of
  weakening State enforcement programs.
     imposition of unnecessary
  transaction casts and delays in
 i (nforcement acH""f, and the potential
 ' increase in the number of situations
 I* requiring the expenditure of scarce
 •: Agency resources, including the
 H "overfiling" of State enforcement
 '„ tfljons. EPA urges States that are
 !• considering a privilege-oriented
 • approach to actively participate in the
 ' comprehensive process described in the
 • June 20. 1994 Federal Register notice
 s (59 FR 31914) before pursuing any
 r legislative action. The Agency also
 \ encourages States that have passed, such
 : legislation to present documentary '.
 ; justification for this approach either at
 ' the public meeting on July 27-28. 1994.
 : or in written comments. •

 • L Environmental Auditing at Fedeml
 \ Facilities
 jT The 1986 Policy also encourages all
 •f Federal agencies subject to
 L environmental laws and regulations to
 £ institute environmental auditing, to
 [ help ensure  the adequacy of internal
 £ systems to achieve, maintain and
 I monitor compliance. Such Federal
 I" faciiiry environmental audit programs
 r should be structured TO promptly
 f " ' itiry environmental problems and
 !    edStiously develop schedules for
  remedial action.
                                          VVhtirs 2?f-ra?rU;ie. EPA * ill w.:er
                                        into a^reeaents with other agencies to
                                        dariry the respective reles,
                                        responsibilities and commitments of
                                        f-ach agency in conducting and
                                        responding to Federal facility  •
                                        environmental audits. Also, to the
                                        extent feasible* EPA will provide
                                        technical assistance to help Federal
                                        agencies design and initiate audit
                                        programs: Currently, the EPA Federal
                                        Facility Enforcement Office (FFEO) is
                                        co-chairing an inter-Agency work group
                                        to revise auditing guidelines and
                                        protocols for Federal agencies. In
                                       • addition. FFEO is developing the
                                        Federal Government Environmental
                                        Challenge Program required by
                                        Executive Order 12856. which calls for •
                                                   m^fl{ of a Code of
Environmental Principles and a Model
Installation Program for Federal
facilities. This program is likely to
include environmental auditing
components.
  The 1986 Policy states that
  With respect to inspections of self-audited
facilities and requests for audit repora. EPA
generally wilt respond;to environmental
audits by Federal fiariliHiM in the «•"»•
manner as it does for other regulated entities.
                              Federal agrmrie* should, however.be
                            aware that the Freedom ot '^^^^atlfl^i Act
                            will govern any disclosure of audit reports or
                            audit-generated information requested from
                            Federafagencies by the-public.

                           "  When Federal agencies discover
                            significant violations through an audit,
                            EPA encourages them to voluntarily
                            submit the related findings and
                            corrective action plans
                                                 mal office and
                                        appropriate EPA
                                        State agencies, even when not ;^,u
                                        specifically required to do so. EPA will
                                        review the audit fi"«*»"r and action
                                        plans, and negotiate either a consent '
                                        agreement or a Federal Facilities
                                        Compliance Agreement, pursuant to its
                                        eaforcement authorities under the
                                        various environmental statutes. In any
                                        event Federal agencies are expected to
                                        report to EPA pollution abatement and
                                        prevention projects involving costs
                                        necessary to correct compliance
                                        problems discovered through the audit.
                                        in accordance with OMB Circular A-
                                        106. Upon request, and in appropriate
                                        circamstances. EPA may assist affected
                                        Federal agencies through coordination
                                        of any public release of voluntarily
                                        submitted audit findings with approved
                                        action plans once agreement has been
                                        reached and/or appropriate enforcement
                                        actions have been taken.
                                                                   120
V. Review of Relationship to State or
Local Regulatory Agencies
 . Effective Federal/state partnerships
are critical to accomplishing the mutual
goal of achieving and maintaining high
levels of compliance with
environmental laws and regulations.
The greater the consistency between
state and local policies and the Federal
response- to environmental auditing, the
greater the degree to which sound
auditing practices might be adopted and
compliance levels unproved. State and
local regulatory aencies, of c
have independe
                                                                                   agencies, of course.
                                                                                    t jurisdiction over
regulated entities. EPA encourages them
to adopt these or similar policies on
environmental auditing, in order to
advance, the use of effective
environmental auditing in a consistent
manner.
  The 1986 Policy emphasizes this
point further:
  EPA recognizes that some state* have
already uadattakeB environmental auditing
                 r toniatwMt fron ihif

                                                                               policy. Other 9tat*s also may want to davtlep
                                                                               *  jf»   «       *i
                                                                    particular needs
                                                                    this policy
                                                                                                             ft»ftfrhiB%eT tH
                                                                                                        AmA       "
                                                                                     age* state and local authorities, to •
consider the basic.
Agency in developing
                                                                                                        mat cutded the
                                                                               zegulanoQS. cegaraieaa oc whether such

                                                                               audit or container! in an audit report.'
                                                                               Required infocnatioa cannot he-withheld
                                                                               merely because it is generated by an audit
                                                                               .ramer tban oy yune ouiav yutsuL
                                                                                 • Regulatory agencies cannot aaky
                                                                               ^)avOv^B2SaS tv9 aiDa^flD Oaf U9S2& a^SXOCCBafBaQS aCpDOtt
                                                                    *niiin>»iM*Ht^^ ettdi&sf aysttema.1 However*
                                                                    such agociMinay uae their discretiaa to
                                                                    adfust enforpantaiit actions oo-a case*by-case
                                                                    basis in ntpoBse to hbneet and genuine
VtftfMM* lIlliMI l»^M*»a*fc •fc^JMM^ W« «MOW/-«M«
basis in mpoose to honeet and genuine
efforts by regulated entities to assure
environmental <-^-»p"-"'^
.  • When setting inspection priorities. /
regulatory agencies tfaCTiM focus to the extent
possible OB compliance performance and
environmental results.
  • Reoulatonr exencia
                                                                      • Regulatory agencies must continue to
                                                                    meet '"^""•"i program requirements (e.g~
                                                                    minimum inspection raquiiemeats. etcl •
                                                                      • Regulatory apimniH should not attempt
                                                                    to prescibe the precise form and structure of
                                                                    regulated entities' environmental
                                                                              t or auditing programs.  ^
                                                                   ' VL Cooclttsion
                                                                      AJ1 of the-policies referenced in this
                                                                    notice remain in effect. The Agency
                                                                    intends, however, to re-examine these
                                                                    policies comprehensively and remains
                                                                    open to suggestions for changes and

-------
 3460
                Federal Register
uprcvements regarding all jsp.-t ts nf
tississ sutlsung pclury. The
-.f&rniausn presented here is niviiUrd
s ;he ccavazieuos of interestod
irt-is, in pnspsra:ion for the July 27-
rt, 1334 publit. meeting. The Agency
optathat thii information wilfclarify
PA*» ormnt activities and policies
ibzeil to environmental auditing.
 Th« Ofnoj of Compliance will
:spond to written requests for copies of
i.e documents referenced in this notice.
cad all raquestt to: U-S/EPA. Office of
amplianta. Ann: Ira R. Feldman.
gctial Counsel. 401 M Street, NVV
1:031 \Yasti=gtoa. DC 20460.
 instant Adminisaaior. Office of
 .ifbiCMMfU and CnmptiaQc* Assurance.
 •R Doc M-1S327 Filed 7-27-94: 8:45 em|
 (fluent Guttatine* Task Fore» Open
 lesafio,

 CENCT: Eavinxuneatai Protection
 .geocytEPA).
 awe Notice of meeting.

 UMARR The Effluent Guidelines Task
 area, an EPA advisory committee, will
 •.old t tueeuiig to diiua m ioipi ut enieuts
 o tfie Agency's Effluent Guidelines
 •ragmen. The meeting is open to the
 ublic
 ATES: The meeting will be held on
 'uesday, August 16, from fc3O am to
 ;flO pm.and Wednesday. August 17.
 994. from 8:30 am to 3:00 pm.
 OORESSES: The meeting will take place
 t the Dupont Plaza Hotel. 1500 New
 lampshire Avenue NW, Washington,
 3.C Comments may be sent to Eric
 Brassier, Effluent Guidelines Task
 •'•.na. Office of Water (4303), EPA. 4O1
 •I y.n-A, S.W.. Washington. O.C 20460.
 3»fWTHSR INfOmUTION COKTACn Eric
         202-260-7150. fax 202-280-
             INFORMATKMC Pursuant
•j e c-j FF wns es:abliihed in Juhr «>f
"•>3t ;o advise EPA on the Effluent
"uijili:i«s Prosrara, which develops
"•Halations for dischargers of industrial
         pursuant to Title III of the
    VVati-f Ad (33 U^.C 1251 et a-q.).
The T-"i*k Force '.onsjsis cf m»i:nh>TS
appointed by EPA from :r»i!usiry. dt.zp.n
groups, state and to.*! government, ihe
ac-sJemic and stwmific c;ommuaf?i*s.
and EPA regional officei. The Task
Force was created u> offer advice to  the
Administrator on the long-term strategy
for the effluent guidelines program,  and
particularly to provide
recommendations on a process for
expediting the promulgation of effluent
guidelines. The Task Force generally
does not discuss specific effluent >
guideline regulations currently under
development.
  The meeting agenda will include
discussions on draft recommendations
for improving the project management
and data collection processes, for
effluent guidelines. Them will also be
discussions on the methodology far
conducting preUmhiary industry
studies, and a planning session for
future task farce activities.
  The meeting is open to the puhfic.
Limited seating for the public is'
available on a nrst-come, fitsi-eerred
basis. The-public may submit written -.-
comments to the Task Force r
improvements to {)«+ Fffimm*
Guidelines program. Conme&t
                                                                           i.-.ss pubH<: rijjr.raen! period to onstuv
                                                                           'hat the ittmngest options have fceun
                                                                 caouJd
                                                      .
                                    be seat to EPA at the above addcasx.
                                    Comments submitted by August 8 will
                                    be considered by the Task Force at or
                                    
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                                                                                                      lit
Notices
 Federal  Register / Vol.  50,  No.  63./  Monday, April  3,  1995 /  Notices       Page  15875
This secson of the FEDERAL REGISTER
contains documents other than rules or
proposed rules that are applicable to me
public. Notices of hearings and investigations,
comrnttae meetings, agency decisions and
rulings, delegations of authority, fifing of   .
petitions and applications and agency
statements of organization and functions are
examples of documens appearing in this
section.
 ENVIRONMENTAL PROTECTION
 AGENCY.
.[FHL-5184-4] '     '      ,        .&:-
                                   *
 Voluntary Environmental Self-Policing *_d
 Self-Disclosure Interim Policy Statement'
 AGENCY: Environmental Protection Agency
 (EPA).                             ,   •
 ACTION: fritifp'i policy statement and request
 for commenL

 SUUUARY: The Environmental Protection
 Agency (EPA) announces and requests
 comment on an interim policy to provide
 incentives for regulated entities mat conduct
• voluntary compliance evaluations and also
 disclose and correct violations. These  .
 incentives inrfrr^r »^*"j**affag or substantially
 rednong the gravity c^nipo"^* ox cxvfl
 penalties and not referring cases for criminal
 prosecution where specified conditions-are
 m<»f The policy »*«" ***** fh*f EPA wdl nor •
 reqnesc voluntary *>**"** reports to cnuvcr
 enforcement mvesQjsanons* &his interim
 policy was developed in close consultation:
 with EPA's regional offices and me
 Department of Justice, and win be appfied
 uniformly by the Agency's enforcement
 programs.
 DATES: This interim, policy statement is
 effective as mt»F"fi guidance 15 days after •
 publication, in order to give the Agency time,
 tO mtutlinat» mipl* mr nrannn of (ne policy
 throughout EPA Headquarters and the
 Regions. EPA mgts interested parties to
 conmjent on this interim policy in writing,
 Comments must be received by EPA at the
 address below by June 2. 1995.
 ADDRESSES: Submit three copies of
 comments to the U.S. EPA Air Docket. Mail
 Code 6102, 401 M Street. SW, Washington.
 D.C 20460, attention: Docket #C^94-01.
 FOR FURTHER INFORMATION CONTACT:
 AjddiOOttal ffevH flpfpfaqruQ rciSttXBff tD tfac
 development of this interim policy is
 pubfic docket. Documents from the 'frrkff
 may be requested by calling (202) 260-7548,
 requesting an index to docket SC-94-01. and
 faxing document requests to (202) 260-4400.
 Hours of operation are 8 aun, to 5:30 p JL.
 Monday through Friday, except legal
 holidays. Additional contacts are Geoff
 Carver or Brian Riedei at (202) 264-4187.

 SUPPLEMENTARY INFORMATION:
 L Bg
 A. Intrcducaon
   One of the Environmental Protection
 Agency's most important responsibiEne
                                                              with federal laws mat
                                          Leadership Program (ELP) pilot projecs with
                                          companies and public agencies to tea criteria
                                          for anriirhig and certification of voluntary
                                          compliance programs. If successful, standards
                                          developed through Environmental Leadership
                                          could lead to reduced inspections and public
                                          recognition for companies or agencies with
                                          state-of-the-art compliance programs. In
                                          keeping with the President's announcement  •
                                          on March 16.. 1995. EPA also will shortly be
                                                            9\ compliance'incentivcs
 protect pubfic health and safeguard the
             That goal can be achieved only
 with the voluntary cooperation of thousj—'.s.
 of businesses and other regulated etri ••"
 subject to these requirements. Today,.   is
 ^mmnn^ incentives for those who tal  •
 \ f ci iopiyini nty for voluttUfuy evaluating.
 disclosing and correcting violations. These
 incentives, developed after ""** months of
 public f^^+Ttrg* and empirical analysis, are
 set forth hi *1*^*1 below *r$ take effect in 15
 days. At the same time. EPA expects to
 * 'Mni/""* a dialogue with «gir»><«i«fa*'» «n<<
 considef nifl&er refiDenscnts to thxs.mtezuQ
 pohcy. The iitrn
 Min
                                                  businesses.
                                            The Agency is especially interested in
                                                 ts relating to whether this intern

                                          policy appropriately defines the criteria for
                                          deosmnning whether a self-audit, self-
                                          evaluation or disclosure is voluntary; whether
                                          the interim policy adequately preserves the •
                                          Agency's authority to_assess a gravity penalty
                                          component in appropriate cases: and whether,
                                          and according to what criteria, the Agency
                                          should consider giving credit against the
                                          economic benefit component of a penalty for
                                          state-of-the-art environmental management
                                          systems.                         "
               rives mat EPA is offering     B. Public Process
   First, the Agency win
 gravity-based (or "punibve
                                            In May 1994. the Administrator asked the
                                          ^JCQCS Of CJCtKUTCCZDCZlZ ^0.0 VfQffifp if ^fflCft
identify, discic
                  d
                                                                   t violati
' according to the mnditii
. policy. EPA win also
•.pmairi..* by up to 75% far
                          Honed is this
                                          disclosure and cotrec&on of violanons
                                          QDCovered dorzns ^nvizonmenQu audits 2Dd
                                          self-evahi
• Second. EPA wiE not recommend to the
be uiv
           against 2
                                 in good
 faith to i<1f unfy^divlfHev and ujucxt _
' violations, so long as no serious aminl harm
 has occurred. FinaDy, the Agency win not
   The incentryes offered in this policy have
 ocen afaijCnTryfl anove au to protect HuAiuUk

 even where-toe condiQOQs for mxngated
 enforcement are mrf. EPA wfll mervc the
 right to collect full dvfl penalties for criminal
 conduct, violations that present an immment
 and substasoal esBan&exment or rcsui£ m  ™
 serious y|"^ harm, or '•yit violations.
 Sources wiQ not be allowed to gain an,
 economic advantage over their competitors by
 oeiflVuiuiL ^^)ezt •nves^^Denc ]^x co^nd23nce* F^QS
     J ^^^V                      f
 wfll EPA b"^""* to bring a criminal yty«i •
 szsinst xnus^ftoosuis respp^yftyi^- tof cmQinsL
 COBOOC-^                *
   EPA is considering additional incentives
 for voluntary comptiancs beyond the benefits
 offered in the policy today. On April 7,1995.
 the Agency will announce 12 Environmental
                                            In-developing tttf* jffi»ptTi poficy, the
                                          Agency held a major two-day public meeting
                                          in July 1994 announced m me Federal
                                          Register-on June 20, 1994 (59 FR 31914);
                                          'published a Restatement of Policies Related
                                           Renter on My 28^994 (59 FR 38455);
                                           copsidcted over 80 written comments
                                           SQO^DXtBed to toe cnvifonn^cnQu jm^ii^^ff
                                           policy docket; held a focus group meeting in
                                           San Francisco on January 19. 1995 with key
                                           flajrrholders from industry, trade groups.
                                           State
                                                 vir
                                                           at commissions. State
                                           anomeys general offices, district attorneys'
                                           offices, environmental and pub&c interest
                                           giuups, and professional environmental
                                           auditing RIUUUS; and held a public coooioJt
                                           session in San Francisco on January 20.1995.
                                             'Tn addition to considering opinion from
                                           stakeholders. EPA conducted its own analysis
                                           of relevant facts. For example, the Agency
                                           'considered EPA and other •Federal policies
                                           relating to »«»vfon»w*y»i auditing, self-
                                           disdosure, and correction, as well as
                                           incentives suggested by State and local
                                           policies and legislation, and by applications
                                           submitted for the ELP pilot program. Toe
                                           Agency also considered 'relevant surveys on
                                           auditing practices and incentives.
                                                         122
                                                            5 C 0 /

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C Purpose  .
  This interim policy is intended to promote
environmental compliance by providing
greater certainty as to EPA's enforcement
response to voluntary self-evaluations, and
voluntary disclosure and prompt correction of
violations. The policy further provides
guidance for States and local authorities in
encouraging rh?s behavior among regulated
entities.
  Federal laws »"d regulations set minimum
standards for protecting ""man health and •
achieving environmental protecaon goals
such as clean air and clean water. EPA win
continue to uphold these laws through
vigorous enforcement actions that   .
appropriately penalize violators. Penalties
help ensure a level playing field by ensuring
that violators do not obtain an unfair
economic advantage over their competitors
who T™*f the necessary invesaaent in
compliance. Penalties also promote protecaon
•of the environment and public health by
encouraging adoption of pollution prevention
and recycling practices that umit exposure to
liability for pollutant discharges and deterring.
future violations by the violator and others.
  At me same rime, the Agency i
rh^y we 1'nniKTt achieve maTfp
without the cooperation of a regulated
community wultng to act responsibly by
detecting, disclosing, and correcting  •
violations. Already, regulated entities have
many compelling incentives to implement
environmental managernentfeuditmg systems.
as noted in EPA's 1986 auditing policy.  .
Indeed, recent surveys show that the vast
majority of large companies engage in.
environmental auditing and/or have  -
environmental rmm**wr-pt systems is place.
Nonetheless. EPA has concluded mat the
additional incentives in mit T^it^>im policy *
will farther promote the regulated
community's raMniiMini^it to adopoaff
svstc^Qs for niaxmn^snff coo^oiiance. "   —
D. Principles for Voluntary Compliance
  The ""»""» policy thar EPA is announcing
today is based on seven principles:
  1. Self-policing by regulated entities <**"
play a crucial rote in finding, fixing and
preventing violations.                    •
  2. Violations discovered through self-
policing should be disclosed and promptly
corrected.
  3. Regulated entities that self-police and
that voluntarily disclose and self-correct
violations in accordance with this policy
should be assessed penalties that are
consistently and predictably lower *"an
penalties for those who do not
  4. Regulated entities that self-police and
voluntarily disclose and self-correct violations
in accordance with this policy should also not
be recommended for criminal prosecurioa,
  5. Providing predictable incentives for
voluntary disclosure and correction of
violations identified through self-policing
                                            offers a positive alternative to across-the-
                                            board privileges and immunities that could be
                                            used to shield criminal misconduct drive up
                                            litigation costs and create an atmosphere of
                                            distrust between regulators, industry and local
                                              6: EPA should not seek voluntary   ''
                                            environmental audit information to trigger an
                                            investigation of a civil or criminal violation
                                            of environmental laws.
                                              7. To preserve a level playing field, EPA
                                            should recover any economic benefit reaK7«<
                                            from violations of environmental- law.
                                            £. Relationship to Emerging Standards
                                              EPA also n-gngnr^ die development of
                                            and growing *»f"PC¥ on international '
                                            standards m the U.S. and other countries. .-
                                            These standards, if properly crafted and
                                            implemeared, can provide a powerful tool for
                                            organir*""'5ns to improve their overall
                                            compliance with environmental requirements
                                           -and move beyond compliance through
                                            innovative approaches to pollution •
                                            prevention. In addition to issuing this interim
                                            policy, EPA wiQ continue to pursue a
                                            dialogue with interested parties and to pilot.
                                            policy approaches through programs such as
                                            the ELP to dftfi111'™* how EPA rai main* me
                                            of ?n*f encourage tfa*«* gfran/foTffa

                                            IL Interim Policy

                                            A. Definitions

                                              For purposes of this interim policy, the-
                                            following d^finitinfl^ apply;
                                                                     »• «~-— vkA *
                                                                     ;  P3S toe
  voluntary environmental audit or voluntary
  self-evaluation appropriate to the size and
  nature of the regulated entity, and
    2. Voluntary disclosure.''^ regulated
  entity, fully and voluntarily discloses the
  violation m writing to all anpropriate federal
  state and local ageaaes-as soon as it is
- discovered (rncrnrfrng a reasonable time to
  determine that a violation exists), and prior
  to (1) the ramnencement of a federal state
  or local agency inspection, investigation or
 . information request; (2)  notice of a nrm^ '
  sun; (3) legal complaint oy a third parry; or
  (4) the regulated entity's knowledge that the
  discovery of .the violation by a regulatory
  agency or third parry was imminent; and
   3. Prompt correction.  The regulated entity  .
  corrects the violation either within 60 days of
 discovering the violation or, if more time is
 Tictdcd. as expeditiousry as practicable: and
   4. Remediation of imminent and substantial
  endanger i.'.*^. The regulated entity
 • expedi£"~  :} ..emediesanycondmonthaihas'
• created o. .-.-' * M^W* an imminent and
 substantial ?ndangenueat to human health or
 the environment: and- •
  - 5. Remediation of harm and prevention of
  repeat violations. The regulated entity
 implements appropriate measures to remedy
 any environmental barm due to  the violation
 and to "prevent a recurrence of the vwlaaon; -
 and
   6. No lack of appropriate preventive
 measures. The violation dp?r not indicy? mat
 the regulated  entity has failed to take
 3^JOrQOU2iB^t SCC^SS CO 2YOti^L ?CDC2£ OT FCC3ZZ3J!!LZ
 violatic

                                            definition given to it in EPA's .1986 policy-
                                            on environmental audiang, LC. "a systematic,
                                            documented, periodic and objective review by-
                                            regulated entities of facility operations and .-
                                            practices related to nyfnng environmental
                                           .  _-__;__^_—.M t»
                                            reqmremeuB*
                                              •'Environmental audit report?*, means-alt.
                                            A'« iiiin-iitafirm of information relating, to an
                                                              , but not including the
                                                          ion underlying or testimonial
                                            CUTUWUUJI
                                            evidence relaang to sn^fi mforinaaoo.
                                              "Regulated entity" m^an* any entity,
                                            including a federal, state, and municipal
                                            facaity, regulated under the federal
                                            environmental laws mgf EPA
                                              "Self-evaluation" m***"* an assessment;
                                            not necessarily meeting all the critgria of a
                                            full environmental audit, by a regulated entity
                                            of its compliance with one or more
                                               "Vohmtary" »"Mn« noc required by
                                            statute, regulation, permit; order; or
                                            B. Conditions
                                              The conditions for redncmg,civil penalties-
                                            anri not making' criminal referrals in
                                            accordancs- with Sections HC and HJ>. of
                                            thit fan-rim policy are as follows:
                                               1. Voluntary self-policing. The regulated
                                            entity discovers a violation through a
   7. Cooperation. The regulated entity
 cooperates as lequired by EPA and provides
 and required by EPA to determine
 applicability of this policy. Cooperation may
 include providing an requested documents  .
 and aeons to employees and assistance in any
 fiii diet investiganons into the violauon.
   Where appropriate, EPA may require that
 to satisfy any of these conditions, a regulated
 entity m"«f cntrr into a written agreement,
 administrative consent order or judicial
 consent decree, particularly where compliance
' or remedial measures are complex or a
 lengthy schedule for -"'j'«"«g ""d
 maintaining compliance or remediating harm
 ts required.
 C Reduce Gvil Penalties for Voluntarily
 Disclosed and Prompdy Corrected Violations.

 1. Incentive       •
   Regulated fntftrer will be eligible for the
 following redactions in civil penalties:
   a. EPA will -eaminate all of the gravity
 component of the penalty for violations by
 rpgniat»xj entitiesIhaf rnfft conditions 1
 through 7 ""fKn^d in Section ILB-. except for
 violations involving (i) criminal conduct by
 the regulated entity or any of its employees.
 or (if) an imminent and substantial
 eadangermenr, or serious armal harm, to
        hearth or die environment.
                                                               123

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                                                                                                                              3
   b. EPA may mitigate up to 75% of the
 unadjusted gravity component of me penalty.
 rating into account any of conditions 1—7 in
 Section ELB. that are met in the following
   (I) cases in which most bat not all of the
 conditions in Section ELB. are mec or
   (ii) T3s?s involving an imminent and
 substantial endangerment. but not serious
 a1"™! harm, in which all the conditions in
 Section ELB. are mec  or
   (iii) cases involving the disclosure of
 criminal conduct in which all the conditions
 is Section ILB. are met.-              .
   c. EPA will retain its foil discretion to
 recover any economic benefit gained as a
 result of noncompliance to preserve a "level.
 playing field" in which violators do not gain
 a competitive advantage through
 nrmmmpfianr-- However, EPA may forgive
 me entire penalty for violations which meet
 conditions I through 7 outlined in Section
' ELB. wH. in EPA's discretion, do not merit
'any penalty due to the ipgjgnifipaff* amount
 of any economic benefit.

 2. Discussion
   a. Providing a dear and significant
 reduction in civil penalties for companies *^af
 »Tgmna responsibility for finding, fH«^i"«i"g
 and correcting violations will create a strong
 incentive for regulated entities to prevent or
 fix violations before EPA expends *
 enforcement resources. The policy states
 clearly the conditions under which EPA wiH
 forgive all or part of the gravity component
 of a penalty for voluntary disclosure and
 correction!
   b. The policy appropriately preserves the
 concept of recovering economic benefit.  .
 except where, it is fa^p***^"***1* as
              by a broad specsuni of
               *iH?t»       iy
              EPA's discretion to collect the
 gravity component of the penalty- in  •
 appropriate cases, such as where a violation
 involves connnal cwnffncti or mnnifient and
 substantial ""^ny"'"^!!, wifl hylp to deter
 the most egregious environmental violations.
 At the same-time, by preserving flexibility to
 reduce the gravity element by up to 75% for
 good faith efforts to disclose and promptly
 comply even in those cases, the policy win
 D. Limit Criminal Referrals for Voluntary
 Disclosure and Correction of Violations

 1. Incentive
   EPA win not recommend tome
 DeDarunent of Justice ^*af criminal
 be brought against a regulated entity where
 EPA determines that conditions 1-7 in.
 Section ELB. above for reduction of civil  " •
 penalties are met. and the violation does not
 demonstrate or involve (1) a prevalent
 corporate management philosophy or practice
 mat concealed or condoned environmental
 violations;-(2) high-level corporate official*'
or managers* conscious involvement in or
willful blindness to the violation: or (3)
serious- ac*11*! harm to hnnmn health or the*
environment. This policy does not apply to
criminal acts of individual managers or
employees. Where EPA determines pursuant
to this Section that a criminal referral (b the
Department of Justice is unwarranted, EPA
may nonetheless proceed with civil .
enforcement in afT*"^"""* with Section IT C*
of this policy or other applicable enforcement
response and penalty policies.

2. Discussion                •   '
  The policy will promote candid and
thorough self-policing by providing greater
^•giTainty as to how EPA win exercise its
^ ij^ip^ investigative discretion to encourage
voluntary disclosure and piouipt correction by
£ Eliminate Routine Requests far Audit
Reports in Pre-Enjbrci.  M. Proceedings
                   •             •  •
1. Incentive
  EPA win not request a voluntary
environmental audit reporno trigger a civil
or criminal investigation. For example. EPA
win not request an audit in routine
inspections. Once the Agency has reason to
believe a violation has been commuted, EPA
may seek through an investigation or
IO ICICOtl^^Tnff YlOldQOfiS Of G
        Of cctcoc or ostrxEL
iDi
  a. This policy inafce* g1«ff rhat EPA wOl
not routinely request audit reports: At the
           th^ poficy in no way limits fhfr
law privileges (e.g.. attorney-client and work
product) as appropriate. EPA believes that
tins ^feyn iimiiionj aionjE with ioe otncr
incentives in **"* im^iim policy, 5fo™?H
greatty reduce any perception that
environmental audits may be mgt nnfji^iy ju
                       '
                                            this policy. In addition, where appropriate,
                                            EPA's Supplemental Environmental Project
                                            Policy may at EPA's discretion be applied in
                                            conjunction with this poficy.

                                            QL Favor These Incentives Over Broad
                                            Privileges a*"* Immunities
                                             • This inTfrim policy offers a positive
                                            alternative to across-the-board privileges and
                                                       *« could be used to shield
                                           criminal miscontlnrt, drive up litigation costs
                                           and create an atmosphere of disaust between '
                                           regulators, industry and local communities.
                                           A. Discussion
                                              1. Penally immumry provisions for
                                           voluntary disclosures of violations can give
                                           lawbreakers an economic advantage over
                                           their law-abiding competitors.
                                           to give substantial penalty reductions for
                                           those who come forward 'with their violations
                                           and promptly correct.^-;., *, but to m*inrain a
                                          •teVeT playing field, t*».  . eral and state
                                           governments must be  privileges and
                                            nenatty umsonx&es could cncouiafie ncidscc
                                            litigation as opposing lawyers baale over.  '•'.
                                            what is privfleged or immune from penalties
                                            and what is not. Litigation over me scope of
                                            the privileges andrisHnunities could burden
                                           government and private resources, and in
                                           some cases prevent quick action to address
                                           environmental etc
                                            .  6. The Supreme Court has noted.
                                            "privileges are not lightty created nor
                                            expansively construed for they are in
                                            derogation of the search for the smb."
                                            United States v. Nixon, 418 US. 683,710
                                            (1974). Moreover, the self-evaluation
                                            privilege has regularly and uniformly been
                                            rejected by the courts in cases where
                                            documents  were sought by a governmental
                                            agency.  %

                                            IV. Consequences for States
                                              EPA recognizes that states are imporant
                                            partners in federal enforcement and tSat it s
                                            desirable to create'a rKirrafi- jn which states
                                            can be innovative. At me same time. EPA u
                                            required to establish a 'certain caBinr-mi
                                            consistency in federal'enforccaiesi. so to
                                                            124

-------
the sanctions a business faces for violating
federal law do not depend on where the
business is located.
  Accordingly, to maintain national
consistency.
  A. EPA will scrutinize enforcement
closely in states with audit privilege and/or
penalty immunity laws and may find it
necessary to increase federal enforcement
where environmental self-evaluation
privileges or penalty immunities prevent a
state from obtaining:"
  h information needed to establish «-*i™««i
liability;  .-  .
  2. facts needed to **tahB?h the nature and
extent of a violation;    ••  .  .
  3 2DQrOffl!li3G6 DCQS^xCKGS JOT 4
   B. EPA will bring to the state's attention
any provisions of state audit privilege and/or
'penalty immunity ""r*^ that raise any of the
concerns outlined above, and will work with
the state to address those concerns and ensure
that federal lequiimienu are satisfied.  ;.

V. Limitations on Applicability of This
Policy
  •This
                                                           policy sets forth internal
                                             guidelines which a!f**tt31-95: 8:45 am]
                                                    CODE I
                                                             SO-P
                                                                    125

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  66706
Federal Register / VoL 60. No^ 246" / Friday. December 22. 1995  / Notices
  ENVIRONMENTAL PROTECTION
  AGENCY               .   -   -

  [FW.-6400-.11

  Incentives for Self-Policing: Discovery,
  Disclosure, Correction and Prevention
  of Violations

  AGENCY: Environmental Protection.
  Agency (EPA).
  ACTION: Final Policy Statement.

  SUMMARY: The Environmental Protection
  Agency (EPA) today issues its final
  policy to enhance protection of human
  health and the environment by
  encouraging regulated entities to
  voluntarily discover, and disclos* and _
  correct violations of environmental
  requirements. Incentives include
  •liininrting or substantially reducing
  the gravity component of civil penalties
  and not recommending cases for
  criminal prosecution where specified
  conditions are met. to those who
  voluntarily self-disclose and promptly
  correct violations. The policy also  •
  restates EPA's long-standing practice of
  not requesting voluntary audit reports to
  trigger enforcement investigations. This
  policy was developed in dose
  consultation with the U.S. Department
  of Justice, states, public interest groups.
  and the regulated community, and will
•  be applied uniformly by the Agency's
  enforcement programs.
  OATEK This policy is effective January
  22.1996.
  FOR FURTHER INFORMATION CONTACT?
  Additional documentation relating to
  the development of this policy is
  contained in the environmental auditing
  public docket; Documents from the
  docket may be obtained by calling (202)
  260-7548. requesting an index to docket
  fC-94-01. and faxing document
  requests to (202) 260-MOO. Hours of
  operation are 8 a_m. to 5:30 pmr.
  Monday through Friday, except legal
  holidays. Additional contacts are Robert
 Fentress or Brian Riedel at (202) 564-
 4187. .                       .

 SUPPl£MB*TARY INFORMATION:
 L Explanation of Policy

 A. Xnfroo'ucnsn
   The Environmental Protection Agency
 today issues its final policy to enhance  •
 protection of human health and the
 environment by encouraging regulated
 entities to discover voluntarily, disclose.
 correct and prevent violations of federal
 environmental law. Effective 30 days
 from today, where violations are found
 through voluntary environmental audits
 or efforts that reflect a regulated entity's
 due diligence, and are promptly '
                    disclosed and expeditiously corrected.
                    EPA will not seek gravity-based (La..  ,'
                    non-economic benefit) penalties and   •
                    will generally not recommend criminal
                    prosecution against the regulated entity.
                    EPA will reduce gravity-based penalties
                    by 75% for violations that are-   ,~r  •
                    voluntarily discovered, and an
                    promptly disclosed and corrected, even
                    if not found through a formal audit or
                    due diligence. Finally, the policy • • •"'.
                    restates EPA's long-held policy and -,- __
                    practice to refrain from routine requestsT
                    for environmental audit reports..
                     The policy includes important /
                    safeguards to deter irresponsible.;
                    behavior and protect ***• public and-"
                    environment For example. In addition
                    to prompt disclosure and expeditious
                    ijiu i Mjion, the policy  requires' - *• ••"
                    companies to act to prevent recurrence
                    of the violation and to remedy any.'C
                    environmental harm-wnich may have
                    occurred. Repeated violations or those
                    which result in actual bans or may  •.
                    present imminent and substantial - -
                    endangerment are not eligible for relief
                    under this policy, and companies will
                    not be allowed to gain an	"~
                    advantage over their competitors by
                    delaying their investment in    -—- • - -
                    compliance. Corporations remain
                    criminally liable for violations that
                    result from conscious disregard of their
                    obligations under the law. and
                    individuals are liable for criminal
                   . misconduct.
                     .The '*y»mn**^ of frh*y policy concludes
                    EPA's «ightn»n-mfmtVi public evaluation
                    of the optimum way to encourage
                    voluntary self-policing while preserving
                    fair and effective enforcement. The
                    incentives, conditions and exceptions  '
                    announced today reflect thoughtful
                   -suggestions from.the Department of. • *
                   -Justice, state attorneys general and local
                    prosecutors, state environmental  •-  '
                    agencies, the regulated community .'and
                    public interest organizations. EPA. ...  -
                    believes that it has found a balanced •..
                    and responsible approach, and will -
                    conduct a study within three yeaxs-to  •
                    determine the effectiveness 6f.this4.v-. •
                    policy.

                    B. Public Process  ••   .
                     One of the Environmental Protection
                    Agency's most important   *     ~-~  '.
                    responsibilities is ensuring compliance
                    with federal laws that protect pubUp&~
                    health and safeguard the environment
                    Effective deterrence requires inspecting,
                    bringing penalty actions and securing
                    compliance and remediation of harm.'-'
                    But EPA realizes that achieving  s-.^£5-~-"
                    compliance also requires the    - ";.-.
                    cooperation of thousands of businesses-
                    and. other regulated entities subjei
                    these requirements. Accordingly,
  May of 1994. the Administrator asked
 . the Office of Enforcement and
  Compliance Assurance (OECA) to
  determine whether additional
  incentives were needed to encourags
  voluntary disclosure and correction of
  violations uncovered during
  environmental audits.
   EPA began its evaluation with a two-
  day public meeting in July of 1994. in
  Washington. D.C.. followed by a two-
-.day meeting in San Francisco on
-•January 19.1995 with stakeholders from
" industry, trade groups, state
  environmental commissioners and
  attorneys general, district attorneys.
  public interest organizations and*
 • professional environmental auditors.
  The Agency also established and
  maintained  a public docket of testimony
  presented at these meetings and all
  comment and correspondence. .
  submitted to EPA by outside parties on
  this issue.      *~"
   In addition to considering opinion
  and information from stakeholders, the
  Agency examined other federal and
  state policies related to self-policing,
  self-disclosure and correction. The
  Agency also considered relevant surveys
  on auditing  practices in the private
  sector. EPA  completed the first stage of
  this effort with the announcement of an
  interim policy on April 3 of this year,
  which denned conditions under which
  EPA would  reduce civil penalties and
  not recommend criminal prosecutioa for
,  companies that audited, disclosed, and
  corrected violations.
   Interested parties were asked to
  submit comment on the interim policy
  by June 30 of this year (60 FR16875);
  and EPA received over 300 responses
  from a wide variety of private and
  public organizations. (Comments on tha
  interim audit policy-are contained in the
 -Auditing Policy Docket hereinafter.
  "Docker'.) Further., the'American Bar
  Association SONREEL Subcommittee
  hosted five days of dialogue with
  representatives from the regulated.
  industry, states and public interest
  organizations in June and September of
  this year, which identified options for
;  strengthening  the interim policy. The
  changes to the interim policy
  announced  today reflect insight gained
  through comments submitted to EPA,
  the ABA dialogue, and the Agency's
  practical experience implementing the
  interim policy.

  .C. Purpose
   This policy is designed to encourage
 ' greater compliance with laws and
  regulations  that protect human health
  and the environment It promotes a
  higher standard of self-policir.g by
  waiving gravity-based penalties for
                                                       126'

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                     Friday. December 22, 1995 / Notices
                              66707
 violations that are promptly disclosed
 and corrected, and which wen
 discovered through voluntary audits or'
 compliance management systems that
 demonstrate due diligence, To further
 promote compliance, the.policy reduces-
 gravity-based penalties by 75% for any
 violation voluntarily discovered and
 promptly disclosed and corrected, even
 if not found through an audit or
 compliance management system.  —
   EPA's enforcement program provides'.
 a strong incentive for responsible  " •  '•
 behavior by imposing stiff sanctions for
 noncompliance. Enforcement h»«
 contributed to the dramatic expansion
 of environmental auditing measured in:
 numerous recant surveys. For example, '
 more than 90% of the corporate
 respondents to a 1995 Price-Waterhouse
 survey who conduct audits said that one
. of the reasons they did so was to find
 and correct violations before they were'.
 found by government inspectors. (A
 copy of the Price-Waterhouse survey is
 contained in the Docket as document
 •Vin-A-76.)
   At the same time, because government
 resources an limited, maximum
 compliance cannot be achieved without
 active, efforts by the regulated
 communityto-police themselves. More
 than half of the respondents to the same
 199S Price-Waterhouse survey said that
 they would expand-environmental .
 auditing in exchange for reduced
 penalties for violations discovered and
 collected. While many companies
 already audit or have compliance
 management programs. EPA believes
 that the incentives offered in this policy
 will improve the frequency and quality .
 of these self-monitoring efforts.
 D. Incentives for Self-Policing  ' ' -~" •
   Section C of EPA's policy identifies
• the major incentives that EPA will
 provide to encourage •self-policing, self-
 disclosure, and prompt self-correction.
 These include not seeking gravity-based
 civil penalties or reducing them by
 75%, declining to recommend criminal
 prosecution for regulated entities that"
 self-police, and refraining from routine
 requests for audits. (As noted in Section
" C of the policy, EPA has refrained from
 making routine requests for audit
 reports since issuance of its 1986 policy
 on environmental auditing.)

 1. Eliminating Gravity-Based Penalties
   Under Section C(l] of the policy. EPA
 will not seek gravity-based penalties for.
 violations found through auditing that
 are promptly disclosed and corrected.
 Gravity-based penalties will also be
 waived for violations found through any
 documented-procedure for self-policing.
 where the company can show that it has
 a compliance management program that
 meets-the criteria for due diligence in
 Secfibn B of the policy.
   .Gravity-based penalties (denned in
 SecfiMiB of the policy) generally reflect
 thesenpusness of the violator's
 behavMrl EPA has elected to waive such
 penaltiesjor violations discovered
 through"due diligence or environmental
 audj$^recognmng that these voluntary
 effoztsplay a critical role in protecting
 humaahealth and the environment by
 identifying, correcting and ultimately '
 preventing violations. All of the
 conditions setforth in Section D. which
 include prompt disclosure and
 expeditious correction, .must be satisfied
. for grayfiy-basad penalties to be waived.*
 * As injha interim policy. EPA reserve*
 the right to collect any economic benefit
 that may have been realized as a result
 of noncompliance, even when  .
 companies.meet all other conditions of.
 the policy. Economic benefit may be
 waived.* however, where the Agency •
 determines that ft is insignificant.
.   After considering public comment..
 EPA has decided to retain the-discretion
 to recover economic benefit for two
 PMi5onf- First, it provides an incentive
 to comply on time. Taxpayers expect to
 pay interest or a penalty fee if their tax
 payments are late; the same principle
. should apply to corporations that have .
 delayed their investment in compliance
 Seconds-it is fair because it protects
 responsible companies from being
 undercut by their noncomprying
 competitors, thereby preserving a level
 playing field. The concept of recovering
economic benefit was supported in
public comments by many stakeholders.
 including industry representatives (see.
 e.g.. Docket. n-F-39i n-f-28. and ff-F-
18J.«^       .
2. 75%Jiaduction of Gravity

•  The policy appropriately limits the
complete'waiver of gravity-based civil
penalties to companies that meet the •
higher standard of environmental    :
auditing or systematic compliance
management. However, to provide
additional encouragement for the kind
of self-policing that benefits the public.
gravity-based penalties will be reduced
by 75%~ for a violation that is
voluntarily discovered, promptly .
disclosed and expeditiously corrected.
even if it was not found through an
environmental audit and the company
cannot document due diligence. EPA
expects that this will encourage •
companies to come forward and work
with the Agency to resolve
environmental problems and begin to
develop_an effective compliance
management program."
   Gravity-based penalties will be *
 reduced 75% only where the company
 meets all conditions in. Sections 0(2)
 through D(9). EPA has eliminated
 language from the interim policy
 indicating that penalties may be
 reduced "up to" 75% where "most"
 conditions are met, because the Agency -
 believes that all of the conditions in.
 D(2) through D(9) are reasonable and
 essential to achieving compliance. This
 change also responds to requests for
 greater clarity and predictability.
 3. No Recommendations for Criminal
 Prosecution  •
  EPA has never recommended criminal
 prosecution of a regulated entity based
 on voluntary disclosure of violations
 discovered through audits and disclosed
 to the government before an
 investigation was already under way.
 Thus. EPA will not recommend criminal
 prosecution for a regulated entity that
 uncovers violations through'
 environmental audits or due-diligence.
• promptly discloses and expeditiously
 corrects those violations, and meets all
 other conditions of Section D of the ..
 policy.
  This policy is limited to good actors.
 and therefore has  important limitations.
 It will not apply, for example, where
 corporate officials are consciously
 involved in or willfully blind to
 violations, or conceal or condone
 noncompliance. Since the regulated
 entity must satisfy all of the conditions
 of Section D of the policy, violations  ,
 that caused, serious harm or which may
 pose iTTiTniTont and substantial
 endangerment to human  health or the
 environment are not covered by this
 policy. Finally. EPA reserves the right to
 recommend prosecution  for the criminal
 conduct of any culpable individual.
  Even where all of the conditions of
 this policy, are not met however, it is
 important to remember that EPA may.
 decline to recommend prosecution of a
 company or individual for many other
 reasons under other Agency
 enforcement policies; For example, the
 Agency may.decline to recommend
 prosecution where there  is no
 significant harm or culpability and the-
 individual or corporate defendant has '
 cooperated fully.
  Where a company has met the •
 conditions for avoiding a
 recommendation for criminal
 prosecution under this policy, it "will
 not Face any civil  liability for gravity-
 based penalties. That is because the
 same conditions for discovery,
 disclosure, and correction apply in both
 cases. This represents a clarification of
 the interim policy, not a  substantive
 change.
                    127

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  66708          Federal Register / VoL 6O. No. 246 / Friday. December 22. 1995 / Notices
  4. No Routine Requests for Audits
    EPA is reaffirming its policy, in effect
  since 1986. to refrain from routine
  requests for audits. Eighteen months of
  public testimony and debate have
  produced no evidence that the Agency
  has deviated, or should deviate, from
  th»« policy.
    If the Agency has independent
  evidence of a violation, it may seek
  information needed to establish the
  extent and nature of the problem and
  the degree of culpability. In general.   •
  however, an audit which results in
  prompt correction clearly will reduce
  liability, not expand it Furthermore, a
  review of the criminal docket did not
  reveal a single criminal prosecution for
  violations discovered as a result of an
  audit self-disclosed to the government.

  E. Conditions
   Section 0 describes the nine
  conditions that a regulated entity must
  meet in. order for the Agency not to seek
  (or to reduce) gravity-based penalties
  under the policy. As explained in the
 Summary above, regulated entities that.
 meet all nine conditions will not face
 gravity-based civil penalties, and will
 generally not have to fear criminal
 prosecution. Where the regulated entity
 meets all of the conditions except the
 first OXD). EPA will reduce gravity-
 based penalties by 75%.

 1. Discovery of the Violation Through
 an Environmental Audit or Due
 Diligence
   Under Section D(l). the violation
 must have been discovered through
 either (a) an environmental audit that is
 systematic, objective, and periodic as
 defined in the 1986 audit policy, or (b) .
 a documented, systematic procedure or
 practice which reflects the regulated .-.•
 entity's due diligence in preventing. ~-.
 detecting, and correcting violations. The
 interim policy provided full credit for
 any violation, found through "voluntary
 self-evaluation." even if the evaluation
 did not constitute an audit In-order to
 receive full credit under the *">•> policy.
 any self-evaluation that is not an audit
 must be part of a "due diligence"
 program. Both "environmental audit" -
 and "due diligence" are defined in
 Section B of the policy;
  Where the violation is discovered
 through a "systematic procedure or
"practice" which is not an audit, the
 regulated entity will be asked to
 document bow its program reflects the
 criteria for due diligence as defined in
 Section B of the policy. These criteria.
 which are adapted from existing codes
 of practice such as the 1991 Criminal
 Sentencing Guidelines, were fully
 discussed during the ABA dialogue. The
 criteria are flexible enough to   ' "
 accommodate different types and sizes
 of businesses. The Agency recognizes
 that a variety of compliance
 management programs may develop
 under the due diligence criteria, and
 will use its review under this policy to
 determine whether basic criteria have  ..
 been met. , .         .        .' ''
   Compliance management programs
 which train and motivate production
 staiT to prevent detect and correct
 violations on a daily basis are a valuable
 complement to periodic auditing. The
 policy is responsive to  •
 recommendations received during
 public comment and from the ABA r; . °
 dialogue to give compliance    ~ * J*
 management efforts which meet thr
 criteria for due diligence the same••'.
 penalty reduction offered for -  . '-.
 environmental audits. (See. e.g-. H-F—
 39. D-E-18. and B-G-18 in the-Docket.) '
   EPA may require as a condition of
 penalty mitigation that a description of
 the regulated entity's due diligence   •
 efforts be made publicly available-The
 Agency-added this provision in -.
 response to suggestions'from  ••
 environmental groups, and believes that
 the availability of «"«**> information will
 allow the public to judge the adequacy
 of compliance management systems.
 lead to enhanced compliance, and fpft^r
 greater public trust in the integrity of
 compliance management systems.

 2. Voluntary Discovery and Prompt
 Disclosure
  Under Section D(2) of the final policy.
 the violation must have been identified  •
voluntarily, and not through a .  .  •
monitoring, sampling, or auditing
 procedure that is required by statute,  .  •
regulation, permit, judicial or
administrative order, or consent
agreement Section D(4) requires that. • •
disclosure of the violation be prompt
and in. writing. To avoid confusion and
respond to state requests for greater   •.
clarity, disclosures under this policy
should be made to EPA. The Agency
will work closely with states in-=r?
 implementing the policy. •'   . —"=y  •
  The requirement that discoverypf the
violation be voluntary is consistent with"
proposed federal and state bills which
would reward those discoveries that the
regulated entity.can legitimately^*.
attribute to its  own voluntary efforts;.
  The policy gives three specific r%9?
examples of discovery that wouloVnot be
voluntary, and therefore would npt.be ..
eligible for penalty mitigation: _™"
emissions violations detected through a
required continuous emissions monitor.
violations of NPDES discharge limits
 found through prescribed monitoring.
 and .violations discovered through a
 compliance audit required to be
 performed by the terms of a consent
 order or settlement agreement
   The final policy generally applies to
 any violation that is voluntarily
 discovered, regardless of whether the
 violation is required to be reported. This
 definition responds to comments
 pointing out that reporting  requirements
 are extensive, and that excluding them
 from the policy's scope would severely
 i'""'t the incentive for self-policing [see
 e.g^n-C-48 in the Docket).      .  '
   The Agency wishes to emphasize that
 the integrity of federal environmental
 law depends upon timely and accurate
 reporting. The public relies on timely
 and accurate reports from the regulated
 community, not only to measure
 compliance but to evaluate health or
 environmental risk and gauge progress
 in reducing pollutant loadings. EPA
 expects the policy to encourage the kind
 of vigorous self-policing that will serra-
 these objectives, and not to provide an
 excuse for delayed reporting.  Whan
 violations of reporting requirements an
 voluntarily discovered, they must be
 promptly reported (as discussed below).
 Where a failure to report results in
 imminent and substantial endangerment
 or serious harm, that violation is not
 covered under this policy (see
 Condition Df 8)). The policy also
 requires the regulated entity to prevent
           of the violation, to ensure
 that noncompuance with reporting
 requirements is not repeated. EPA will .
 closely scrutinize the effect of the policy
 in furthering the public interest in
 timely and accurate reports from the
 regulated community.
  Under Section D(4), disclosure of the
 violation' should be made within 10  .
 days of its discovery, and in writing to.
 EPA. Where a statute or regulation
 requires reporting be made in less than '
 10. days, disclosure should be made
 within the time limit established by law.
 Where reporting within ten days is not
 practical because the violation is
 complex and compliance cannot be .,
 determined within that period, the
 Agency may accept later disclosures if
• the circumstances do not present a
 serious threat and the regulated entity
 meets, its burden of showing that the
 additional time was needed to
 determine compliance status.
   This condition recognizes that it is
 critical for EPA to get timely repotting
 of violations in order that it might have
 clear notice of the violations and the
 opportunity to respond if necessary, as
 well as an accurate picture of a given
 facility's compliance record. Prompt
 disclosure is also evidence of the
 regulated'entity's good faith in wanting
                                              128

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                                                           Friday.-December 22, 1995
                                                                                                           66709
 to achieve or return to compliance as
 soon as possible.
   In the final policy, the Agency has
 added the words, "or may have
 occurred," to the sentence. "The
 regulated entity fully discloses that a
 specific violation has occurred, or may
 have occurred * " V This change. •
 which was made in response to
 comments received, clarifies that where
 an entity has some doubt about the.
 existence of a violation, the
 recommended course is for it to disclose
 and allow the regulatory authorities to
 make a definitive determination.  -
   In general, the Freedom of
 Information Act,will govern the
 Agency's release of disclosures made
 pursuant to this policy. EPA will.
 independently of FQIA, make publicly
 available any compliance agreements
 reached under the policy (see Section H
 of the policy), as well as descriptions of
 due diligence programs submitted under
 Section D.I of the Policy. Any material
 claimed to be Confidential Business
 Information will be treated in
 accordance with EPA regulations at 40
"CFJLPart2.
 3. Discovery and Disclosure .
 Independent of Government or Third
 Party Plaintiff
   Under Section D(3). in order to be
 "voluntary", the violation must be
 identified and disclosed by the
 regulated entity prior to: the
 commencement of a federal state or
 local agency inspection, investigation.
 or information request: notice of a
 citizen suit; legal complaint by a third
 party: the reporting of the violation to
 EPA by a "whistleblower" employee;
 and imminent discovery of the violation
 by a regulatory agency.
   This condition means that regulated
 entities must have taken the initiative to
 find violations and promptly report
 them, rather than reacting to knowledge
 of a pending .enforcement action or
 third-party complaint This concept was
 reflected in the interim policy and in
 federal and. state penalty immunity laws-
 and did not prove controversial in the
 public comment process.

' 4. Correction and Remediation
   Section D(5) ensures that, in order to
 receive the penalty mitigation benefits
 available under the policy, the regulated
 entity not only voluntarily discovers
 and promptly discloses a violation, but
 expeditiously corrects it. remedies any
harm caused by that violation
 (including responding to any spill and
 carrying out any removal or remedial
action required by law), and
expeditiously certifies in writing to
appropriate state, local and EPA
 authorities that violations have been
 corrected. It also enables EPA to ensure
 that the regulated entity will be publicly
 accountable for its commitments
• through binding written agreements.
 orders or consent decrees where.
 necessary.
   The final policy requires the violation
 to be corrected within 60 days, or that
 the regulated entity provide written
 notice where violations may take longer
 to correct. EPA recognizes that some
 violations can and should be corrected
 immediately, while others (e.&. when
 capital expenditures are involved), may
 take longer than 60 days to correct In
 all cases, the regulated entity will be
 expected to do its utmost to achieve or
 return to compliance as expeditiously as
 possible.
   When correction of the violation
 depends upon issuance of a permit
 which has been applied for but not
 issued by federal or state authorities, the
 Agency will, when appropriate, make
 reasonable efforts to secure timely
 review of the permit.

 5. Prevent Recurrence
   Under Section D(6). the regulated
 entity must agree to take steps to
 prevent a recurrence of the violation,
 including but not limited to
 improvements to its environmental
 auditing or due diligence efforts. The
 final policy makes dear that the
preventive steps may include
 improvements to a regulated entity's
environmental auditing or due diligence
efforts to prevent recurrence of the
violation.
  In the interim policy, the Agency
required that the entity implement
appropriate measures to prevent a.
recurrence of the violation* a
requirement thafoperates prospectively.
However, a separate condition in the
interim policy also required that the
violation not indicate "a failure to take
appropriate steps to avoid repeat or
recurring violations"—a requirement
that operates retrospectively. In the
interest of both clarity and fairness, the
Agency has decided for purposes of this
condition to keep the focus prospective
and thus to require only that steps be
taken to prevent recurrence of the
violation after it has been disclosed.

6. No Repeat Violations •'
  In response to requests from
commenters (see, e.g.. n-F-39 and H-G—
18 in the Docket). EPA has established
"bright lines" to determine when
previous violations will bar a regulated
entity from obtaining relief under this
policy. These will help protect the
public and responsible companies by
ensuring that penalties are  not waived
 for repeat offenders. Under condition
 D(7), the same or closely-related
 violation must not have occurred
 previously within the past three years at
 the same facility, or be part of a pattern
 of violations on the regulated entity's
 part over the past five years. This
 provides companies with a continuing
 incentive to prevent violations, without
 being unfair to regulated entities
 responsible for managing hundreds of
 facilities. It would be unreasonable to
 provide unlimited amnesty for repeated
 violations of the same requirement
  The term "violation" includes any
 violation subject to a federal or state
 civil judicial or administrative order.
 consent agreement conviction or plea
 agreement Recognizing that minor
 violations are sometimes settled without
 a formal action in court, the term also
 covers any act or omission for which the
 regulated entity has.received a penalty
 reduction in the past Together, these
 conditions identify situations in which
 the regulated community has had clear
 notice of its noncomplianca and an
 opportunity to correct
 7. Other Violations Excluded
 ' Section D(8) makes clear that penalty
 reductions are not available under this
 policy for violations that resulted in
 serious actual harm or which may have
 presented an imminent and substantial -
 endangerment to public health or the
 environment Such events indicate a
 serious failure (or absence) of a self-
 policing program, which should be
 designed to prevent such risks, and it
 would seriously undermine deterrence
 to waive penalties for such violations.
These exceptions are responsive to
suggestions from public interest
 organizations, as-well as other
 commenters. (See. e.g., n-F-39 and H-
 G—18 in the Docket) •  •
  The final policy also excludes penalty
reductions for violations of the specific
terms of any order, consent agreement
 or plea agreement (See. n-E-60 in the
Docket) Once a consent agreement has
been negotiated, there is little incentive
 to comply if there are no sanctions for
violating its specific requirements. The
exclusion in this section applies to
violations of the terms of any response.
removal or remedial action covered by
 a written agreement
8. Cooperation
  Under Section D(9). the regulated
entity must cooperate as required by
EPA and provide information necessary
to determine the applicability of the
 policy. This condition is  largely
unchanged from the interim policy. In
the final policy, however, the Agency
has added that "cooperation" includes
                                                             129

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 66710
Federal Register / VoL 60. No. 246 / Friday. December 22. 199S / Notices
       	     --  	_^.....^—^^mmmmm 	     ••^•••a—»^—in i i nan i—. i  ^^^^,^MM|__	,	    ,  , ,
 assistance in determining the facts of
 any related violations suggested by the
 disclosure, as well as of the disclosed
 violation itself. This was added to allow
 the agency to obtain information about
 any violations indicated by the
 disclosure, even where the violation is
 not initially identified by the regulated
 entity.
 F. Opposition to Privilege
   The Agency remains firmly opposed
 to the establishment of a statutory
 evidentiary privilege for environmental
 audits for the following reasons:
   1. Privilege, by definition, invites
 secrecy, instead of the openness needed
 to build public trust in industry's ability.
 to self-police. American law reflects the
 high value that the public places on fair
 access to the facts. The Supreme Court.
 for example, has said of privileges that.
 "Whatever their origins, these
 exceptions to the demand for every
 man's evidence are not lightly created
 nor expansively construed, for they are
 in derogation of the search for truth."
 United States v. Nixon. 418 U.S. 683
 (1974). Federal courts have
 unanimously refused to mmgnint a
 privilege for environmental audits in the
 context of government investigations.
 See. e.g.. United States v. Dexter. 132
 FJLD. 8. 9-10 CD-Conn, 1990)
 (application of a privilege "would
 effectively impede [EPA'sl ability to
 enforce the Clean Water Act. and would.
 be contrary to stated public policy.")
   2. Eighteen months have failed to
 produce any evidence that a privilege is
 needed. Public testimony on the interim
 policy confirmed that EPA rarely uses
 audit reports as evidence. Furthermore,
 surveys demonstrate that environmental
 auditing has expended rapidly over the
 past decade without the stimulus of a
 privilege. Most recently, the 1995 Price
 Watarhouse survey found that those tew
 large or mid-sized companies that do
 not audit generally do not perceive aay
 need to: concern about confidentiality
 ranked as one of the least important
 factors in their decisions.
  3. A privilege would invite
 defendants to Haim as "audit" material
almost any evidence the government
needed to establish a violation or
determine who was responsible. For
example, most audit privilege bills
under consideration in federal and state
legislatures would arguably protect
factual information—such as health
studies or contaminated sediment
data—and not just the conclusions of
the auditors. While the government
might have access to required
monitoring data under the law, as some
industry commenters have suggested, a
privilege of that'nature would cloak
                     underlying facts needed to determine
                     whether such data were accurate.
                       4. An audit privilege would breed
                     litigation, as both parties struggled to
                     determine what material fell within its
                     scope. The problem is compounded by
                     the lack of any dear national standard
                     for audits. The "in camera" (Le.. non-
                     public) proceedings used to resolve
                     these disputes under some statutory
                     schemes would result in a series of
                     time-consuming, expensive mini-trials.
                       5. The Agency's policy eliminates the
                     need for any privilege as against the
                     government, by reducing civil penalties
                     and criminal liability for those
                     companies that audit, disclose and
                     correct violations. The 1995 Price
                     Waterhouse survey indicated that
                     companies would expand their auditing
                     programs in exchange for the kind of
                     incentives that EPA provides in its
                     policy.
                       6. Finally, audit privileges are.
                     strongly opposed by the law
                     enforcement community, including the
                     National District Attorneys Association.
                     as well as by public interest groups.
                     (See.>.&. Docket. B-C-21.0-C-28. H-
                     C-52. tV-C-10. n-C-25. D-C-33.B-G-
                     52. H-C—48, and n-G-13 through Q-G-
                     24.)

                     G. Effect on States   .
                       The final policy reflects EPA's desire
                     to develop fair and effective incentives
                     for self-policing that will have practical
                     value to states that share responsibility
                     for enforcing federal environmental
                     laws. To that end. the Agency has
                     consulted closely with state officials in
                     developing this policy, through a series
                     of special meetings and conference calls
                     in addition to the extensive opportunity
                    .for public comment As fresult, EPA
                     believes its final policy is grounded in
                     (T>tTnnnn-<^Ti5J» principles that should
                     prove useful in the development of state
                     programs and policies.
                       As always, states are encouraged to
                     experiment with different approaches
                     that do not jeopardize the fundamental  .
                     national interest in assuring that
                     violations of federal law do not threaten
                     the public  health or the environment, or
                     make it profitable not to comply. The
                     Agency remains opposed to state
                     legislation that does not include these
                     basic protections, and reserves its  right
                     to bring independent action against
                     regulated entities for violations of
                     federal law that threaten human health
                     or the environment, reflect criminal
                     conduct or repeated noncompiiance, or
                     allow one company to make a
                     substantial profit at the expense of its
                     law-abiding competitors. Where a state
                     has obtained appropriate sanctions
needed to deter such misconduct, there
is no need for EPA action.

H. Scope of Policy

  EPA has developed this document as
a policy to guide settlement.actions.
EPA employees will be expeced to
follow this policy, and the Agency will
take steps to assure national consistency
in application. For example, the Agency
will make public any compliance
agreements reached under this policy.
in order to provide the regulated
community with cur notice of decisions
and greater accountability to affected
communities. Many in the regulated
community recommended that th'e
Agency convert the policy into a
regulation because they felt it might
ensure gnaterjconsistency and
predictability. While EPA'is taking steps
to ensure consistency and predictability
and believes thatjt will be successful.
the Agency will consider this issue and
will provide notice if it determines that
a rulemaking is appropriate.

IL Statement of Policy: Incentives for
Self-Policing

Discovery. Disclosure. Correction and
Prevention

A. Purpose

  This policy is designed to enhance
protection of human health and the
environment by encouraging regulated
entities to voluntarily discover, disclose.
correct and prevent violations of federal
environmental requirements.

B. Definitions
  For purposes of this policy, the
following definitions apply:
  "Environmental Audit" has the
definition given-hw* in EPA's 1986
audit policy on environmental auditing,
Le.. "a systematic, documented.
periodic and objective review by
regulated entities of facility operations
and practices related to meeting
environmental requirements."
  "Due Diligence" encompasses the
regulated entity's systematic efforts,
appropriate to the size and nature of its
business, to prevent, detect and correct
violations through- all of the following:
  (a) Compliance policies, standards
and procedures that identify how
employees-and agents are to meet the
requirements of laws, regulations.
permits and other sources of authority
for environmental requirements:
  (b) Assignment of overall
responsibility for overseeing compliance
with policies, standards, and
procedures, and assignment of specific
responsibility for assuring compliance
at each facility or operation:
                                                  130

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                  Federal Register / Vol. 60. No. 246 / Friday. December 22. 1995 / Notices
                                                                     66711.
   (c) Mechanisms for systematically
 assuring that compliance policies.
 standards and procedures are being
 carried out. including monitoring and
 auditing systems reasonably designed to
 detect and correct violations, periodic
 evaluation of the overall performance of
 the compliance management system.
 and a means for employees or agents to
 report violations of environmental
 requirements without fear of retaliation;
   (d) Efforts to communicate effectively
 the regulated entity's standards and
 procedures to all employees and other
 agents;    • "•
   (e) Appropriate incentives to  •
 managers and employees to perform in
 accordance with the compliance
 policies, standards and procedures.
 including consistent enforcement  ,
 through appropriate disciplinary.
 mechanisms: and
   (f) Procedures for the prompt and.
 appropriate correction of any violations.
 and any necessary modifications to the
 regulated entity's program to prevent
 future violations.
   "Environmental audit report" means
 the analysis, conclusions, and
 recommendations resulting from an'
 environmental audit, but does not
 include data obtained in. or testimonial
 evidence concerning, the environmental
 audit  :
   "Gravity-based penalties" are that
 portion of a penalty over and above the
 economic benefit.. i.e.. the punitive .
 portion of the penalty, rather than that •
 portion representing a defendant's
 economic gain from non-compliance.
 (For further discussion of this concept
 see "A Framework for Statute-Specific
 Approaches to Penalty Assessments".
 *GM-22.1980. ILS. EPA General
 Enforcement Policy Compendium).
   "Regulated entity" means any entity.
 including a federal, state or municipal
 agency or facility, regulated under
 federal environmental laws.

 C. Incentives for Self-Policing  .
 1. No Gravity-Based Penalties

  Where the regulated entity establishes
 that it satisfies all of the conditions of
 Section D of the policy. EPA will not
 seek gravity-based penalties for
 violations of federal environmental'
 requirements.

 2. Reduction of Gravity-Based Penalties
 by75%

  EPA will reduce gravity-based
 penalties for violations of federal
 environmental requirements by 75% so
 long as the regulated entity satisfies all
 of the conditions of Section D(2)
through 0(9) below.
  3. No Criminal Recommendations
    (a) EPA will not recommend to the
  Department of Justice or other
  prosecuting authority that criminal
  charges be brought against a regulated
  entity where EPA determines that ail of
  the conditions in Section D are satisfied,
  so long as the violation does not
  demonstrate or involve:
   (i) a prevalent management
  philosophy or practice that concealed or
  condoned environmental violations: or
   (ii) high-level corporate officials' or
  managers' conscious involvement in. or
  willful blindness to, the violating
   (b) Whether or not EPA refers the-   '
  regulated entity for criminal prosecution
  under this section, the Agency reserves
  the Tight to recommend prosecution for
  the criminal acts of individual managers
  or employees under existing policies
  guiding the exercise of enforcement
  discretion.

  4. No Routine Request for Audits:'
   EPA will not request or use an
  environmental audit report to initiate a
  civil or criminal investigation of the
  entity. For example. EPA will not
  request an environmental au'dit report in,
  routine inspections. If the Agency has
  independent reason to believe that a-
  violation has occurred, however. EPA
  may seek any information relevant to
 identifying violations or determining
•  liability or extent of harm.

 D. Conditions
 1. Systematic Discovery
   The violation was discovered through:
   (a) an environmental audit: or
   (b) an objective, documented.
 systematic procedure or practice
 reflecting the regulated entifvjs due
 diligence in preventing, detecting, and
 correcting violations. The reguli.ted
 entity must provide accurate and
 complete documentation to the Agency •
 as to how it exercises due diligence to
 prevent detect and correct violations
 according to the criteria for due
 diligence outlined in Section B. EPA
 may require as a condition of penalty
 mitigation that a description of the
 regulated entity's due diligence efforts
 be made publicly available.

 2. Voluntary Discovery
   The violation was identified
 voluntarily, and not through a legally
 mandated monitoring or sampling
 requirement prescribed by statute.  .
 regulation, permit, judicial or
 administrative order, or consent
 agreement For example, the policy does
 not apply to:
   (a) emissions violations detected
 through a continuous emissions monitor
 (or alternative monitor established in a
 permit) where any such monitoring is
 required:
   lb) violations of National Pollutant
 Discharge Elimination System (NPDES)
 discharge limits detected through
 required sampling or monitoring;
   (c) violations discovered through a
 compliance audit required to be
 performed by the terms of a consent
 order or settlement agreement •
 3. Prompt Disclosure
   The regulated entity fully discloses a
 specific violation within 10 days (or
 such shorter period provided by law)
 after it has discovered that the violation
 has occurred, or may have occurred,  in
 writing to EPA:

 4. Discovery and Disclosure
 Independent of Government or Third
 Party Plaintiff
  The violation must-also be identified-
 and disclosed by the regulated entity
 prior to:
   (a) the commencement of a federal.
 state or local agency inspection or
 investigation, or the issuance by such
 agency of an information request to the
 regulated entity;
  (b) notice of a citizen suit
  (cj the filing of a complaint by a third

  (d) the reporting of the violation to
EPA (or other government agency) by a
"whistleblower" employee, rather than
by one authorized to speak on behalf of
the regulated entity; or
  (e) imminent discovery of the
violation by a regulatory agency;

5. Correction and Remediation
  The regulated entity corrects the
violation within 60 days, certifies in
writing that violationsjiave been
corrected, and takes appropriate .
measures as determined By EPA to
remedy any environmental or human
harm due to the violation. If more than
60 days will be needed to correct the
violation(s). the regulated entity must so
notify EPA in writing before the 60-day
period has passed. Where appropriate,
EPA may require that to satisfy
conditions 5 and 6, a regulated entity
enter into a publicly available written
sgTwment.administrative consent order
or judicial consent decree,  particularly
where compliance or remedial measures
are complex or a lengthy schedule for
attaining and maintaining compliance
or remediating harm is required:

6. Prevent Recurrence
  The regulated entity agrees in writing
to take steps to prevent a recurrence of
the violation, which may include
improvements to its environmental
auditing or due diligence efforts;
                                                         131

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 66712
Federal Register  /  VoL  60,  No. 246 / Friday. December 22.  1995 / Notices  .
 7. No Repeat Violations,
   The specific violation (or closely
 related violation) has not occurred
 previously within the past throe years at
 the same facility, or is not part of a •
 pattern of federal, state or local
 violations by the facility's parent  .
 organization (if any), which have
 occurred within the past five yean. For
 the purposes of this section, a violation
 is:
   (a) any violation of federal, state or
 local environmental law identified in a
 judicial or administrative order, consent
 agreement or order, complaint, or notice
 of violation, conviction or plea
 agreement: or
   (b) any act or omission for which the'
 regulated entity has previously received
 penalty mitigation from EPA or. a state
 or local agency.
 8. Other Violations Excluded
  The violation is not one which (i)
 resulted in serious actual harm, or may
 have presented an itnminant and
 substantial endangerment to. human
 health or the environment, or (ii)
 violates the specific terms of any
 judicial or administrative order, or
 consent agreement.

 9. Cooperation
  The regulated entity cooperates as
 requested by EPA and provides such
 information as is necessary and
 requested by EPA to determine
 applicability of this policy. Cooperation
 includes, at a minimum, providing all
 requested documents and access to
 employees and assistance in
 investigating the violation, any
 noncompliance problems related to the
 disclosure, and any environmental  •
 consequences related to the violations. .

 E. Economic Benefit
  EPA will retain its full discretion to
 recover any economic benefit gained as
 a result of noncompliance to preserve a
 "level playing field" in which violators
 do not gain a competitive advantage
 over regulated entities that do comply.
EPA may forgive the entire penalty for
violations which meet conditions 1
through 9 in section D and. in tha
Agency's  opinion, do not merit any
penalty due to the insignificant amount
of any economic benefit
                     F. Effect on State Law, Regulation or
                     Policy
                      EPA will work closely with states to
                     encourage their adoption of policies that
                     reflect the incentives and conditions
                     outlined in this policy. EPA remains
                     firmly opposed to statutory
                     environmental audit privileges that
                     shield evidence of environmental
                     violations and undermine the public's
                     right to know, as well as to blanket
                     immunities for violations that reflect
                     criminal conduct, present serious
                     threats or actual hum to health and the
                     environment, allow noncomplying
                     companies to gain an economic
                     advantage over their competitors, or
                     reflect a repeated failure to comply with
                     federal law. EPA will work with states  .
                     to address any provisions of state audit
                     privilege or immunity laws that are
                     inconsistent with this policy, and which
                     may prevent a timely and appropriate
                     response to .significant environmental
                     violations. The Agency reserves its right
                     to take necessary actions to protect
                     public health or the environment by
                     enforcing against any violations of
                     federal law.

                     G. Applicability
                      (1) This policy applies to the
                     assessment of penalties for any
                     violations under all of the federal
                     environmental statutes that EPA
                     administers, and supersedes any
                     inconsistent provisions in media-
                     specific penalty or enforcement policies
                     and EPA's 1986 Environmental
                    Auditing Policy Statement
                      (2) To the extent that existing EPA
                     enforcement policies are not .
                    inconsistent they will continue to apply
                     in conjunction with *h'« policy.
                    However, a regulated entity that has
                    received penalty mitigation for
                    satisfying specific conditions under this
                    policy may not receive additional
                     penalty mitigation for satisfying the
                    same or similar conditions under other
                    policies for the same violation(s). nor
                    will this policy apply to violations
                    which Have received penalty mitigation
                    under other policies.
                    • (3) This policy sets forth factors for
                    consideration that will guide the
                    Agency in the exercise of its
                     prosecutorial discretion. It states the
Agency's views as to the proper
allocation of its enforcement resources.
The policy is not final agency action.
and is intended as guidance. It does not
create any rights, duties, obligations, or
defenses, implied or otherwise, in any
third parties.
  (4) This policy should be used
whenever applicable in settlement
negotiations for both administrative and
civil judicial enforcement actions. It is
not intended for use in pleading, at
hearing or at trial. The policy may be
applied at EPA's discretion to the
settlement of administrative and judicial
enforcement actions instituted prior to,
but not yet resolved, as of the effective
date of this policy.

H. Public Accountability

  (1) Within 3 years of the effective date
of this policy. EPA will  complete a
study of the  effectiveness of the policy
in encouraging:  -     •	
  (a) changes in compliance behavior
within the regulated community,
including unproved compliance rates;
  (b) prompt disclosure and correction
of violations, including timely and
accurate compliance with reporting
requirements;
  (c) corporate compliance programs
that are successful in preventing
violations, improving environmental
performance, and promoting public
disclosure:
  (d) consistency among state programs
that provide incentives  for voluntary
compliance.
  EPA will make the study available to
the public.
  (2) EPA will make publicly available
the terms and conditions of any
compliance  agreement reached under
**"f policy, including the nature of the
violation, die remedy, and the schedule
for returning to compliance.

L Effective Date  •

  This policy is effective January 22,
1996.
  Dated: December 18.1995.
Steven A. Herman.
AstistantAdtninisaator for Enforcement and
Cooiplianco Assurance.
[FR Doc, 95-31146 Filed 12-21-95:8:45 affll
                                                         132

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Audit Policy Interpretive Guidance
             January 1997
     Office of Regulatory Enforcement
   U.S. Environmental Protection Agency
           Washington, D.C.
               133

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                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                              WASHINGTON, D.C. 20460
                                    JAN 151997



MEMORANDUM

SUBJECT:   Issuance of Audit §9licy Interpretive Guidance

FROM:      Steven A.
     OFFICE OF
  ENFORCEMENT AND
COMPUANCEASSURANCE
 TO:          Regional Administrators
              Assistant Attorney General, Environment and Natural Resources Division

       Attached is the :HAudit Policy Interpretive Guidance':that the ORE-led "Quick Response
 Team" (QRT) has developed since issuance of the Audit Policy, formerly known as the policy on
 "Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations,M60
 Fed. Reg. 66706 (December 22,1995).

       As you may recall, we established the QRT to make expeditious, fair, and nationally
 consistent recommendations concerning the applicabile of the policy to specific enforcement
 cases. This Interpretive Guidance builds upon the July 1994 "Redelegations" effort, which
 focused Headquarters' involvement on case-specific matters raising issues of national significance
 e.g., novel interpretations of the Audit Policy). The attached guidance is based upon nationally
 significant issues that have confronted the QRT in consulting with Regions on more than two
 dozen cases over the past several months. During the process of evaluating these cases, the QRT
 has identified numerous interpretive issues that could benefit from further guidance.

        This Interpretive Guidance document - presented as a series of generic Questions and
 Answers - is intended to aid both the government and the regulated community in implementing
 the Audit Policy. Within the next two weeks, we anticipate that it will be publicly available via
 the Internet, at http'V/esJnel gov/oeca/epapolguid. html, and through the Audit Policy Docket at
 Waterside Mall in Washington D.C. (202-260-7548). The QRT welcomes comment on this
 Interpretive Guidance and suggestions for additional interpretive issues that may be appropriate
 for resolution in future guidance. As new issues warranting guidance arise, ORE will issue
 addenda to this Guidance and will place any such updates in these two locations. We also are
 working to make all of these items-easily accessible on the Agency's Local Area Network (LAN)
  system and we will apprise you of our progress in that regard.
                                            134

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      I very much appreciate the efforts of the Audit Policy QRT in developing this guidance,
and I encourage you to take advantage of the QRTs extensive experience and expertise in dealing
with Audit Policy issues. As you will note from the membership list attached to the end of the
Interpretive Guidance, the QRT is led by the Office of Regulatory Enforcement and is comprised
of senior staff and managers from all civil enforcement media, the criminal enfbrcemenprogram,
the federal facilities program, the OECA compliance and policy offices, two Regions, and the
Department of Justice. The broad participation on the QRT. its senior level of involvement, and
its intensive effort to resolve these issues swiftly in the attached guidance, all demonstrate the
strong commitment of OECA and the Clinton Administration to ensuring that implementation of
the Audit Policy continues to be an even greater success in the months ahead and beyond.

       I encourage you to contact me, or to have your staff contact Gary A. Jonesi (Audit QRT
 Chair) at 202-564-4002, if you have any questions regarding this Interpretive Guidance.

 Attachment

 cc:     OECA Office Directors
        ORE Division Directors
        Regional Counsel
        Regional Enforcement Coordinators
        Chief Environmental Enforcement Section, Department of Justice
        Deputy & Assistant Chiefs, Environmental Enforcement Section, Department of Justice
        Audit Policy Quick Response Team
                                           135

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                                   Explanatory Note
                                                                                ^
This document was prepared by EPA's Audit Policy "Quick Response Team" (QRT). The QRT
is chaired by the Office of Regulatory Enforcement, and it is charged with making expeditious,
fair, and nationally consistent recommendations concerning the applicability of the December 22,
1995 policy on "Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of
Violations" (referred to in mis document as the final Audit Policy) to specific enforcement cases.
A copy of the final Audit Policy is provided as Attachment 1 to mis document

As of the date of mis document, the QRT has evaluated more tan two dozen cases for potential
Audit Policy application, most of which have resulted in significant gravity-based penalty
reductions. Attachments 2 and 3 summarize some of those cases in the "Audit Policy Update"
newsletters. During the process of evaluating these cases, the QRT has identified several
interpretive issues mat could benefit from further guidance. This interpretive guidance document,
presented as a series of Questions and Answers (Qs and As), is intended to aid in implementation
of the Audit Policy. It includes discussion of many of the most significant issues raised to the
QRT's attention.  The QRT welcomes comment on mis document; and on additional interpretive
issues that may be appropriate for resolution in future guidance. A list of QRT members is
presented in Attachment 4.

This document sets form guidance for the Agency's use in exercising its enforcement discretion.
It is not final agency action and it does not create any rights, duties, obligations, or defenses,
implied or otherwise, in any third parties.         -

This document can be found on the internet at http://es.mel.gov/oeca/epapolgdd.html, and in
EPA's Audit Policy Docket located at the EPA Headquarters Air Docket, at Waterside Mall in
Washington, D.C. (202-260-7548). Revisions or additions to this guidance also will be made
publicly available at these two locations.                                ''
                                               tfffff  /fttft$tft   ff f ftft
                                     136

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                        Audit Policy Interpretive Guidance


                            TABLE OF CONTENTS


Summary of Questions and Answers '  ... ......


Interpretive Issues:


      Voluntary Discovery (Section D.2. of Audit Policy)


            Discovery of Violations During Audits Required By Settlements ..... ............      l
                                                            1
            Discover of Violations Under Clean Air Act Tide V Permit Applications ......     2


      Prompt Disclosure (Section D3. of Audit Policy)


            Consolidation of Similar Disclosures. ................ . .................................          3

            Submitting Information Without Disclosing Specific Violations ........ : .........      4
              • •             /
            Requirement For Disclosures To Be In Writing and to EPA ............ '. .........       5

            Definition Of When A Violation "May Have Been Discovered" .................       6
     ;
            Disclosure Before Violations Occur , ........ . ......................... ...... ..........           7


      Repeat Violations (Section D.7. of Audit Policy)


            Determining Whether Repeat Violations Bar Penalty Mitigation ....... ..... .....      8

            Informal Enforcement Responses and Repeat Violations . ................. . .......       9


      Applicability (Section G. of Audit Policy)


            Further Penalty Reductions Beyond The Audit Policy ....... ................. .-•       10
                                                    r            •  \.
            Inconsistencies Between Audit Policy and Statute-Specific
            Penalty Policies .............. . .............................. •»..-: ...................             n
            Applicability of AuditPolicy in Litigation ...................................... ,-•          12
                                       137

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             Degree of Confonnance to The Audit Policy's Conditions

      Miscellaneous

             EPA Inspections While Audits Are Being Performed	
                                                    13
             Impact Of Prior Owner or Operator's Pattern of Violations On Subsequent
             Owner/Operator's Eligibility Under The Audit PolicyJ.	

             Resolving Audit Policy Determinations Through Informal Or
             Formal Means	.'.	
Background Information:
                '                         .s
      Policy (^Incentives for Self-Policing: Discovery,
      Disclosure^Conrection and Prevention of Violations,*
      60 Fed. Reg. 6&SQ6 (December 22,1995),	
       Audit Policy Update, VoVX No. 1 (April 1996): lists
       disclosures and settlements ussier the Audit Policy,'.
       for making disclosures, etc.
                                                   14
                                                   15
                                                   16
                                                 entl
       Audit Policy Update (January 1997V1JS
       under the Audit Policy, EPA conjactsfor i
               losures and settlements
                  ; disclosures, etc......
      List of Audit Policy'
      Members	
: Response Team" (QRT)
Attachment 2


Attachment 3


Attachment 4
                                          138

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-v
                                      Summary of Questing and Answers

  Belowjsasumiiiary ofkeypoto^^                                               Not every rationale.
  supixatmg reference, and subtlety associated wim these issues are inchided in dris summary Reader* am adv^CnT
  sec Ibe full textof the Qs and As immcdiatdy following tins summary.                   **««« are aovisea B>

  1.      Canavblatorbedeemedtoliavevoh^^
          djmngtte condartof acomplia^
          Where a violator - wifiiout am^ legd oMgati^
          auditor to aityfc^ or mfc«^
          described In Section ttD.4. of me policyX an oMgatkm to conduct swh an audit wim the sanw material
          scope and pmppse can be incoipcj^
          disqualifying violations discovered under die axiitfiDmobtainmg penalty mitigation uirfertibe Audit Policy
          (See Question # Ion page 1 for more detailed explanation.)
          Can violations identified m a reqiriredcc^K^
          Clean Air Act Tide V operating permit be eligible fix- penalty mitigation imder me final Audit Policy?

          Generally no, because discover of violations in these circumstances is not aM^deredvohmtaiy in light of
          the comprehensive Tide Vrequiimerils to m^
          permit Where an applicant can demonstrate that its inquiiy exceeded its obUgations under 40 C.F.R. §70.5,
          however, EPA may on a case-by-case basis consider the discovery of violations during such an inquiiy to be
          vohmtary and rjotentialty eligible for penalty mitigation under the policy. Where permit application
          requirements under other enviromiental statutes do not im
          about, analyze, and report violations, violations discovered pnraiant to «aich permit application n«qBi
          may qualify as vohmtary discovery and, thus, are poteim^lfy eligible for Audh Policy penalty mitigation.
          (See Question #2 on page 2 for more detau^ explanation.)
  3.      Tn order in rnmply witfi 1fhf. pfyimpt ^''SpVvBlff TgqniFeme"^ wngt «" gnfrty planning ffi p^ rfnrm an aiirfif nf
          numerous giniily facilities send a gg^ialf notification to EPA within 10 days of discovering each violation,
          or can me violator consolidate its disclosures and submit mem to EPA later?
                                                                  /
          A violator may consolidate its «"fr"issfon <>fe«tf«"' «"%i?"tfk«" i" ^*A, N>* 
-------
5.      Why must disclosures be in writing and to EPA?

        This protects both EPA and the submitter by eliminating any uncertainly about die timing and content of the
        disclosure, and it expedites EPA's process of evaluating claims for penalty mitigation. (See Question #5 on
        page 5 for more detailed explanation.)

6.      At what point does an entity have to disclose to EPA that a violation "may have occurred?"
                           ,                                                      /

        The regulated entity must disclose violations when mere is an objectively reasonable factual basis for
        concluding that violations may have occurred.  Where the facts underlying the violation are clear but the
        existence of a violation is in doubt due to the possibility of differing interpretations of the law, the regulated
        entity should disclose the potential Eolations.  (See Question #6 on page 6 for more detailed explanation.)

7.      If potential violations are disclosed before they occur, are they eUgiblefcr penalty reductions under me final
        Audit Policy?
                                     \
        Yes, provided the regulated entity uses all best efforts to avoid me violations. The policy is designed to
        encourage disclosure as expeditioush/ as possible. This can be as late as 10 days after discovery that a
        violation occurred or may have occurred, or as carry as when a compUance problem is identified. Once the
        violation actually occurs, EPA may men mitigate any potential penalty. (See Question #7 on page 7 for more
        detailed explanation.)                                     -

8.      How does EPA determine if disclosed violations are repeated wimm the 3-year time frame specified in the
        final Audit Policy's repeat violations provision?                        •
                                     '                                   f

        The 3-year period begins to run when the government or third party has given the violator notice of a specific
        violation (e.g.. through a complaint consent order, notice of violation, receipt of an inspection report, citizen
        suit, receipt of penalty mitigation through a compliance assistance project). If the same type of violations or
        closely related violations occur at the same faculty within three years of such notice, they are repeat violations
        and are meUgiWe for penalty mitigation under the final Audit PoHcy. (See Question #8 on page 8 for more
        detailed explanation.)

9.      Do non-penalty enforcement responses such as notices of violation or wanimg fetters constitute a previous
        violation for purposes of me policy's repeat violations provision?
                                                      "''           '
        Generally yes, as long as the notification identifies specific violations and the allegations are not later
        withdrawn or defeated. (See Question #9 on page 9 for more detailed explanation.)
                                   V                  • .                           *             ~"
10.     In cases where a 75% gravity-based penalty reduction is appropriate under the Audit Policy, can the penalty
        be further reduced in consideration of supplemental environmental projecte (SEPs), go^
        factors as justice may require?
                                   V"
        Yes, as long as such further penalty mitigation is for activities mat go beyond the conditions outlined in the
        final Audit Policy, and provided that economic benefit of noncompliance is recovered as required by existing
        Agency policies. (See Question #10 on page 10 for more detailed explanation.)

11.     Where statute-specific penalty policies provide for different penalty reductions in cases of self-policing or
        voluntary disclosure, which policy takes precedence?

        The final Audit Policy takes precedence over any other policies that offer penalty reductions for satisfying the
        same conditions (e.g.. the voluntary discovery, disclosure, and correction of violations), hi most
        circumstances, the Audit Policy will offer more generous incentives.  (See Question # 11 on page 11 for more
        detailed explanation.)              •


               3*ra^                                     -,;'

                                                 140

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12.    T^isuseoffcemialAudftPdicyliinitedto
       adjudicatory proceedings?             ,                                   —*-rr

       P1!!^^*1?^?^"1^
                              *   "            Agency resources. IJniin^ use of me polky to settlement also
       reduces transaction costs for tbe regulated community. Making ittbe object of adversarial litigation is
       incoosislaitwifliftiscareMyconsidcmlappDach^                                (SeeQuestion
       #12 on page 12 for more detailed explanation.)

13.    Must the specific coodhions of the final AiiditP<>ficyte met m order to qualify for p
       consistency wifli tbe general thrustof die polky sufficient ( fi^ \diere discl<>surc of violatioiis occurs wifliin
       30 days hit not within the10-dajr period specified in die policy)?
                                                              ^
       Ite specific conditions must be met Ifthey are not met, EPA instead will utilize me flexibility provided
       under its statute-specific penalty poKcies to rtojgnize good faifliefiEbrts ami de*enninen» extent to whi<±
       penalty reductions arc appropriate. (See Question #13 on page 13 fix- more detailed explanation.)
       f  .          v                      •                                                i
14.   . Should me government agree to TO mspections, fewer inspections or
       during the time periods ID which an audit is being performed?

       Although not explicitly addressed in me final Audit Policy, EPA's longstanding policy is not to agree to limit
       its lion-penalty enforcement authorities as a provision of settlement or otherwise. Whfle EPA may consider
       suchafadlitytobealOT^inspecticmprior^
       when to conduct an inspection does, and should, remain a matter of Agency discretion. (See Question#14 on
       page 14 for more detailed explanation.)

IS.    If an owner or operator discxjvers at its facility a violation that began whra
       operated by^a previous entity, can the subsequent owner/operator receive penalty mitigation under the final
       Audit Policy? Can tbe previous owner/operator also obtain such mitigation?

       In both cases, me regulated entity must meet all conditions in u^mial Audit Policy, including the requirement
       lor prompt disclosure. If there has been an arm's length tiansactkm between the entities and u^
       considered separate, mere may be situations where a subsequent owner/operator can receive penalty
       mitigation wh^ the previous owner/operator cannot ( e.g.. where the subsequent owner discloses violations
       promptly to EPA and me previous owner had not disclosed such violations). Separate entities are considered
       independency, and applicability of me policy is based on the merits of each individual entity's actions. (See
       Question #15 on page 15 £br more detaifcd explanation.)

16.    Must aU penalty mitigaticm based upc« application of me fmal Audit Policy be efifec^^
       unifcxmtypeofoxxumentsuchasaformalsetdementagreeinenloris
       mechanisms such as informal letters?

       Basting Agency policies determine whether a formal enforcemert document such as a consent order is
       needed, or whether an informal letter^vfll suffice.  Generalfy,enfc*ceablec*ders are used unless mere w
       pendmgenfMcement action, no penalty, and «>outstan(!ing compliance obfigations. (See Question #16 on
      . page 16 for more detailed explanation.)
                                                               ^^

                                                 141

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#1: Discovery of Violations During Audits Reqqjred. fly Settlements

Q:     Can a violator be deemed to have "voluntarily" discovered hs violations, and thus potentially
       be eligible for penalty mitigation under tile final Audit Policy, where the violations are
       discovered during the conduct of a compliance audit that is required as part of a binding
       settlement fe.g~ in a consent decree or consent agreement)?
          \                                                            •
A:     Yes, but only under certain circumstances The final Audit Policy requires discovery of violations to
       be voluntary in Older 1O obtain dwy penalty mitigafk'P, and it defines nigh vplimfaritv>g«; y> 33 fc>
       exclude situations where the violations are "discovered through a compliance audit required to be
       perfonned by the tenns of a consent order or settlement agreement" 60 Fed Reg. 66706,66708
       (Dec. 22,1995). This language, however, should not be read in isolation, because doing so would
       unduly preclude penalty mitigation under the policy and cieate a significant disincentive lor fiiture
       settling patties to bind themselves in settlement documents to doing compliance audits.  In the same
       section of the final policy, two key goals are expressed: (1) to encourage me conduct of audits; aod  ,
       (2) to "reward those discoveries thatme regulated entity can legitiniately atnibute to its own
       voluntary efforts."  Ii at 66708.

       Where a violator—without any legal obligation to do so — already fa*? committed to conducting a
      . compliance audit prior to anv finmal crmfonnalemljroemeflt response fe.g..«Mnplairt filing or
       other circumstance described in Section ILD.4. of the policy), an obligation to conduct such an audit
       with the same material scope and purpose canoe incorporated into a binding settlement with EPA
       without automatically disqualifying violatioris discovered under tbe audit finwnc4)tainmgpendty
       mitigation under the Audit Policy.1 hi such cases, EPA should describe the voluntary nature of the
       audit in the settlement, document, so mat it is distinguishable from omer provisions that are not
       eligible for penalty mitigation under tie pohcy. By allowing audit provisions in settlements to be
       potentially eligible for penalty mitigation in these limited circumstances, EPA is able to shape the
       content and timing of audits, ensure UKirperfonnarK«mrough enforceable terms, and more
       effectively achieve me goals of thefinal policy.               \         -
       1  Where there is any indication that the audit is less than completely voluntary ( e.g.. •
       the violator committed to doing an audit after some sort of enforcement response as noted
       above, where the violator is a small business and received penalty credit under EPA's May
       1995 Supplemental Environmental Project (SEP) policy, etc.), the violations discovered as
       a result of the audit are not voluntary and are not eligible for penalty mitigation under this
       policy.

                                                      142

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#2; Discovery of Violations Under Clean Air Act Titfe V Permit AppKr«rim»«

Q:     Can violations or potential violations that are identified in a required compliance certification
        accompanying an initial application for a dean Air Act (CAA) Tide V operating permit be
        eligible for penalty mitigation under the final Audit policy?
          *    - •              f                                    ^
A:     Generally no, because lie manner in which such violations arc discovered normally wiH not satisfy
        the policy's requirement of "voluntary discovery."  Under die final Audit Policy, the violation must
        be Identified voluntarily, and not through a legally mandated monitoring or sampling f^pmmfnt
        prescribed by statute,: regulation, permit, judicial or aAnmigtrariw fmfrr, i\f r«ny»nt agreement" 60
        Fed. Reg. at 66711.  The regulations implementing TifleV of the CAA require applicants to analyze
        comprehensively and describe completely the source's enmpKjjn^ status, 40 CJFJR. $ 70^(cX8), and
        to include in the myngd compliant*; ri»rfifi<>flrirtn a ghrt»m<^if maf m* ^yrt'fiT-aerinit program, the Clean Air Act
        Add Ram permit program, the Safe Drinking Water Act UndergrwimlligectMnCcMirol program)  do
                   similarly
            rit^U^on stage, violations discpvenxi puisiim
        quaUfy aVvoluntaiy discovery and, thus, are r»tBntiaTlyeBgfl>leforAudhPoK
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#3: Copon
Q:     In order to comply with the prompt disclosure requirement under the final Audit Policy, must
        an entity planning to perform an audit of numerous similar facilities send a separate
        notification to EPA within 10 days of discovering each violation, or can the violator
        consolidate hs disclosures and submit them to EPA later?
                                                               i  \             • '
A:      Consolidation of disclosures is acceptable in certain circumstances, provided the Audit Policy's
        "pranpt disclosure" requirement is met This provision recognizes EPA's need to have dear and
        timely notice of violations, so mat the Agency can respond quickly and appropriately to potential
        health or environmental risks and can accurately evaluate a conuiany's compliance status.  60 Fed.
        Reg. at 66708. Prompt disclosure is also evidence of the regulated entity's good failhrn wanting to
        achieve or return to compliance as soon as possible.  60 Fed Reg. at 66708-66709. Hie policy
        reqirirestnat disclosure be made within 10 days of discovery mat a violation has occuned or may
        have occurred, except where an applicable statute or regulation requires reporting in a shorter time
        10 days is not practical because the violation is complex and^compliance cannot be determined within
        that period," as long as *lhe circumstances do not present a seriom threat and the regulated entity
        meets its burden of showing mat the additional time was needed to determine compliance status." 60
        Fed Reg. at 66708.

        EPA encourages the conduct of intensive company-wide or mum'-facuity audits, and a consolidated
                                appropriate "» cerfari« ^irrnTngtaTMyg Specifically, although a
       consolidated reporting arrangement may take many forms depending on the duration and scope of the
       proposed audit, the audit must be completed expeditiousfy and the reporting arrangement must
       ensure that EPA receives sufficient specific information up front to allow it to respond to any health
       or environmental risks that may stem from the violations. At a minimum, this must include the
       identity and location of all facilities foflt may raise similar tympKinny concerns and a description of
       the potential violations. (EPA recogniTcs that the description of potential violations may be generic
       in nature where the numerous facilities being audited ccvduct similar operations.) Providing this
       minimal information within 10 days should not be an undue hardship, and it wfll be a significant help
       to EPA in its efforts to process requests for Audit Policy penalty mitigation in an expeditious
       manner.   '                  '

       As long as the initial disclosing cntitahis mis minimum inform arinn atu| complies Wltfa tfag time
       period set out in the final Audit Poh'cy, the Agency recognizes that the prompt disclosure requirement
       can allow for such disclosures to be supplemented at a later time( e.g.. me audit results concerning
       the suspected violations can be consolidated into a subsequent submission to EPA), hi such cases,
       EPA would consider the prompt disclosure requirement to have been met because the timeliness of
       disclosure would be based upon the initial submission of information. The Agency notes, however,
       mat it wifl consider disclosures to be untimely where factual inferences can be drawn about other
       probable violations (e.g.. where the violator's operations .and practices are homogeneous in nature) if
       the above-mentioned minimum information regarding such violations are not disclosed within flie 10-
       day period specified in the final Audit Policy.
                                            144

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14s Snbmittin« In
                          11 Wttfaout Dfetlftting Sn
Vfala+tAM
Q?
A:
       Do sobmteJoot of information required by law (ejt.. late submittal of an EPTPA
       reporting form, late submittal of a Clean Water Act discharge monitoring report)
       meet the requirements for disclosure under the final'Audit Policy where snch    -*<*
       submissions are unaccompanied by a written disclosure that a violation has or may
                                        ''           """"
       have occurred?/-^-- -:
                       .••" i
       No. Under the final Audit Policy, an entity mustfulfy disclose that specie violations
       occurred or may have occurred, and such disclosure must be made promptly within the
       specified time period in order to be eligible for penalty mitigation. 60 Fed. Reg. at
       66711.  The conditions of the policy are not fulfilled by the mere disclosure of facts or
       other information. The policy's explicit reference to "specific violations1' is meant to
       require clear notice to EPA mat a compliance problem has occurred or exists, and
       protects the regulated entity by eliminating any otoot as to whether a disclosure has
       been made. Late submission of required information without any accompanying
       disclosure concerning the existence of possible violations does not constitute ^full
       disclosure of a specific violation" under the Audit Policy. 'Full disclosure of potential
       violations is necessary for EPA to get "clear notice of the violations and the
       opportunity to respond if necessary, as welt as an accurate picture of a given facility's ,
       compliance record.*  60 Fed. Reg. at 66706. Without a specific reference to the fact
       mat die mfbrmation is being submitted late and that it constitutes or may constitute a*
       violation, EPA will not have clear notice of the potential violations and its ability to
       respond to potential threats may be hampered.
                                     145  -

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fS; Requirement For Disclosures To Be In Writing and to EPA

Q:    Why most disclosures raider the. final Audit Policy be in writing and to EPA?

A:.   Disclosures under the Audit Policy must be "in writing to EPA,* 60 Fed. Reg. at
       66711, because prompt written disclosure to EPA gives it "clear notice of the
       violations and the opportunity to respond if necessary, as well as an accurate picture of
       a given facility's compliance record." 60 Fed. Reg. at 66708.  Also, the policy
                 mat government resources are limited. It serves the interests of both the
       disclosing entity and the government to be absolutely clear about die full character and
       extent of the disclosure.  Otherwise, unnecessary energy is expended in determining
       whether an oral disclosure occurred.  Also, requiring disclosures to be in writing and
       to EPA has die effect of expediting EPA's process of evaluating claims for penalty
       mitigation under the final Audit Policy. Where EPA receives oral notice of violation
       from those who would like AuditPpUcy penalty mitigation. Agency staff are
       encouraged to advise the disclosing entity as to the importance of putting the disclosure
       in writing.              •-,-,  ... ..;•.            .                ,
                                 146

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#fr Pefmition Of When A Violation "Mav Have Qcmrr^*

Q:    At what point does a party have to disclose to EPA that a violation "may have
       occurred** in order to qualify for penalty mitigation under the final Audit Policy?

A:     Thefinal AuditPoIicyrequires that a regulated entity fully disclose "a specific violation
       within 10 days (or such shorter period provided by law) after it has discovered that me
       violation has occurred, or may have occurred,^ writing toEPA." 60 Fed. Reg. at 66711
       [emphasis added]. The policy explains that the Agency added the phrase "or may have
       occurred" to respond to comments received on the Interim AuditPoIicy, and to clarify
       mat where an entity has some doubt about the existence of a violation, the recommendedx
       course is for itto disclose and allow the regulatory authorities to make a definitive
       determination about whether me violation occurred. 60 Fed. Reg. at 66709.
                             '                  N
       The regulated entity should report possible violations to the Agency wheri there is a
       reasonable basis for concluding that the violations have occurred. Two components go
       into this analysis: (1) an evaluation of known facts; and (2) application oflegal
       requirements to such facts. Absolute factual and legal certainty is not necessary in order
       to require disclosure under the policy. This is particularly true where mere is a reasonable
       certainty as to the facts underlying potential violations. For example, if a company
       discovers a release violation due to inadequate design of equipment usedat one facility
       and mis same equipment is used at other faculties it owns throughout tile country, an
       inference can bedrawn mat other violations may have occurred and the company should
       disclose these other possible violations to the Agency at the same time it discloses the
       initial violation.  Although additional data concerning the other facilities may be disclosed
       to EPA more than 10 days later, the initial disclosure should include information as to the
       identity, location, and nature of the suspected violations at such other facilities (see
       Question and Answer #3 above). In this situation, the company should investigate its
       other facilities to verify whether the violations actually occurred, perform any necessary
       corrective measures or remediation, and comply with the other criteria articulated in the
       Audit Policy in order to receive penalty mitigation for these other violations.

       Even where the facts underlying a possible violation are clearly known, there may be some
       doubt as to whether such facts give rise to a violation as a matter of law (§&„ due to
       differing legal interpretations). As long as there is an objectively reasonable factual basis
       upon which to base a possible violation, disclosure should occur and EPA win make a
       definitive determination concerning whether such facts actually present a violation of law.
                                           147

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#7: Disclosure Before Violations Occur
                                                     **

Q:    If potential violations are disclosed before they occur, are they eligible for penalty
       reductions under the final Audit Policy?

A:    Generally yes. For example, if the violations cannot be avoided despite the regulated
    '   entity's best efforts to comply fe.g.. where an upcoming requirement to retrofit a tank
       cannot be met due to unforeseeable technological barriers), EPA may mitigate the gravity-
       based penalty once the violation actually occurs.

       The policy requires violators to disclose violations fully and promptly, and it defines such
       prompt disclosure generally to require disclosure "within 10 days (or such shorter period
       provided by law) after it has discovered mat the violation has occurred, or may have
       occurred." 60 Fed. Reg. at 66711. The use of the past tense in this phrase reflects EPA's
       recognition of the most common types of disclosure that occur, L&, involving past
       violations (as opposed to possible future violations). Nevertheless, the essence of this
       requirement in the policy is on prompt self-disclosure of compliance deficiencies. The
       language requiring disclosure generally "within 10 days'* should not be read to preclude
       disclosure as early as possible, including before the violation actually has occurred.  Once
       the violation actually occurs, these violations may be eligible for Audit Policy penalty
       mitigation where a violator can establish to EPA's satisfaction based on objective evidence
       mat it has employed all best efforts to avoid the violations. By allowing for disclosure as
       soon as possible, the policy may even encourage potential violators to work with EPA in a
       way that can minimize or eliminate the compliance concern before it actually occurs.
                                              148

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#9: Determining Whether Repeat Violations Bar Penalty Mftfanfan

Q:     How does EPA determine if disclosed violations fall within die 3-year time period specified in
        the final Audit Policy's repeat violations provision?
                                                    /
A:     Violations arc conadered to be repeat vid^
        subsequently discovered and disclosed violations are: (1) the same or closely related to the original
        violations and have occurred at the same fealty wWimme past three years; or (2) part of a pattern of
        federal, State, or local violations by the company's parent wganization, if aiy.wimin the past five
        years. 60 Fed Reg. at 66712. Ttepurpc)se of the rqjeatviolatic)ns provision in the policy is to
        "deter irresponsible behavior and protect the public and environment" 60 Fed. Reg. at 66706. It
        also "provides companies with a continuing incennve to prevent violatiais,wimoat being un&ir to
        regulated entities responsible for managing hundreds of facflities."  60 Fed. Reg. at 66706.

        Two quedjms mnstlhe answered in n«w «n A^frmm^ yhftfar ihe violations are repeat violations
        ineligible for penalty mitigation under the final Audit Policy :(1) when the 3-year period begins; and
        (2) whether the violations which are disclosed, and far ^^wldch the vwlator seeks penalty mitigatioii,
        M within me subsequent 3-year period. As to the ; first question, the 3-year period begins to run
        when me violator first lecerves notice of the original violations. 3 Such notice can take several forms,
        mchding notification by EPA or a State or local agency thrcnigh receipt of a judicial or
        administrative order, consent agreement or order, complaint, conviction or plea agreement, notice of
        violation such as a letter or inspection report, notice during an inspection or even thrwigh a third
        party complaint •(&£• in a citizen suit). A violator also may be put on notice of particular
        environmental violations when it obtains penalty mitigation for such violations from EPA, a State, or
        a local agency (fix. under EPA's Small Business Compliance Incenthre policy ). As noted in the
        final Audit Policy, these circumstances cdlectrvefy"ideWhVsituatiorismwMch me regulated
                ity fata had t^tar notice nf it; nntvmmplianr^ ^nrj jtn nppnfhmity tn cnnect " • fiO  FftH Reg at
        66709. Where a government or third party has given such rwticeofnorKXMnpUance,thesameor
        closer/ related violations cannot be repeated within the subsequent 3-year period following such
        notice. Thus, the 3-year period begins to run when such clear notice of noncomph'ance is received,  4
        without regard to when the original violations cited in that notice actually occurred.
                      • '   ,    '    -^    /
                                                                          ,/
        As to the seccttlqiestic^ EPA locks to whether the disclosed violation         occurredvn&m
        the 3-year period following me original noticeAnitigation.  If the violations occurred within this
        period, they would be considered repeat violations and would not -be eligible for penalty mitigation
        under the policy because corrective measures shcidd have rxevented such a recuirence. If, however,
        mose violations occurred either before the original notice of noncomph'ance was received by me
        violator or after the 3-year period running from the original notice, they would not be considered
        repeat violations under the final  Audit Policy.  Thus, repeat violations are determined by the date
        that such subsequent violations occur, without regard to when notice of such subsequent violations
        is given to the violator.
        3 Typically, the Agency wffl provide written notice of violations because it recognizes the
        significant benefits to providing such notice in writing, including the minimization of uncertainty
        concenimg when such notice was received and hs contents.

        4 mdetermirring whether a "pattern of violation" has c>ccunedwithm the past i^ years,
        notice of earlier violations is less relevant The inquiry mto whemer a pattern exists more  t
        appropriately focuses on die dates that all violations actually occurred.
                                                  149

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#9: Informal Enforcement Responses and Repeat Violations

Q:    Do non-penalty enforcement responses such as notices of violation or warning letters
       constitute a previous violation for purposes of the policy's repeat violations
       provision?        ^

A:     Generally yes. The repeat violations provision defines such violations to encompass
       formal and informal enforcement responses, and nonenforcement responses mat result in
       penalty mitigation. 60 Fed. Reg. at 66712 (specifically including a reference to any
       violation identified in a"... notice of violation.") The common theme is that a
       government entity has notified the violator that it believes a violation has occurred, and, as
       a result, the government reasonably can expect the regulated entity to take whatever steps
       are necessary to prevent similar violations.
                                                                  \
       Notices of violation (NOVs) and warning letters may be worded in many different ways
       (e.g.. sometimes alleging particular violations and sometimes speaking only generally in
       terms of an upcoming need to comply with a new requirement). The tide or caption on
       such documents is not necessarily dispositive for purposes of the repeat violations
       provision.  The substance of theiNOV, warning letter, or other correspondence — usually
       found in the text of such documents - determines whether it provides notice of an alleged
       violation. If such documents give the regulated entity notice of allegations of specific
       deficiencies in compliance and those allegations are not later withdrawn or defeated, any
       subsequent violations would be considered repeat violations if they occurred within the
       time periods outlined in the final Audit Policy. If, however, the substance of the document
       merely provides a prospective statement of new requirements not yet violated ( eg.f in a
       compliance assistance guide), the notice or letter would not be considered an enforcement
       response for purposes of the repeat violations provision.
                                         150

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#10; Further Penalty Rednctions Bevond The Anrifr P^
     i                   '                    -
Q:    In cases where a 75% gravity-based penalty reduction is appropriate under the final
       Audit Policy, may the penalty be further reduced in consideration of supplemental
     .  environmental projects (SEPs), good faith, or "other factors as justice may require11
       as long as any economic benefit of noncompliance (EBN) B recovered?

A:     Where a 75% gravity-based penalty reduction is appropriate under the final Audit Policy,
       further penalty reductions may be obtained for activities that go beyond me specific
       conditions required under the final Audit Policy.  For example, further reductions
       generally may be warranted where a violator agrees to undertake a supplemental
       environmental project (SEP) and the project meets the criteria established for SEPs in the
       Agency's SEP Policy. The Audit Policy, however, precludes "additional penalty
       mitigation for satisfying the same or similar conditions." 60 Fed Reg. at 66712. Thus, if
       the particular project mat the violator proposes to undertake as a SEP must be carried out
       in order to receive a penalty reduction under the audit policy, additional credit may not be
       given under tile SEP Policy. For example, where EPA determines mat an audit must be
       carried out at a large complex facility in order to prevent a recurrence of violations, SEP
       credit may not be provided for conducting this audit Note, however, that SEP credit
       could be provided if EPA determined that such an audit was not necessary to prevent a
       recurrence of violations.                  .
           i                                        •          •
       Similarly, additional penalty reductions for goodfaith and "other factors as justice may
       require" may be provided only where the specific activities justifying those reductions are
       not required in order ,to receive a 75% penalty reduction under the Audit Policy. Thus, the
       prompt disclosure of a violation ordinarily would not qualify a company for additional
     '  good faith penalty reductions since the disclosure clearly is required by the Audit Policy.
       On the other hand, a violator that takes steps to correct and remediate a violation in a
       manner that is above and beyond the steps normally expected in order to qualify for
       mitigation under the Audit Policy (eg., quicker or more extensive correction) may qualify
       for a good faith reduction.

       As to economic benefit of noncompliance (EBN), the Audit Policy restates the Agency's
       longstanding position mat recovery of any significant EBN is important in order to
       preserve a level playing field for the regulated community. The Audit Policy does not
       revise or modify any other Agency policies (fi^ the SEP Policy) concerning recovery of
       EBN.
                                           151

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#11; Inconsistencies Between Audit Policy and Statute-Specific Penalty Policies

Q:     Where statute-specific penally policies provide for different penalty reductions in
       cases of self-policing or voluntary disclosure, which policy takes precedence?
                  '               '              *                     '
A:     The final Audit Policy states cleariy that it "supersedes any inconsistent provisions in
       media-specific penalty or enforcement policies" but that such policies continue to apply
       where they are not inconsistent [Emphasis added] 60 Fed. Reg. at 66712. (If not
       inconsistent, the Audit Policy states that such existing EPA enforcement policies continue.
       to apply in conjunction with the Audit Policy provided that the regulated entity has not
       already received penalty mitigation for similar self-policing or voluntary disclosure
       activities. 60 Fed. Reg. at 66712.) In most circumstances, tile! final Audit Policy will
       result hi a greater penalty mitigation than under any media-specific penalty or enforcement
       policy. In such cases, the Audit Policy s greater penalty reductions take precedence.

       In some circumstances, however, the Audit Policy may provide for less penalty mitigation
       (e.g.. 75% penalty reductions where the violations are not discovered through a systematic
       discovery, as opposed to potential 80% or greater reductions for such cases under another
       penalty policy).  Here top, the Audit Policy takes precedence. This is because the Audit
       Policy is a more recent and more detailed statement as to the precise national strategy for
       providing incentives for self-policing, prompt disclosure, and expeditious correction and
       remediation. Therefore, in order to qualify for 75% penalty reductions or greater for
       activities related to voluntary discovery, disclosure, and remediation/correction, the Audit
       Policy provides a minimum standard of behavior that must be met5 As long as the criteria
       in the Audit Policy are met, the certainty and national consistency provided by the penalty
       reductions in the Audit Policy would apply.
      5 For activities unrelated to voluntary discovery, disclosure, and remediation/correction,
      additional penalty mitigation is available as described in Question and Answer #10.
                                          152

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#12: Applicability of Audit Policy in Litigation

Q:    Why is use of the final Audit Policy limited to settlement proceedings rather than
       being applicable also to adjudicator? proceedings?

A:    The final Audit Policy expressly limits its applicability to settlement contexts, and states
       that "[i]t is not intended for use in pleading, at hearing, or trial," 60 Fed. Reg. at 66712,
       because the Agency wanted to create these incentives for self-policing, prompt disclosure,
       and expeditious correction in a manner mat most effectively allocates scarce Agency
       resources and reduces transaction costs for the regulated community.  Subjecting the
       policy to litigation and judicial review is inconsistent with mis carefully considered
       approach to streamlining the enforcement process. As noted in the final Audit Policy,
       EPA intends to apply the policy uniformly in settlements across all of the Agency's
       enforcement programs. However, where enforcement matters are not resolved through
       settlement, but instead proceed to litigation, the Audit Policy is not applicable, and any
       attempt to apply the policy in such contexts is inappropriate.
                                          153

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#13: Degree of Conformance to The Audit Policy*s Conditions

Q:     Must the specific conditions of the final Audit Policy be met in order to qualify for
       penalty reductions, or is consistency with the general thrust of the policy sufficient
       fe.g.. where disclosure of violations occurs within 30 days but not within the 10-day
       period specified in the policy)?
                                            '  •              .             .     '       ">
A:     The specific conditions must be met Although the final Audit Policy is intended as
       guidance, die Summary section states EPA's intent to apply the policy uniformly across
       the Agency's enforcement programs. 60 Fed. Reg. at 66706. those who disclose
       violations after the policy's January 22,19% effective date have been put on notice as to
       the behavior that is expected in order to get penalty reductions. EPA also has the
       discretion to apply the policy to disclosures occurring prior to me policy's effective date.
       In such cases, however, if the policy's conditions have not been met, EPA instead will
       utilize tiie flexibility provided under its statute-specific penalty policies to recognize good
       faith efforts and determine the extent to which penally reductions are appropriate.
                                           154

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#14! EPA Inspections While Audits Are Being Performyd

Q:    Should the government agree to no inspections, fewer inspections, or other limits on
       its enforcement authorities during the time periods in which an audit is being
       performed?  *

A:    Although not explicitly addressed in the final Audit Policy, EPA's longstanding policy is
       not to agree to limit its non-penalty enforcement authorities as a provision of settlement or
       otherwise. While EPA may consider such a facility to be a lower inspection priority than a
       facility mat is not known to be auditing, whether and when to conduct an inspection does,
       and should, remain a matter of Agency, discretion. If me Agency's inspection or other
       enforcement authorities were limited, mis could compromise the Agency's ability to
       respond to citizen complaints or site conditions posing a potentially serious threat to
       human health or me environment, or its ability to assure the public as to the compliance
       status of a given faculty.  -
                                                                            January 1997
                                         155

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#15; Impact Of Prior Owner or Operators Pattern of Violations On Subsequent
Owner/Operator's Eligibility Under The Audit Policy

Q:    If an owner or operator ("owner/operator") discovers at its facility a violation that
       began when the faculty was owned and/or operated by a previous entity, may the
       subsequent owner/operator receive penalty mitigation under the final Audit Policy?
       May the previous owner/operator also obtain such mitigation?

A:     The subsequent owner/operator may obtain penally mitigation if it meets all of the policy's
       conditions, including prompt disclosure to EPA as soon as it discovers the violation. For
       purposes of the final Audit Policy, the previous owner/operator's actions will not be
       imputed to the successor, except where me relationship between the companies makes
       imputing such actions appropriate (&&» where me subsequent owner/operator is a wholly
       owned subsidiary of, and controlled by, the previous owner operator). For example, if
       mere has been an arm's length transaction between the entities and they are considered
       separate (e.g.. where the subsequent owner/operator is not considered merely a continuing
       enterprise), there may be situations where a subsequent owner/operator may receive
       penalty mitigation while the previous owner/operator cannot (tee such situation would
       be where the previous owner/operator had discovered a violation during the time that it
       owned the facility but did not disclose such a violation to. EPA.  In such a case, the
       previous owner would fail to meet the policy's prompt disclosure condition and it would
       be ineligible for penalty mitigation under the final Audit Policy.  If the subsequent
       owner/operator disclosed the violation to EPA promptly after it discovered the violation,
       it still could be eligible for penalty mitigation under the Audit Policy.  Thus, separate
       entities are considered independently, and applicability of the policy is based on the merits
       of each individual entity's actions.
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   ; Resolving Audit Policy Determination* Thrnnph Inforni5ii Or Formal MMn«

Q:     Must all penalty mitigation based upon application of the final Audit Policy be
       effectuated through one uniform type of document such as a formal settlement
       agreement or is there flexibility to use other mechanisms such as informal letters?

A:     Where applicability of the policy arises in the context of settling a pending enforcement
       action, the penalty mitigation will be effectuated through the nomal process used to setde
       pending cases in the various media-specific programs mat EPA enforces - normally
       through formal enforceable settlement agreements.6

       Even in enforcement matters that have not yet matured into pending cases (Lfi,, before any
       complaint is filed), an enforceable order normally is used in order to ensure payment of
       any penalties and/or completion of any compliance obligations.  This would occur (1)
       when the final Audit Policy would provide for 75% mitigation; (2) if an economic benefit
       penalty component was being recovered; or (3) where any compliance measures are
       necessary.                                           •

       EPA specifically stated in the policy mat it may require a regulated entity to enter into a
      , "publicly available written agreement,  administrative consent order or judicial consent
       decree, particularly where compliance  or remedial measures are complex or a lengthy
       schedule for attaining and maintaining compliance or remediating harm is required." 60
       Fed, Reg. at 66711. EPA also notes mat it may require as a condition of settlement that any
       penalty mitigation premised on the final Audit Policy be contingent upon the completeness and
       accuracy of the violator's representations.

       In the absence of a pending enforcement action, where 100% of the gravity-based penalty
       is being waived and there is no economic benefit penalty component and no outstanding
       compliance obligations, several of EPA's media-specific enforcement policies do not
    •   require that resolution of the matter occur through a formal settlement document The
       final Audit Policy applies to enforcement settlements for all the regulatory statutes under
       which EPA seeks gravity based penalties. Flexibility is necessary to meet the myriad
       settlement conditions mat may be employed as part of such settlements and the numerous
       objectives to be accomplished.  The use of a uniform document for self-disclosure
       settlements could hamper the settlement process and may even prevent EPA from meeting
       some objectives of the underlying case (e.g.. the need to expedite resolution of the case).
       Regardless of the approach taken to effectuate such penalty mitigations, EPA will track
       mis data for purposes of implementing the repeat violations provision and it will
       "independently of FOIA, make publicly available any compliance agreements reached
       under the policy."  60 Fed. Reg. 66709.
      6 In matters where judicial action is contemplated, EPA consults with the Department
      of Justice (DOJ) in the Audit Policy determination.  Where judicial actions are
      pending, DOJ approves and files formal consent decrees.
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EPA SUPPLEMENTAL ENVIRONMENTAL PROJECTS POLICY
                    EPA SUPPLEMENTAL ENVIRONMENTAL
                                    PROJECTS POLICY

                                         Effective May 1,1998

                 A. INTRODUCTION      :

                 1. Background                   •           .     .
                       .V                  /      .                .     '•_.'.'"
                 In settlements of environmental enforcement cases, the U.S. Environmental
                 Protection Agency (EPA) requires the alleged violators to acWeve and maintain
                 compliance with Federal environmental laws and regulations and to pay a civil
                 pena^. To further EPA*s goals to protect and enhance public health and the
                 environment, in certain instances environmentally beneficial projects, or
                 Supplemental Environmental Projects (SEPs), may be part of the settlement.
                 .This Policy sets forth the types of projects that are permissible as SEPs, the
                 penalty mitigation appropriate for a particular SEP, and the terms and
                 conditions under which they may become part of a settlement. The primary
                 purpose of this Policy is to encourage and obtain environmental and public
                 health protection and improvements that may not otherwise have occurred
                 without the settlement incentives provided by this PoUcy.

                 In settling ; enforcement actions, EPA requires alleged violators to promptly
                 cease the violations and, to the extent feasible, remediate any harm caused by
                 the violations. EPA also seeks substantial monetary penalties in order to deter
                 noncompliance. Without penalties, regulated entities would have an incentive to
                 delay compliance until they are caught and ordered to comply. Penalties
                 promote environmental compliance and help protect public health by deterring
                 future violations by the same violator and deterring violations by other members
                 of the regulated community. Penalties hdp ensure a national level playing field
                 by ensuring that violators do not obtain an unfair economic advantage over their
                 competitors who made the necessary expenditures to comply on time. Penalties
                 also encourage regulated entities to adopt pollution prevention and recycling
                 techniques border to minimize their pollutant discharges and reduce their
                 potential liabilities.                                     .

                 Statutes administered by EPA generally contain penalty assessment criteria that
                 a court or administrative law judge must consider in determining an appropriate
                 penalty at trial or a hearing. In the settlement context, EPA generally follows
                 these criteria in exercising its discretion to establish an appropriate settlement
                 penalty. In establishing an appropriate penalty, EPA considers such factors as
                 the economic benefit associated with the violations, the gravity or seriousness of
Iof22

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SUPPLEMENTAL LJ'TvTR.GKrvicjN i Ai* rKVjjkC 1 S POLICY
lSU
              the violations, and prior history of violations. Evidence of a violator's
              commitment and ability to perform a SEP is also a relevant factor for EPA to
              consider in establishing an appropriate settlement penalty. All else being equal,
              the final settlement penalty will be lower for a violator who agrees to perform an
              acceptable SEP compared to the violator who does not agree to perform a SEP.

              The Agency encourages the use of SEPs that are consistent with this Policy.
              SEPs may not be appropriate in settlement of all cases, but they are an important
              part of EPA's enforcement program. While penalties play an important role in
              environmental protection by deterring violations and creating a leyel playing
              field, SEPs can play as additional role in securing significant environmental or
              public health protection and improvements. SEPs may be particularly
              appropriate to further the objectives in the statutes EPA administers and to
              achieve other policy goals, including promoting pollution prevention and
              environmental justice.

              2. Pollution Prevention and Environmental Justice

              The Pollution Prevention Act of 1990 (42 U.S.C. § 13101 et seq., November 5,
              1990) identifies ah environmental management hierarchy in which pollution
              "should be prevented or reduced whenever feasible; pollution that cannot be
              prevented should be recycled in an environmentally safe manner whenever
              feasible; pollution that cannot be prevented or recycled should be treated in an
              environmentally safe manner whenever feasible; and disposal or other release
              into the environment should be employed only as a last resort ..." (42 U.S.C.
              §13103). Selection and evaluation of proposed SEPs should be conducted
              generally in accordance with this hierarchy of environmental management, i.e.,
              SEPs involving pollution prevention techniques are preferred over other types of
              reduction or control strategies, and this can be reflected in the degree of
              consideration accorded to a defendant/respondent before calculation of the final
              monetary penalty.

              Further, there is an acknowledged concern, expressed in Executive Order 12898
              on environmental justice, that certain segments of the nation's population, Le.,
              low-income and/or minority populations, are disproportionately burdened by
              pollutant exposure. Emphasizing SEPs in communities where environmental
              justice concerns are present helps ensure that persons who spend significant
              portions of their time in areas, or depend on food and water sources located
              near, where the violations occur would be protected. Because environmental
              justice is not a specific technique or process but an overarching goal, it is not
              listed as a particular SEP category; but EPA encourages SEPs in communities
              where environmental justice may be an issue.

              3. Using this Policy
                ............. ^~^^   "™^^—  _      t

              In evaluating a proposed project to determine if it qualifies as a SEP and then
              determining how much penalty mitigation is appropriate, Agency enforcement
              and compliance personnel should use the following five-step process:
                                                                                            07/31/98 1030:05

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                   (1) Ensure that the project meets the basic definition of a SEP. (Section B)

                   (2) Ensure that all legal guidelines, including nexus, are satisfied. (Section C)

                   (3) Ensure that the project fits within one (or more) of the designated categories
                   of SEPs. (Section D)

                   (4) Determine the appropriate amount of penalty mitigation. (Section E)

                   (5) Ensure that the project satisfies all of the implementation and other criteria.

                   (Sections F, G, H, I and J)

                   4. Applicability

                   This Policy revises and hereby supersedes the February 12, 1991 Policy on the
                   Use of Supplemental Environmental Projects in EPA Settlements and the May
                   1 995 Interim Revised Supplemental Environmental Projects Policy. This Policy
                   applies to settlements of all civil judicial and administrative actions filed after the
                   effective date of this Policy (May 1, 1998), and to all pending cases in which the
                   government has not reached agreement in principle with the alleged violator on
                   the specific terms of a SEP.

                   This Policy applies to all civil judicial and administrative enforcement actions
                   taken under the authority of the environmental statutes and regulations that EPA
                   administers. It also may be used by EPA and the Department of Justice in
                   reviewing proposed SEPs in settlement of citizen suits. This Policy also applies
                   to federal agencies that are liable for the payment of civil penalties. Claims for
                   stipulated penalties for violations of consent decrees or other settlement
                   agreements may not be mitigated by the use
                   This is a settlement Policy and thus is not intended for use by EPA, defendants,
                   respondents, courts or administrative law judges at a hearing or in a trial.
                   Further, whether the Agency decides to accept a proposed SEP as part of a
                   settlement, and the amount of any penalty mitigation that may be given for a
                   particular SEP, is purely within EPA's discretion. Even though a project appears
                   to satisfy all of the provisions of this Policy, EPA may decide, for one or more
                   reasons, that a SEP is not appropriate (e.g., the cost of reviewing a SEP
                   proposal is excessive, the oversight costs of the SEP may be too high, the
                   defendant/respondent may hot have the ability or reliability to complete the
                   proposed SEP, or the deterrent value of the higher penalty amount outweighs
                   the benefits of the proposed SEP).

                   This Policy establishes a framework for EPA to use in exercising its enforcement
                   discretion in determining appropriate settlements. In some cases, application of
                   this Policy may not be appropriate, in whole or part. In such cases, the litigation
                   team may, with the advance approval of Headquarters, use an alternative or
                   modified approach.
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^ SUPPLEMENTAL ENVIRONMENTAL PROJECTS POLICY
               B. DEFINITION AND KEY CHARACTERISTICS OF A SEP

               Supplemental environmental projects are defined as environmentally beneficial
               projects which a defendant/respondent agrees to undertake in settlement of an
               enforcement action, but which the defendant/respondent is not otherwise
               legally required to perform. The three bolded key parts of this definition are
               elaborated below.

               "Environmentally beneficial" means a SEP must improve, protect, or reduce
               risks to public health, or the environment at large.. While In some cases a SEP
               may provide the alleged violator with certain benefits, there must be no doubt
               that the project primarily benefits the public health or the environment.

               "In settlement of an enforcement action" means: 1) EPA has the opportunity to
               help shape the scope of the project before it is implemented; and 2) the project is
               hot commenced until after the Agency has identified a violation (e.g., issued a
               notice of violation, administrative order, or complaint).^

               "Not otherwise legally required to perform means" the project or activity is not
               required by any federal, state or local law or regulation. Further, SEPs cannot
               include actions which the defendant/respondent is likely to be required to
               perform:

               (a) as injunctive relief^) hi the instant case;

               (b) as injunctive relief hi another legal action EPA, or another regulatory agency
               could bring;

               (c) as part of an existing settlement or order in another legal action; or,

               (d) by a state or local requirement.

               SEPs may include activities which the defendant/respondent will become legally
               obligated to undertake two or more years hi the future, if the project will result
               in the facility coming into compliance earlier than the deadline. Such
               "accelerated compliance" projects are not allowable, however, if the regulation
               or statute provides a benefit (e.g., a higher emission limit) to the
               defendant/respondent for early compliance.

               Also, the performance of a SEP reduces neither the stringency n6r timeliness
               requirements of Federal environmental statutes and regulations. Of course,
               performance of a SEP does not alter the defendant/respondent's obligation to
               remedy a violation expeditiously and return to compliance.

               C. LEGAL GUIDELINES

              EPA has broad discretion to settle cases, including the discretion to include
               SEPs as an appropriate  part of the settlement. The legal evaluation of whether a
              proposed SEP is within EPA's authority and consistent with all statutory and


                                                                                           07/31/98 10:30:06
                                                 t
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 EPA SUPPLEMENTAL ENVIRONMENTAL PROJECTS POLICY
                   Constitutional requirements may be a complex task. Accordingly, this Policy
                   uses five legal guidelines to ensure that our SEPs are within the Agency's and a
                   federal court's authority, and do not run afoul of any Constitutional or statutory
                   requirements.^

                   1 . A project cannot be inconsistent with any provision of the underlying
                   statutes.

                   2. All projects must advance at least pne of the objectives of the environmental
                   statutes that are the basis of the enforcement action and must have adequate
                   nexus. Nexus is the relationship between the violation, and the proposed project.
                   This relationship exists only if:

                   a.  the project is designed to reduce the likelihood that similar violations will
                   occur in the future; or

                   b. the project reduces the adverse impact to public health or the environment to
                   which the violation at issue contributes;  or

                   c.  the project reduces the overall risk to public health or the environment
                   potentially affected by the violation at issue.

                   Nexus is easier to establish if the primary impact of the project is at the site
                   where the alleged violation occurred or at a different site in the same ecosystem
                   or within the immediate geographic^ area. Such SEPs may have sufficient
                   nexus even if the SEP addresses a different pollutant in a different medium. In
                   limited cases, nexus may exist even though a project will involve activities
                   outside of the United States.^ The cost of a project is not relevant tq whether
                   there is adequate nexus.

                   3 .  EPA may not play any role in managing or controlling funds that may be set
                   aside or escrowed for performance of a SEP. Nor may EPA retain authority to
                   manage or administer the SEP. EPA may, of course, perform oversight to
                   ensure that a project is implemented pursuant to the provisions of the settlement
                   and have legal recourse if the SEP is not adequately performed.

                   4.  The type and scope of each project are defined in the signed settlement
                   agreement.  This means the "what, where and when" of a project are defined by
                   the settlement agreement. Settlements in which the defendant/respondent agrees
                   to spend a certain sum of money on a project(s) to be defined later (after EPA
                   or the Department of Justice signs the settlement agreement) are not allowed.

                   5.  a.  A project cannot be used to satisfy EPA's statutory obligation or another
                   federal agency's obligation to perform a particular activity. Conversely, if a
                   federal statute prohibits the expenditure of federal resources on a particular
                   activity, EPA cannot consider projects that would appear to circumvent that
                   prohibition
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SUPPLEMENTAL ENVIRONMENTAL PROJECTS POUCY
             b. A project may not provide EPA or any federal agency with additional
             resources to perform a particular activity for which Congress has specifically
             appropriated funds. A project may not provide EPA with additional resources to
             perform a particular activity for which Congress has earmarked funds in an
             appropriations committee report.^ Further, a project cannot be used to satisfy
             EPA's statutory or earmark obligation, or another federal agency's statutory
             obligation, to spend funds on a particular activity. A project, however, may be
             related to a particular activity for which Congress has specifically appropriated
             or earmarked funds.

             c. A. project may not provide additional resources to support specific activities
             performed by EPA employees or EPA contractors. For example, if EPA has
             developed a brochure to help a segment of the regulated community comply
             with environmental requirements, a project may not directly, or indirectly,
             provide additional resources to revise, copy or distribute the brochure.

             d. A project may not provide a federal grantee with additional funds to perform
             a specific task identified within an assistance agreement.

             D. CATEGORIES OF SUPPLEMENTAL ENVIRONMENTAL
             PROJECTS

             EPA has identified seven specific categories of projects which may qualify as
             SEPs. In order for a proposed project to be accepted as a SEP, it must satisfy
             the requirements of at least one category plus all the other requirements
             established in this Policy.

              1. Public Health
                    "~""i  " / ~

             A public health project provides diagnostic, preventative and/or remedial
             components of human health care which is related to the actual or potential
             damage to human health caused by the violation.  This may include
             epidemiological data collection and analysis, medical examinations of potentially
             affected persons, collection and analysis of bipod/fluid/ tissue samples, medical
             treatment and rehabilitation therapy.

             Public health SEPs are acceptable only where the primary benefit of the project
             is the population that was harmed or put at risk by the violations.

             2. Pollution Prevention

             A pollution prevention project is one which reduces the generation of pollution
             through "source reduction," i.e., any practice which reduces the amount of any
             hazardous substance, pollutant or contaminant entering  any waste stream or
             otherwise being released into the environment, prior to recycling, treatment or
             disposal. (After the pollutant or waste stream has been generated, pollution
             prevention is no longer possible and the waste must be handled by appropriate
             recycling, treatment, containment, or disposal methods.)
,,                                                                                          07/31/98 10:30:08

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 *-«~/-v -^v .r .- »-r ^LCj'.
                   Source reduction may include equipment or technology modifications, process
                   or procedure modifications, reformulation or redesign of products, substitution
                   of raw materials, and improvements in housekeeping, maintenance, training,
                   inventory control, or other operation and maintenance procedures. Pollution
                   prevention also includes any project which protects natural resources through
                   conservation or increased efficiency in the use of energy, water or other
                   materials. "In-process recycling," wherein waste materials produced during a
                   manufacturing process are returned directly to production as raw materials on
                   site, is considered a pollution prevention project.

                   In all cases, for a project to meet the definition of pollution prevention, there
                   must be an overall decrease in the amount and/or toxicity of pollution released
                   to the environment, not merely a transfer of pollution among media. This
                   decrease may be achieved directly or through increased efficiency (conservation)
                   in the use of energy, water or other materials. This is consistent with the
                   Pollution Prevention Act of 1990 and the Administrator's "Pollution Prevention
                   Policy Statement:  New Directions for Environmental Protection," dated June
                   15, 1993

                   3. Pollution Reduction

                   If the pollutant or waste stream already has been generated or released, a
                   pollution reduction approach — which employs recycling, treatment,,
                   containment or disposal techniques — may be appropriate. A pollution reduction
                   project is one which results in a decrease in the amount and/or toxicity of any
                   hazardous substance, pollutant or contaminant entering any waste stream or
                   otherwise being released into the environment by an operating business or
                   facility by a means which dees not qualify as "pollution prevention," This may
                   include die installation of more effective end-of-process control or treatment
                   technology, or improved containment, or safer disposal .of an existing pollutant
                   source. Pollution reduction also includes "out-of-process recycling,"  wherein
                   industrial waste collected after the manufacturing process and/or consumer
                   waste materials are used as raw materials for production off-site.

                   4. Environmental Restoration and Protection

                   An environmental  restoration and protection project is* one which enhances the
                   condition of the ecosystem or immediate geographic area adversely affectecl.^
                   These projects may be used to restore or protect natural environments (such as
                   ecosystems)  and man-made environments, such as facilities and buildings. This
                   category also includes any project which protects the ecosystem from actual or
                   potential damage resulting from the violation or improves the overall condition
                   of the ecosystem.*^ Examples of such projects include: restoration of a wetland
                   in the same ecosystem along the same avian flyway in which the facility is
                   located;  or purchase and management of a watershed area by the
                   defendant/respondent to protect a drinking water supply where the violation
                   (e.g., a reporting violation) did not directly damage the watershed but
                   potentially could lead to damage due to unreported discharges. This category
                   also includes projects which provide for the protection of endangered species


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               fcortcTii POLICY
                                                                                    plinaLhtrnJ
 (e.g  developing conservation programs or protecting habitat critical to the
 well-being of a species endangered by the violation).

 In some projects where a defendant/respondent has agreed to restore and then
 protect certain lands, the question arises as to whether the project may include
 the creation or maintenance of certain recreational improvements, such as hiking
 and bicycle trails. The costs associated with such recreational improvements
 may be included in the total SEP cost provided they do not impair the   "
 environmentally beneficial purposes of the project and they constitute only an
 incidental portion of the total resources spent on the project

 In some projects where the parties intend that the property be protected so that
 the ecological and pollution reduction purposes of the land are maintained in
 perpetuity, the defendant/respondent may sell or transfer the land to another
 party with the established resources and expertise to perform this function, such
 as a state park authority. In some cases, the U.S. Fish and Wildlife Service or
 the National Park Service may be able to perform this function.^

 With regard to man-made environments, such projects may involve the
 remediation of faculties and buildings, provided such activities are not otherwise
 legally required. This includes the removal/mitigation of contaminated materials,
 such as soils, asbestos and lead paint, which are a continuing source of releases
 and/or threat to individuals.

 5. Assessments and Audits

 Assessments and audits, if they are not otherwise available as injunctive relief,
 are potential SEPs under this category. There are three types of projects in this
 category: a. pollution prevention assessments; b. environmental quality
 assessments; and c. compliance audits. These assessments and audits are only
 acceptable as SEPs when the defendant/respondent agrees to provide EPA with
 a copy of the report. The results may be made available to the public, except to
 the extent they constitute confidential business information pursuant to 40 CFR
 Part 2, SubpartB.

 a. Pollution prevention assessments are systematic, internal reviews of specific
 processes and operations designed to identify and provide information about
 opportunities to reduce the use, production, and generation of toxic and
 hazardous materials arid other wastes. To be eligible for SEPs, such assessments
 must be conducted using a recognized pollution prevention assessment or waste
 minimization procedure to reduce the likelihood of future violations. Pollution
 prevention assessments are acceptable as SEPs without an implementation
 commitment by the  defendant/respondent: Implementation is not required
 because drafting implementation requirements before the results of an
 assessment are known is difficult. Further, many of the implementation
 recommendations may constitute activities that are in the defendant/respondent's
 own economic interest.

b. Environmental quality assessments are investigations of: the condition of the
                                                                              07/31/98.10:30:09

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 £PA SUPPLEMENTAL ENVIRONMENTAL PROJECTS POLICY


                   environment at a ate not owned or operated by the defendant/respondent; the
                   environment impacted by a site or a facility regardless of whether the site or
                   facility is owned or operated by the defendant/respondent; or threats to human
                   health or the environment relating to a site or a facility regardless of whether the
                   she or facility is owned or operated by the defendant/respondent These include,
                   but are not limited to: investigations of levels or sources of contamination in any
                   environmental media at a site; or monitoring of the air, soil, or water quality
                   surrounding a site or facility. To be eligible as SEPs, such assessments must be
                   conducted in accordance with recognized protocols, if available, applicable to
                   the type of assessment to be undertaken. Expanded sampling or monitoring by
                   a defendant/respondent of its own emissions or operations does not qualify as
                   a SEP to the extent it is ordinarily available as injunctive relief.

                   Environmental quality assessment SEPs may not be performed on the following
                   types of sites: sites that are on the National Priority List under CERCLA §  105,
                   40 CFR Part 300, Appendix B; sites that would qualify for an EPA removal
                   action pursuant to CERCLA §104(a) and the National Oil and Hazardous
                   Substances Pollution Contingency Plan, 40 CFR § 300.415; and sites for which
                   the defendant/respondent or another party would likely be prdefed to perform a
                   remediation activity pursuant to CERCLA §106, RCRA §7003, RCRA 3008(h),
                   CWA § 311, or another federal law.

                   c. Environmental compliance audits are independent evaluations of a'
                   defendant/respondent's compliance status with environmental requirements.
                   Credit is only given for the costs associated with conducting the audit. While the
                   SEP should require all violations discovered by the audit to be promptly
                   corrected, no credit is given for remedying the violation since persons are
                   required to achieve and maintain compliance with environmental requirements.
                   In general, compliance audits are acceptable as SEPs only when the
                   defendant/respondent is  a small business or small community.^ ^

                   6. Environmental Compliance Promotion

                   An environmental compliance promotion project provides training or technical
                   support to other members of the regulated community to: 1) identify, achieve
                   and maintain compliance with applicable statutory and regulatory requirements
                   or 2) go beyond compliance by reducing the generation, release or disposal of
                   pollutants beyond legal requirements. For these types of projects, the
                   defendant/respondent may lack the experience, knowledge or ability to
                   implement the project itself, and, if so, the defendant/respondent  should be.
                   required to contract with an appropriate expert to develop and implement the
                   compliance promotion project. Acceptable projects may include, for example,
                   producing a seminar directly related to correcting widespread or prevalent
                   violations within the defendant/ respondent's economic sector.

                   Environmental compliance promotion SEPs are acceptable only where the
                   primary impact of the project is focused on the same regulatory program
                   requirements which were violated  and where EPA has reason to believe that
                   compliance in the sector would be significantly advanced by the proposed


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UPPLEMENTALENVIRONMEKrALPROJECTSPOUCY


             project. For example, if the alleged violations involved Clean Water Act
             pretreatment violations, the compliance promotion SEP must be directed at
             ensuring compliance with pretreatment requirements. Environmental compliance
             promotion SEPs are subject to special approval requirements per Section J
             below.

             7. Emergency Planning and Preparedness

             An emergency planning and preparedness project provides assistance — such as
             computers and software, communication systems, chemical emission detection
             and inactivation equipment, HAZMAT equipment, or training — to a responsible
             state or local emergency response or planning entity. This is to enable these
             organizations to fulfill their obligations under the Emergency Planning and
             Community Right-to-Know Act (EPCRA) to collect information to assess the
             dangers of hazardous chemicals present at facilities within their jurisdiction, to
             develop emergency response plans, to train emergency response personnel and
             to better respond to chemical spills.

             EPCRA requires regulated sources to provide information on chemical
             production, storage and use to State Emergency Response Commissions
             (SERCs), Local Emergency Planning Committees (LEPCs) and Local Fire
             Departments (LFDs). This enables states and local communities to plan for and
             respond effectively to chemical accidents and inform potentially affected citizens
             of the risks posed by chemicals present in their communities, thereby enabling
             them to protect the environment or ecosystems which could be damaged by an
             accident. Failure to comply with EPCRA impairs the ability of states and local
             communities to meet their obligations and places emergency response personnel,
             the public and the environment at risk from a chemical release.

             Emergency planning and preparedness SEPs are acceptable where the primary
             impact of the project is within the same emergency planning district or state
             affected by the violations and EPA has not previously provided the entity with
             financial assistance for the same purposes as the proposed SEP. Further, this
             type of SEP is allowable only when the SEP involves non-cash assistance and
             there are violations of EPCRA, or reporting violations under CERCLA § 103,
             or CAA § 112(r), or violations of other emergency planning, spill or release
             requirements alleged in the complaint.

             8. Other Types of Projects

             Projects determined by the case team to have environmental merit which do not
             fit. vithin at least one of the seven categories above but that are otherwise fully
             consistent with all other provisions of this Policy, may be accepted with the
             advance approval of the Office of Enforcement and Compliance Assurance.

             Q Projects Which Are Not Acceptable as SEPs

             The following are examples of the types of projects that are not allowable as
             SEPs:


,-„'                                                      '                                  07/31/98 10:30:10
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EPA SUPPLEMENTAL ENVIRONMENTAL PROJECTS POLICY
                   a. General public educational or public environmental awareness projects, e.g.,
                   sponsoring public seminars, conducting tours of environmental controls at a
                   facility, promoting recycling in a community;

                   b. Contributions to environmental research at a college or university;

                   c. Conducting a project, which, though beneficial to'a community, is unrelated
                   to environmental protection, e.g., making a contribution to a non-profit, public
                   interest, environmental, or other charitable organization, or donating playground
                   equipment;

                   d. Studies or assessments without a requirement to address the problems
                   identified in the study (except as provided for in § D.5 above);

                   e. Projects which the defendant/respondent will undertake,  in whole or part,
                   with low-interest federal loans, federal contracts, federal grants, or other forms
                   of federal financial assistance or non-financial assistance (e.g., loan guarantees).

                   E. CALCULATION OF THE FINAL PENALTY

                   Substantial penalties are an important part of any settlement for legal and policy
                   reasons. Without penalties there would be no deterrence, as regulated entities
                   would have little incentive to comply. Additionally, penalties are necessary as a
 ,                  matter of fairness to those regulated entities that make the necessary
                   expenditures to comply on time: violators should not be allowed to obtain an
                   economic advantage over their competitors who complied.

                   As a general rule, the net costs to be incurred by a violator in performing a SEP
                   may be considered as one factor in determining an appropriate settlement
                   amount. In settlements in which defendant/respondents commit to conduct
                   a SEP, the final settlement penalty must equal or exceed either: a) the
                   economic benefit of noncompliance plus 10 percent of the gravity
                   component; or b) 25 percent of the gravity component only; whichever is
                   greater.

                   Calculating the final penalty in a settlement which includes  a SEP is a five step
                   process. Each of the five steps is explained below. The five steps are also
                   summarized in the penalty calculation worksheet attached to this Policy.

                   Step 1: Settlement Amount Without a SEP

                  a. The applicable EPA penalty policy is used to calculate the economic
                  benefit of noncompliance.

                  b. The applicable EPA penalty policy is used to calculate the gravity
                  component of the penalty. The gravity component is all of the penalty other
                 . than the identifiable economic benefit amount, after gravity has been adjusted
                  by all other factors in  the penalty policy (e.g., audits, good faith, litigation


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SUPKiMENTAL-BMVKlUNMtN 1AL PROJECTS POLICY
              considerations), except for the SEP.

              c. The amounts in steps 1 .a and b are added. This sum is the minimum amount
              that would be necessary to settle the case without a SEP.

              Step 2: Minimum Penalty Amount With a SEP
                                      j
              The minimum penalty amount must equal or exceed the economic benefit of
              noncompliance plus 10 percent of the gravity component, or 25 percent of the
              gravity component only, whichever is greater. The minimum penalty amount is
              calculated as follows:

              a. Calculate 10 percent of gravity (multiply amount in step 1 .b by 0.1).

              b. Add economic benefit (amount in step l.a) to amount in step 2.a.

              c. Calculate 25 percent of gravity (multiply amount in step 1 .b by 0.25).

              d. Identify the minimum penalty amount: the greater of step 2.c or step 2.b.^

              Step 3. Calculate the SEP Cost

              The net present after-tax cost of the SEP, hereinafter called the "SEP COST," is
              the maximum amount that EPA may take into consideration in  determining an
              appropriate penalty mitigation for performance of a SEP. In order to facilitate
              evaluation of the SEP COST of a proposed project, the Agency has developed a
              computer model  called PROJECT.^ There are three types of costs that may
              be associated with performance of a SEP (which are entered into the PROJECT
              model): capital costs (e.g., equipment, buildings); one-time nondepreciable costs
              (e.g., removing contaminated materials, purchasing land, developing a
              compliance promotion seminar); and annual operation costs and savings (e.g.,
              labor, chemicals, water, power, raw materials)^

              To use PROJECT,  the Agency needs reliable estimates of the costs associated
              with a defendant/respondent's performance of a SEP, as well as any savings due
              to such factors as energy efficiency gains, reduced materials costs, reduced
              waste disposal costs, or increases in productivity. For example, if the annual
              expenditures in labor and materials of operating a new waste recycling process
              is $ 100,000 per year, but the new process reduces existing hazardous waste
              disposal expenditures by $30,000 per year, the net cost of $70,000 is entered *
              into the PROJECT model (variable, 4).

              In order to run the PROJECT  model properly (i.e., to produce a reasonable
              estimate of the net present after-tax cost of the project), the number of years
              that annual operation costs or  savings will be expended in performing the SEP
              must be specified. At a minimum, the defendant/respondent must be required to
              implement the project for the same number of years used in the PROJECT
              model calculation. (For example, if the settlement agreement requires the
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. EPA SUPPLEMENTAL ENVIRONMENTAL PROJECTS POLICY
                   defendant/respondent to operate the SEP equipment for two years, two years
                   should be entered as the input for number of years of annual expense in_the
  ;                 PROJECT model.) If certain costs or savings appear speculative, they should
                   not be entered into the PROJECT model. The PROJECT model is the primary
                   method to determine the SEP COST for purposes of negotiating settlements.*1^

                   EPA does not offer tax advice on whether a regulated entity may deduct SEP
                   expenditures from its income taxes. If a defendant/respondent states that it will
                   not deduct the cost of a SEP from its taxes and it is willing to commit to this in
                   the settlement document, and provide the Agency with certification upon
                   completion of the SEP that it has not deducted the SEP expenditures, the
                   PROJECT model calculation should be adjusted to calculate the SEP Cost
                   without reductions for taxes. This is a simple adjustment to the PROJECT
                   model: just enter a zero for variable 7, the marginal tax rate. If a business is not
                   willing to make this commitment, the marginal tax rate in variable 7 should not
                   be set to zero; rather the default settings (or a more precise estimate of the
                   business' marginal tax rates) should be used in variable 7.

                   If the PROJECT model reveals that a project has a negative cost during the
                   period of performance of the SEP, this means that it represents a positive cash
                   flow to the defendant/respondent and is a profitable project. Such a project is
                   generally not acceptable as a SEP. If a project generates a profit, a
                   defendant/respondent should, arid probably will, based on its own economic
                   interests, implement the project. While EPA encourages regulated entities to
 i                 undertake environmentally beneficial projects that are  economically profitable,
                   EPA does not believe violators should receive a bonus in the form of penalty
                   mitigation to undertake such projects as part of an enforcement action. EPA
                   does not offer subsidies to complying companies to undertake profitable
                   environmentally beneficial projects and it would thus be inequitable and perverse
                   to provide such subsidies only to violators. In addition, the primary goal of
                   SEPS is to secure a favorable environmental or public  health outcome which
                   would not have occurred but for the enforcement case settlement. To allow SEP
                   penalty mitigation for profitable projects would thwart this
                   Step 4.a: Mitigation Percentage. After the SEP COST has been calculated, EPA
                   should determine what percentage of that cost may be applied as mitigation
                   against the amount EPA would settle for but for the SEP. The quality of the
                   SEP should be examined as to whether and how effectively it achieves each of
                   the following six factors listed below. (The factors are not listed in priority
                   order.)

                   Benefits to the Public or Environment at Large. While all SEPs benefit public
                   health or the environment, SEPs which perform well on this factor will result in
                   significant and quantifiable reduction in discharges of pollutants to the
                   environment and the reduction in risk to the general public. SEPs also will
                   perform  well on this factor to the extent they result in significant and, to the


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WPLEMENTALENVIRONMENTALPROJECTSPOUCY
              extent possible, measurable progress in protecting and restoring ecosystems
              (including wetlands and endangered species habitats).

              Innovativeness. SEPs which perform well on this factor will further the
              development, implementation, or dissemination of innovative processes,
              technologies, or methods which more effectively: reduce the generation^ release
              or disposal of pollutants; conserve natural resources; restore and protect
              ecosystems; protect endangered species; or promote compliance. This includes
              "technology forcing" techniques which may establish new regulatory
              "benchmarks.1'

              Environmentat Justice. SEPs which perform well on this factor will mitigate
              damage or reduce risk to minority or low income populations which may have
              been disproportionately exposed to pollution or are at environmental risk.

              Community Input. SEPs which perform well on this factor will have been
              developed taking into consideration input received from the affected
              community. No credit should be given for this factor if the defendant/respondent
              did not actively participate in soliciting and incorporating public input into the
              Multimedia Impacts. SEPs which perform well on this factor will reduce
              emissions to more than one medium.

              Pollution Prevention. SEPs which perform well on this factor will develop and
              implement pollution prevention techniques and practices.

              The better the performance of the SEP under each of these factors, the higher
              the appropriate mitigation percentage. The percent of penalty mitigation is
             . within EPA's discretion; there is no presumption as to the correct percentage of
              mitigation. The mitigation percentage should not exceed 80 percent of the
              SEP COST, with two exceptions:

              (1) For small businesses, government agencies or entities, and non-profit
              organizations, this mitigation percentage of the SEP COST may be set as high
              as 100 percent if the defendant/respondent can demonstrate the project is of
              outstanding quality.

              (2) For any defendant/respondent, if the SEP implements pollution prevention,
              the mitigation percentage of the SEP  COST may be set as high as 100 percent if
              the defendant/respondent can demonstrate that the project is of outstanding
              quality.

              If the government must allocate significant resources to monitoring and
              reviewing the implementation of a project, a lower mitigation percentage of the
              SEP COST may be appropriate.

              In administrative enforcement actions in which there is a statutory limit
              (commonly called "caps") on the total maximum penalty that may be sought in a
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 EPA SUPPLEMENTAL ENVIRONMENTAL PROJECTS POLICY


                   single action, the cash penalty obtained plus the amount of penalty mitigation
                   credit due to the SEPs shall not exceed the limit.

                   Step 4.b: SEP Mitigation Amount. The SEP COST (calculated pursuant to step
                   3) is multiplied by the mitigation percentage (step 4.a) to obtain the SEP
                   mitigation amount, which is the amount of the SEP cost that may be used in
                   potentially mitigating the preliminary settlement penalty.

                   Step 5: Final Settlement Penalty

                   S.a. The SEP mitigation amount (step 4.b) is then subtracted from the settlement
                   amount without a SEP (step l.c).
                                                                                   s
                   5.b The greater of step 2.d or step S.a is the minimum final settlement penalty
                   allowable based on the performance of the SEP.

                   F. LIABILITY FOR PERFORMANCE

                   Defendants/respondents (or their successors in interest) are responsible and   ••
                   legally liable for ensuring mat a SEP is completed satisfactorily.  A
                   defendant/respondent may not transfer this responsibility and liability to
                   someone else, commonly called a third party. Of course, a defendant/respondent
                   may use contractors or consultants to assist h in implementing a SEP.^

 t                  G. OVERSIGHT AND DRAFTING ENFORCEABLE SEPS

                   The settlement agreement should accurately and completely describe the SEP.
                   (See related legal guideline 4 in § C above.) It should describe the specific
                   actions to be performed by the defendant/respondent and provide for a reliable
                   and objective means to verify that the defendant/respondent has timely
                   completed the project. This may require the defendant/respondent to submit
                   periodic reports to EPA. The defendant/respondent may utilize an outside
                   auditor to verify performance, and the defendant/respondent should be made
                   responsible for the cost of any such activities. The defendant/respondent remains
                   responsible for the quality and timeliness of any actions performed or any
                   reports prepared or submitted by the auditor. A final report certified by an
                   appropriate corporate official, acceptable to EPA; and evidencing completion of
                   the SEP and documenting SEP expenditures, should be required.

                   To the extent feasible, defendant/respondents should be required to quantify the
                   benefits associated with the project and provide EPA with a report setting forth
                   how the. benefits were measured or estimated. The defendant/respondent
                  should agree that whenever it publicizes a SEP or the results of a SEP, it
                  will state in a prominent manner that the project is being undertaken as
                  part of the settlement of an enforcement action.

                  The drafting of a SEP will, vary depending on whether the SEP is being
                  performed as part of an administrative or judicial enforcement action SEPs with
                  long implementation schedules (e.g., 18 months or longer), SEPs which require


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EPA review and coihment on interim milestone activities, and other complex
SEPs may not be appropriate in administrative enforcement actions. Specific
guidance on the proper drafting of settlement documents requiring SEPs is
provided in a separate document.

H. FAILURE OF A SEP AND STIPULATED PENALTIES

If a SEP is not completed satisfactorily, the defendant/respondent should be
required, pursuant to the terms of the settlement document, to pay stipulated
penalties for its failure. Stipulated penalty liability should be established for each
of the scenarios set forth below as appropriate to the individual case.

1. Except as provided in paragraph 2 immediately below, if the SEP is not
completed satisfactorily, a substantial stipulated penalty should be required.
Generally, a substantial stipulated penalty is between 75 and 150 percent of the
amount by which the settlement penalty was mitigated pn account of the SEP.

2. If the SEP is not completed satisfactorily, but the defendant/respondent:

a) made good faith and timely efforts to complete the project; and b) certifies,

with supporting documentation, that at least 90 percent of the amount of

money which was required to be spent was expended on the SEP, no stipulated

penalty is necessary.

3. If the SEP is satisfactorily completed, but the defendant/respondent spent less
than 90 percent of the amount of money required to be spent for the project, a
small stipulated penalty should be required. Generally, a small stipulated penalty
is between 10 and 25 percent of the amount by which the settlement penalty was
mitigated on account of the SEP.

4. If the SEP is satisfactorily completed, and the defendant/respondent spent at
least 90 percent of the amount of money required to be spent for the project, no
stipulated penalty is necessary.

The determinatioris of whether the SEP has been satisfactorily completed (i.e.,
pursuant to the terms of the agreement) and whether the defendant/respondent
has made a good faith, timely effort to implement the SEP should be reserved to
the sole discretion of EPA, especially in administrative actions in which there is
often no formal dispute resolution process.

I. COMMUNITY INPUT

In appropriate cases, EPA should make special efforts to  seek input on project
proposals from the local community that may have been adversely impacted ty
the violations.*12* Soliciting community input into the SEP development process
can:  result in SEPs that better address the needs of the impacted community;
                                                                             07/31/98 10:30:14

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                  promote environmental justice; produce better community understanding of
                  EPA enforcement; and improve relations between the community and the
                  violating facility. Community involvement in SEPs may be most appropriate in
                  cases where the range of possible SEPs is great and/or multiple SEPs may be
                  negotiated.

                  When soliciting community input, the EPA negotiating team should follow the
                  four guidelines set forth below.

                  1. Community input should be sought after EPA knows that the
                  defendant/respondent is interested in doing a SEP and is willing to seek
                  community input, approximately how much money may be available for doing a
                  SEP, and that settlement of the enforcement action is. likely. If these conditions
                  are not satisfied, EPA will have very little information to provide communities
                  regarding the scope of possible SEPs..

                  2. The EPA negotiating team should use both informal and formal methods to
                  contact the local community. Informal methods may involve telephone calls to
                  local community organizations, local churches, local elected leaders, local
                  chambers of commerce, or other groups. Since EPA may not be able to identify
                  all interested community groups, a public notice in a local newspaper may be
                  appropriate

                  3. To ensure that communities have a meaningful opportunity to participate, the
                  EPA negotiating team should provide information to communities about what
                  SEPs are, the opportunities and limits of such projects, the confidential nature of
                  settlement negotiations, and the reasonable possibilities and limitations in the
                  current enforcement action.- This can be done by holding a public meeting,
                  usually in the evening, at a local school or facility. The EPA negotiating team
                  may wish to use community outreach experts at EPA or the Department of
                  Justice in conducting this meeting. Sometimes the defendant/respondent may
                  play ah active role at this meeting and have its own experts  assist in the process.

                  4. After the initial public meeting, the extent of community input and
                  participation in the SEP development process will have to be determined. The
                  amount of input and participation is likely to vary with each case. Except in
                  extraordinary circumstances and with agreement of the parties, representatives
                  of community groups will not participate directly in the settlement negotiations.
                  This restriction is necessary because of the confidential nature of settlement
                  negotiations and because there is often no equitable process to determine which
                  community group should directly participate in the negotiations.

                  J. EPA PROCEDURES

                  1. Approvals

                  The authority of a government official to approve a SEP is  included in the
                  official's authority to settle an enforcement case and thus, subject to the
                  exceptions set forth here, no special approvals are required. The special
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                     x-UUC Y
approvals apply to both administrative and judicial enforcement actions as
follows:

a. Regions in which a SEP is proposed for implementation shall be given the
opportunity to review and comment on the proposed SEP.

b. In all cases in which a project may not fully comply with the provisions of this
Policy (e.g., see footnote  1), the SEP must be approved by the EPA Assistant
Administrator for Enforcement and Compliance Assurance. If a project does not
fully comply with all of the legal guidelines in this Policy, the request for
approval must set forth a legal analysis supporting the conclusion that the
project is within EPA's legal authority and is not otherwise inconsistent with
law.

c. In all cases in which a SEP would involve activities outside the United States,
the SEP must be approved in advance by the Assistant Administrator and, for
judicial cases only, the Assistant Attorney General for the Environment and     »
Natural Resources Division of the Department of Justice.

d. In all cases in which an environmental compliance promotion project (section
D.6) or a project in the "other"  category (section D.8) is contemplated, the
project must be approved in advance by the appropriate office in DEC A, unless
otherwise delegated.

2. Documentation and Confidentiality

In each case in which a SEP is included as part of a settlement, an explanation of
the SEP with supporting materials (including the PROJECT model printout,
where applicable) must be included as part of the case file. The explanation of
the SEP should explain how the five steps set forth in Section A.3 above have
been used to evaluate the project and include a description of the expected
benefits associated with the SEP. The explanation must include a description by
the enforcement attorney of how nexus and the other legal guidelines are
satisfied.

Documentation and explanations of a particular  SEP may constitute confidential
settlement information that is exempt from disclosure under the Freedom of
Information Act, is outside the scope of discovery, and is protected by various
privileges, including the attorney-client privilege and the attorney work-product
privilege. While individual Agency evaluations of proposed SEPs are
confidential, privileged documents, this Policy is a public document and may be
released to anyone upon request.
         f~
 This Policy is primarily for the use of U.S. EPA enforcement personnel in settling cases. Ef
 the right to change this Policy at any time, without prior notice, or to act at variance to this
 This Policy does not create any rights, duties, or obligations, implied or otherwise, in any ti
parties.
                                                                              07/31/98 10:30:16

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 EPA SUPPLEMENTAL EHV»ONMENTAL PROJECTS POLICY
wysiwygy/9/hltp^/es.epB.gov/occa/sep/sepfia|j
                                            ATTACHMENT
                                               j
                          SEP PENALTY CALCULATION WORKSHEET

                        This worksheet should be used pursuant to section E of the Policy.

                   Specific Applications of this Worksheet in a Case Are Privileged, Confidential
                                               Documents.
STEP 1
AMOUNT
STEP 1 : CALCULATION OF SETTLEMENT AMOUNT WITHOUT A SEP.
l.a. BENEFIT: The applicable penalty policy is used to calculate the economic
benefit of noncompliance.
l.b. GRAVITY: The applicable penalty policy is used to calculate the gravity
component of the penalty, this is gravity after all adjustments in the applicable
policy!
l.c SETTLEMENT AMOUNT without a SEP: Sum of step l.a plus l.b.
$
$
$
STEP 2: CALCULATION OF THE MINIMUM PENALTY AMOUNT WITH A SEP
2.a 10% of GRAVITY: Multiply amount in step l.b by 0,10 ||$
2.b BENEFIT PLUS 1 0% of GRAVITY: Sum of step 1 a plus step 2.a.
|$ 	 	
2.c. 25 % of GRAVITY: Multiply amount in step l.b by 0.25. ||$
2.d MINIMUM PENALTY AMOUNT: Select greater of step 2.c or step 2.b. |$
STEP 3: CALCULATION OF THE SEP COST USING PROJECT MODEL, |$
STEP 4: CALCULATION OF MITIGATION PERCENTAGE AND MITIGATION
AMOUNT.
4.a. SEP Cost Mitigation Percentage. Evaluate the project pursuant to the 6
mitigation factors in the Policy. Mitigation percentage should not exceed 80 %
unless one of the exceptions applies.
4.b. SEP Mitigation Amount. Multiply step 3 by step 4. a
%
STEP 5: CALCULATION OF THE FINAL SETTLEMENT PENALTY.
5. a Subtract step 4.b from step l.c
5.b. Final Settlement Penalty: Select greater of step 2.d or step 5.a.
$
$
                  1. In extraordinary circumstances, the Assistant Administrator may consider
                  mitigating potential stipulated penalty liability using SEPs where: (1) despite the
                  circumstances giving rise to the claim for stipulated penalties, the violator has
                  the ability and intention to comply with a new settlement agreement obligation
                  to implement the SEP; (2) there is no negative impact on the deterrent purposes
                  of stipulated penalties; and (3) the settlement agreement establishes a range for
                  stipulated penalty liability for the violations at issue. For example, if a
                  respondent/defendant has violated a settlement agreement which provides that a
                  violation of X requirement subjects it to a stipulated penalty between $1,000
                  and $5,000, then the Agency may consider SEPs in determining the specific
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A SUPPLEMENTAL ENVIRONMENTAL PROJECTS POLICY
               penalty amount that should be demanded.

               2. Since the primary purpose of this Policy is to obtain environmental or public
               health benefits that may not have occurred "but for" the settlement, projects
               which the defendant has previously committed to perform or have been started
               before the Agency has identified a violation are not eligible as SEPs. Projects
               which have been committed to or started before the identification of a violation
               may mitigate the penalty hi other ways. Depending on the specifics, if a
               regulated entity had initiated environmentally beneficial projects before the
               enforcement process commenced, the initial penalty calculation could be lower
               due to the absence of recalcitrance, no history of other violations, good faith
               efforts, less severity of the violations, or a shorter duration of the violations.

               3. The statutes EPA administers generally provide a court with broad authority
               to order a defendant to cease its violations, take necessary steps to prevent
               future violations, and to remediate any harm caused by the violations. If a court
               is likely to order a defendant to perform a specific activity in a particular case,
               such an activity does not qualify as a SEP.

               4. These legal guidelines are based on federal law as it applies to EPA; States
               may have more or less flexibility in the use of SEPs depending on their laws.

               5. The immediate geographic area will generally be the area within  a 50 mile
               radius of the site on which the violations occurred. Ecosystem or geographic
               proximity is not by itself a sufficient basis for nexus; a project must always
               satisfy subparagraph a, b, or c in the definition of nexus. In some cases, a project
               may be performed at a facility or site not owned by the defendant/respondent.

               6. All projects which would include activities outside the U.S. must be approved
               in advance by Headquarters arid/or the Department of Justice. See  section J;

               7. Earmarks are instructions for changes to EPA's discretionary budget authority
               made by appropriations committee in committee reports that the Agency
               generally honors as a matter of policy.

               8. If EPA lacks authority tp require repair of the damage caused by the
               violation, then repair itself may constitute a SEP.

               9. Simply preventing new discharges into the ecosystem, as opposed to taking
               affirmative action directly related to preserving existing conditions  at a property,
               would not constitute a restoration and protection project, but may fit into
               another category such as pollution prevention or pollution reduction.

               10. These federal agencies have explicit statutory authority to accept gifts of
               land and money in certain circumstances. All projects with these federal agencies
               must be reviewed and approved in advance by legal counsel in the agency,
               usually the Solicitor's Office in the Department of the Interior.

               1 1 . For purposes of this Policy, a small business is owned by a person or another
                                                                                              07/31/98 10:30:17

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                                   cc IS PGuOY
                  entity that employs 100 or fewer individuals. Small businesses could be
                  individuals, privately held corporations, farmers, landowners, partnerships and
                  others. A small community is one comprised of fewer than 2,500 persons.

                  12. Since most large companies routinely conduct compliance audits, to mitigate
                  penalties for such audits would reward violators for performing an activity that
                  most companies already do. In contrast, these audits are not commonly done by
                  small businesses, perhaps because such audits may be too expensive.

                  13, Pursuant to the February  1995 Revised Interim Clean Water Act Settlement
                  Penalty Policy, section V, a smaller minimum penalty amount may be allowed
                  for a municipality.

                  14. A copy of the PROJECT  computer program software and PROJECT User's
                  Manual may be purchased by calling that National Technology Information
                  Service at (800)~553-6847, and asking for Document #PB 98-500408GEI, or
                  they may be downloaded from the World Wide Web at
                  "http://www.epa.gov/oeca/models/".

                  15. The PROJECT calculated SEP Cost is a reasonable estimate, and not an
                  exact after-tax calculation. PROJECT does not evaluate the potential for market
                  benefits which may accrue with the performance of a SEP (e.g., increased sales
                  of a product, improved corporate public image, or improved employee morale).
                  Nor does it consider costs imposed on the government, such as the cost to the
                  Agency for oversight of the SEP, or the burden of a lengthy negotiation with a
                  defendant/ respondent who does not propose a SEP until late in the settlement
                  process; such factors may be considered in determining a mitigation percentage
                  rather than in calculating after-tax cost.

                  16. See PROJECT User's Manual, January 1995. If the PROJECT model
                  appears inappropriate to a particular fact situation, EPA Headquarters should be
                  consulted to identify an alternative approach. For example,  PROJECT does not
                  readily calculate the cost of an accelerated compliance SEP. The cost of such a
                  SEP is only the additional cost associated with doing the project  early (ahead of
                  the regulatory requirement) and it needs to be calculated in a slightly different
                  manner. Please consult with the Office Of Regulatory Enforcement for
                  directions on how to calculate the costs of such projects.

                  17. The penalty mitigation guidelines provide that the amount of mitigation
                  should not exceed the net cost of the project. To provide penalty mitigation for
                  profitable projects would be providing a credit in excess of net costs.

                  18. Non-profit organizations, such as universities and public interest groups,
                  may function as contractors or consultants.

                  19. In civil judicial cases, the Department of Justice already seeks public
                  comment on lodged consent decrees through a Federal Register notice. See 28
                  CFR §50.7. In certain administrative enforcement actions, there are also public
                 • notice requirements that are followed before a settlement is finalized. See 40
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         CFRPart22.
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                                                                                  07/31/98 1030:19

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 [Published June 23,-1995 60 FR 32675]
 A. .  ; INTRODUCTION

       -Thisdocument sets forth the Environmental Protection Agency's Interim Policy on
 compliance' incentives for ymaft. businesses.  This Policy is one of the 25 regulatory reform.
 initiatives announced by President Clinton on. March 1(5,1995, and implemen'ts, in part, the -
 Executive Memorandum on Regulatory Reform,  60 FR 20621 (Aprii*26, 1995).

       ' The Executive Memorandum provides in pertinent part •  .        ••

    .   .To the extent permitted by law, each agency shaTi use its discretion to modify
   •  " the penalties for small businesses in the following situations.'  Agencies  shall  '
      . exercise their enforcement discretion to waive the imposition of aH'or a    .  '
       portion of a penalty when the violation is corrected within a time period
      .appropriate to the violation in question... For those violations that may tab*  '"  '
       longer to correct than the period set by the agency, the agency shall use its
       "enforcement discretion to waive up to. 100 percent of the financial penalties if
       the amounts waived are used to bring the entity into compliance. The    ' • >
       provisions [of this paragraph] shall apply only where there has been a good .   "'••'
       faith effort to comply with applicable regulations and the violation does not
    ..   involve criminal wrongdoing or significant threat to health, safety, or the •
.-..  \; environment •••"   ""'  -.'-_'.""     •'<"•'   -••'.   •.'.'•     '\     '  "".  ' "••  '..  :...

~ '• •. v. Pursuant to this Interim Policy, EPA wiE exercise-its discretion,  under applicable '
medjarspeciiic policies, to refrain :rrom initiating an enforcement action seeking civil '    '
penalties, or to mitigate civil penalties," whenever a grnafl business malcg^ a good faith effort
to 'comply with environmental requirements and where there is no criminal behavior and no
significant health, safety or environmental threat. In addition, as announced in the package*.
of regulatory reform initiatives, EPA is creating special incentives for small businesses wno
take the initiative to identify and correct environmental violations by requesting compliance
assistance from the government.  In such circumstances, and provided the small business
meets certain other criteria set forth below, EPA will exercise its discretion  to  waive the
entire penalty.  Moreover, EPA will defer to state- actions that are consistent with this Policy.
                                                                               *-ll  2 3 159

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                        \
 Compliance IncentiYes for Small Businesses     *. * • June 1995 Interim Policy * "
                                                                • *
 B.    BACKGROUND .-
    '  -    •'.''..
•      The dean Air Act (CAA) Amendments of 1990 require that states-establish SmaH  "
 Business Assistance Programs (SBAPs) to provide technical and environmental compliance
 assistance to stedonary sources.  On August 12, 1994, EPA issued an enforcement response
 policy which provided thai an authorized or delegated state program may; consistent with  '
 federal requirements, eimen                '                           '              •

       (1) assess no. penalties."against «naH .businesses that voluntarily seek compliance  •'•"
       assistance and correct violations revealed as a result of compliance assistance within a
      .limited period of time; or   •.   •    .    . -:              "  '
•   .    (2) keep confidential information .that identifies the names and'locations of specific  '
       small businesses with violations-revealed through compliance assistance, where the
       SBAP is independent of thestate enforcement program. '

       In a further effort to assist small .businesses to comply with environmental regulations,
 and to achieve health, safety, and environmental benefits, the Agency is adopting a 'similar .
 policy for water, toxics,, hazardous waste, and other media programs.  This interim Policy
 sets forth the Agency's implementation of the Executive Memorandum.    ,  .
 C    PURPOSE
           •*. •
   •  -• '  ••: t. ...' • .. .       .        .         .....
  -   -.  This interim Policy JS intended to .promote environmpTit'aT mmplianrj* amrmg email .-.-'
 businesses by providing incentives for participation in compliance assistance programs, and
 encouraging the prompt correction of violations. The Policy accomplishes this in two ways; .
.by setting forth/a y'ttlfm"'* pearly Policy that rewatdrsuch behavior, and by providing^, "
 guidance for States and local governments to offer these incentiviss.  :';..%    ' •. . .
   •  • -HP A i* cnmTnin^ tn a strong enforcement and compliance. assurance program as 'a
. means to protect human health and the environment.  We expect this Policy to encourage
 greater pardcipatioh in" compliance assistance programs that offer services to small businesses
 (referred to genericaHy as "SBAPs in this Policy).. The Policy .win allow greater openness •
 among SBAPs and specific facilities, the small business community in general, and. other
 federal and state officials.  It will promote the sharing of information on pollution prevention
 measures, cost effective means of compliance and other valuable compliance-related activities
 with and among the regulated community. Application of the policy to all media programs
 should encourage small businesses to look for  "whole facility" approaches to environmental
 compliance.  Ultimately, by bringing many small businesses into compliance, this Policy will
 enhance  the quality of our air, water, and land.

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           IncentiTe for S««aii Businesses     * * • June 1595 Interim Policy • * *'           page 3.

      •  Measuring .the success of compliance assistance programs is a critical component of . -
. EPA's ability to assess  the results of compliance and enforcement activities.  EPA will work
 with States to evaluate .the effectiveness of this Policy and, in 1997,-EPA wfll consider. '..'_••:
 whetherthis Policy should be continued, modified or discontinued.   •  " . •      ' -    '•'•••
 D.     APPLICABILITY
    •     • .  .•        %  .

        This Policy applies to faciffities owned by small businesses as rigffoed here.  A small •. ,
 business is a1 person, corporations-partnership, of other entity, who employs 100 or fewer -"  •":'
 individuals (on a company wide basis)'.  This definition is a simplified version of the CAA
 §507 definition of small business. On balance, EPA deter*™"*** that-a* single definition
 would make Implementation of this Policy simple and would allow for consistent application
 of the Policy in a multimedia context.  . •'••          .'"-.'•   .     •    ...—•'
              •  .                      *   -         »       *-..-*             ...
            m    •            »                                         •              *
        This interim policy is effective immediately.  This Policy 'applies toail civil judicial •
 and administrative enforcement actions *?fo^n wid^** the authority of the environmental
 statutes and regulations that EPA administers, except for corrective action programs and the " :
•Public Water System Supervision Program under the Safe Drinking .Water Act.1  This Policy
 applies to an such actions filed after the effective date  of mis Policy, and to all pending cases
 in which the government frag not 'reached agreement in principle "with the aTfegej violator on
 the amount of the civil penalty.    .  ...     .          '•   .    _- -. . . •  -/       ;   -..
 « •        «,*f     •                -^.-        _    ..     .ft,    ..          •
 • •                  •      .•         '»'*•"*•        "     ""    '.*''         ",'•'
   .     This Policy sets forth how the Agency expects i to  exercise its enforcement discretion   • :
 in deciding on an appropriate enforcement response and determining an
 settlement penalty for violations by smaTT businesses.  This Policy is to be used for settlement
 purposes and is not intended for use in pleading, or- at hearing or triaL To the extent mat
 this Policy may differ from .the terms of applicable, erforcement response policies under '.  ,
-media-specific piufeiams, this document supersedes those policies. .This Policy Supplements, ...
 but does^riot supplant the August.12, 1994 Ertfbrcement Response Polity-far Treatment of •'••'. '.
 Information Obtained Through dean Air Act Section 507SmaU Business Assistance :
'                "       '              '"'"                  "                  •
    1 This Policy does not apply to corrective action programs (such as CERCLA,'RCRA §7003, and
SDWA §1431) because mese programs are primarily .remedial in nature..and generally dp not seek
penalties. This Policy does not apply to the Public Water System Supervision Program'.because EPA
is developing another policy which addresses compliance by small communities.

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 Compliance IncentiTes for Small Businesses     *** June 1995 Interim Policy •*"       :.  page 4
        C3UT3ERIA'FORCIVILPENALTYMTEIGATION             ...
 EPA will rfi"""gte or tmtigate its settlement penalty demands against sr»"fll businesses based "
 on me following criteria:     -..•,.'..              :    .  .    •         ••-.-'

 1) For purposes of sections F(l) and FC21. the small business has made a good faith effort to

 'affistahce from a non-confidential government" or government supported progtam that" offers   •
 services "to small businesses (such as a SBAP or state university), and the violations are    '  "
 detected                                         "
   .      . ..             .                      •   •   -.,*•   • -_•    -     .    •• —
 • Good fejth does not exist if an. agency specifically offered, a compliance assistance program-  '
 • '- - - -uing the relevant regulated activities to the .business and it failed to paxticipatejn- such
concet
.•program.'        •           •  ,                '•         •. "  '          '     ''.'.-•

 2) This is the small businesses first violation of this TegtrirerneiiL  This Policy applies to
 businesses that have not previously .been subject to" a warning letter, notice of violation, field
 • 'citation, or other enforcement action by a government agency for a violation of that  .  .    .
 requirement within me past five years.  If a business, has been subject to multiple > •  :   •  '
; enforcement actions  for violations of environmental requirements in the past five years, this
• Policy does mot apply even .if ^this is the first violation of this pardcular.requirement.  ...

 3) The policy does:not apply if: /     •   - -/..•"':  :' ":"•... v    •   -.^   -: "!::.•': -y-
  • : .   • a) The violatioh has cayy* actual serious hariri to public health, safety," or the  ~/: '" : '••
"; environment^ or '••"  ;,:-.•. •... .••*"'"
 "    '-:'- '4) -The violakon may ""present an imminent ana^st*stanti4_endangerment tapublic  '  •>
  " - " "^ '4't     •  '                     • '   m         '     .••.*.       * .        "."""
 heaEnlor the environment; or '".. ••   '.'   .  .'..   ':-'•"•  -  , '.-   '  "•-.  ".-.-•"
•''. '••• •" c) .The violation'pTesents a sigru^ant health, safety or .environmental threat (e.g.j";.  .
'• violations involvmg hazardous or toxic substances may present:such.mreats). .i.- :-;".-/".:.

 4^  Ttie violation does'Tint involve criminal conduct.-    :   ......   -   .'         .   -
  •'  '  *  If the compliance or technical assistance program keeps me" information obtamed confidential
  0-e., does not share or disclose facility specific infonnatioa on compliance status with a regulatory
  agency) mis Policy does not apply.. However, if a small business.wishes to obtain a corrections  .
  period iter receiving compliance assistance from.a confidential program, me business need only _
  disclose the violations to the appropriate regulatory agency pursuant to criterion 1 and comply wiuv
  &e other provisions of this Policy.

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 Compliance Incentives for £"«»n Businesses     « * * June 1995 Tn*Ar4m Policy * * »           page 5


 5) The business corrects the violation within the corrections period set forth below.    •   • .
   *                        •""*"           '••*
     •   Small businesses are expected to remedy the violations within ihe shortest practicable
 period of time.  Small businesses may take up to 90 days following detection of the violation
; to correct the violation, or to take substantial steps to correct the Violations (e.g. apply for
          permits, secure financing, order equipment).  For violations that cannot be
 corrected within 90 days, the correction period may be extended for an additional period not
 to exceed 90 days, so long as the business enters .into a written agreement .that sets forth the
 additional collection period and any additional steps to be undertaken by the business to  '  •
• achieve compliance. The schedule may extend for an additional period of 180 days, Le.., up  ;
 to a period of one year from me date the violation is detected, only if necessary where the
 small business corrects the violation by implementing pollution prevention measures.
 Correcting the violation includes remediating.any gnvirr>Ti'PifPta^ .harm agsnciated with the
 violation.3 Any collections period longer than 180 days should be incorporated -into an
 enforceable order.  The requirements of the correction period should be made dear to the  '
 gmaTi business prior to offering compliance
 F.    PENALTY MITIGATION GUIDELINES

      . EPA win exercise its enforcement discretion to .eliminate or mitigate civil settlement
 penalties as follows.

      • 1.   .  EPA will riJTrrinafR the civil settlement penalty in any enforcement.action if a
              satisfies at! of fee criteria in section E»  ".;~ •  '  ' •  '     ~  •  .•      '    .•'• '
  •  ..  2> '•-.'. jf the srnaTI business meets all of me criteria, except it needs a longer '
.corrections period than provided by criterion 5 (Le., more than 180-days for non-pollution
prevention remedies, or 360 days for pollution prevention remedies)^ EPA wiirwaive up to .
1009S#o£me gravity component of the penalty, but may seek the full amount of any ••'-
economic benefit associated witn the violations.4.       "   -.  . '  .-.   ...     '   "'"   (    .

•  ;."   -3.    If a small business has not met all the criteria above^ but has otherwise made a
good faith effort to comply; EPA has discretion, pursuant to its  applicable policies, to refrain.
from .filing an enforcement action seeking civil penalties or to mitigate its demand for
 •   3  If significant efforts will be required to remediate the harm, criterion 3 is likely not to have
been satisfied.                   •                  -      ...

    4' In determining how much of the gravity component of the penalty is appropriate, EPA should
consider the nature of the violations, me duration of me violations, the environmental or- public health
impacts of the violations, good faith efforts by the small business to promptly remedy the violation,
and the facility's overall record of compliance with environmental requirements.

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    «    .               •
 Compliance laceDtxres for Small Businesses   '  -'* * *- June 1595 Interim Policy • * *           page 6
 penalties to the maTrininm extetf appropriate.; These "policues generally recognize good faith
• efforts to ^comply and allow Jbrniitigalicm of fee "penalty where there is a documented   " •
 inability to pay/all ora portion of the penalty, thereby placing "emphasis on enabling the
              to                               ''                 '      '
 G.    OTHER FACTORS.

 ... ..,••"  To ensure feat this Policy enhances "and [does not compromise publk- health and fee  •••
•; environment, fee following conditions applyV :-.">.'.•;._- ^\.t       ".•••'     -:-

 1.    Violations detected through federal, " state, or local enforcement inspections or reported
 to an agency as required by applicable regulations or permits remain fully'enforceable.-
    .' \    .".-_••••••"*   •             rf      *. /         •»    "        .     •  .
 2.  '  A business is subject to all applicable enforcement response policies (which may
 inclndr discretion whether or not to take formal enforcement action) for all violations that
 had been detected through compliance assistance and were not remedied within the.
 corrections period. • The penalty in such action may include fee time period before and
 ' during the correction period. __  _    .   .:        -         .......

 * 3i    A business's good faith- efforts to correct* violations. detected during compliance
          should be considered as a mitigating factor, in determinina an appropriate
; enforcement response or penalty in a subsequent enforcement action.. • -.However, a State's or
 EPA's actions in providing compliance assistance is not a legal defense in any. enforcement  •
faction. This iPoIicrdoes not ^limit EPA or a state's discretion to use- information on .     '.  .
                 *•   •          • *"     "'•*.•     . '            '    '.-••"
;. violations revealed, through compliance assistance as evidence. in subsequent enforcement.. •
                             -     •••   '                 -                 •
 H.    APPUCABIIITy. TO STATES..
 .>.-'.' .   "EPA recbgnizes tf«t states are partners. in enforcement and. compliance assurance.,
 Therefore, EPA will defer to state actions in delegated oFzpproyed programs that are •'  - ..."_•
 generally consistent wife fee guidelines set forth in this Policy.   '•     .";  ".  '.. •         :.

       ' This" Policy does not require SBAPs to provide to" EPA information that identifies the
 . names or locations of specific .businesses feat are found to be in violation through compliance
 . assistance. EPA recommends, .however, .feat whenever an agency provides a correction
 period to a gmall business, the agency notify fee appropriate EPA Region or state of its
 action, to assure that -'federal and state enforcement responses to. fee identified violations are

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. Compliance Incentives for SmaB Businesses
June 1995 Interim Policy
page?
  consistent A state program that offers confidentiality may/not also offer a corrections period
  for thie y»rng violations (see footnote 2).4 .      •        "                "    ".  ,   •'
         Li developing this Policy, EPA balanced three primary considerations.  First, the "
  Agency is seeking to provide States with, ample opportunity to adopt innovative approaches to
  environmental compliance.  Thus, the Policy provides the parameters within which Stales
 •frTVe fJg*ibffity tn taflnf ffRAPg to th'gjr T>ee*fc_                ; '   '             . .    •  '

 • •      Second, EPA recognizes that participation in SBAPs by individual businesses is..     :
  typically voluntary: ^Assistance is provided generally upon request.  Thus, the Agency is .
  seeking to assure states of the'ability to provide incentives mat wfll encourage many small
  businesses -to participate in SBAPs.:                            ^.~»•-••.       /        . •
    *        *          •     • ".'                          *»             **•
         Third, the environmental statutes covered by this Policy generally require, as a
  condition of delegation or authorization, that programs be consistent with Federal
  requirements and that states have the authority to take appropriate enforcement action with.
  respect to violations.6  Thus, EPA has an obligation to ensure that state SBAPs are
  structured so as to maintain an appropriate level of enforcement authority within delegated or
  authorized stale programs.  The Agency believes this-Policy will allow states  sufficient
  latfrnrf* to use an appropriate- combination of delegated stale enforcement authority and
  compliance assistance activity to improve compliance in  the small  business community.
          t
        > .t
     s  The CAA §507 policy establishes criteria for EPA approval of SBAPs in State Implementation
 Plans to satisfy the ma-nAyt* in me CAA, and addresses confidential assistance in that context.

     6  For example, the Resource Conservation and Recovery Act provides that the Administrator
 may authorize any State to administer and enforce the Act unless he finds, among othetrthings, that
 "such program does not provide adequate enforcement of compliance with the requirements or the
 ACL 42 U.S.C. §6926(b).                '

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              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON, D.C. 20460
                           SE? I 9 ;cc5
MEMORANDUM
                                                CfrCEOF
                                              ENFORCEMENTAND
                                            CCMaiAWE ASSURANCE
SUBJECT:  Qs  and As on Interim Policy on Cotrroliance Incentives
          for Krriall Businesses'
              fr-xVx]v f 1
FROM:     Robfeir
          Office of Regulatory Enforcement
.TO:
Elaine G. Stanley, Director} _    _
Office of Compliance       ^       ••'          /""

Regional Program Divfsion Directors
Regional Counsels
     On June  13,  1995,  the Assistant Administrator issued the
Interim Policy on Compliance Incentives for Small Businesses.
The Policy was subsequently published in the Federal Register for
public comment on June 23, 1995 (60 FR 32675) .  We have^received
a variety of  questions from SPA.Regions and the public on how the
Policy was intended to be implemented.  We expect to finalise
this Policy,  with appropriate revisions, by the end of the-
calendar year.  In the interim,, in order to provide nationally
consistent guidance on proper implementation" of the Policy,  we
'have compiled answers to the most common questions.  Attached is
a "Q and A"' guidance document.

     The attached guidance document answers the following
questions:  •

1.   What is  the definition of compliance assistance for purposes
     of this  Policy?
2.   What procedures should be used to document violations'-
     discovered during compliance assistance?
3.   What are the goals and objectives of this Policy?    *
4.   What, are good faith efforts to comply under the Policy?
5.   What penalty mitigation is available if a small business
     makes a  good faith effort to comply, but compliance
     assistance was not available or was not sought?
6.   Why does the Policy apply only to "nonconfidential"
     comoliance assistance'programs?
7.   what impact does the Policy have on citizen suits?
8.   How does the Policy define.a "small business"; how does a
     parent corporation fit in?                .          .
9.   Does 'the Policy apply to violations that occurred prior to
     the effective date"of the Policy?

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                              - 2 -
     In a few enforcement cases, respondents have filed motions
asserting that a Region has failed to provide the respondent with
the benefits of the Policy.  And in a 'few cases, an
Administrative Law Judge has questioned whether this Policy
should be applied.   EPA Regions should consult with the
appropriate contact person in the Office of Regulatory
Enforcement in every case in which application of this Policy is
raised as an issue.

     The contact persons in the Office of Regulatory Enforcement
are as follows:  Steven Viggiani, Air - Stationary Sources, 202
554-2002;  Marc Hillson,  Air - Mobile Sources, 202 564-2255;
Kathryn Smith, Water, 202 564-3252;  Barbara Reilly, Toxics and
Pesticides, 202 564-4176; and Susan Garcia, RCRA, 202 564-4013.
Questions also may be directed to David Hindin in the Multimedia
Enforcements Division, 202 564^5.004, or to Karin Lef.f, 202 564-
706.8, in the Office of Compliance who are coordinating—
implementation of the Policy.

     Finally, this cover memorandum and the attached Q and A
guidance document are both public documents.

Attachment

cc:  (w/attachment)
     Steven Herman
     Small Business Ombudsman
     Regional Enforcement Coordinators
     OSCA Office Directors
     ORE and OC Division Directors
     Chief, ESS, ENRD, Department of Justice
     Assistant Chiefs, ESS, ENRD, Department of Justice

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                           Questions and Answers on
       Interim Policy on Compliance Incentives for Small Businesses
                          U.S. EPA  - September 19, 1995
1.     What is the definition of compliance assistance for purposes of this Policy?

       Compliance assistance1 -is information or assistance provided by EPA, State or
another government agency or government supported entity to help the regulated community
comply with legally mandated environmental requirements.2 Compliance Assistance does not
include enforcement inspections or enforcement actions.

       In its broadest sense, the content of compliance assistance can vary greatly, ranging
from basic information on the legal requirements to specialized advice on what technology
may be best suited to achieve compliance at a particular facility.  Compliance assistance also
may be delivered in a variety- of ways, ranging from general outreach through the Federal
Register or other publications, to  targeted conferences and computer bulletin boards, to on-
site assistance provided in response to a specjfic request for help.

       The special penalty mitigation considerations provided by this Policy only apply
to civil violations which were identified as part of a non-confidential compliance
assistance visit.  The key component of compliance assistance hi this Policy is the
detection of the violations during the compliance assistance visit.  While a facility may
discover it has violations based  on information obtained through reading a brochure,
calling a hotline or attending a  seminar, the Policy does not apply unless the violations
were detected as part of the compliance assistance.
2.     What procedures should be used to document violations discovered during the
       compliance assistance visit?

       Section E.5 of the Policy recommends that before the compliance assistance is
provided businesses should be informed of their obligation to promptly remedy any violations
discovered during the compliance assistance.  Before a government agency provides on-site
compliance assistance pursuant to this Policy or similar State policy, the agency should
provide the facility with a short document explaining how the program works and the
responsibilities of each party.. The  document should emphasize the responsibility of jhe
facility to remedy all violations discovered within the corrections period and the types of
violations which are excluded from penalty mitigation (e.g., violations that caused serious
harm).  The facility should sign a simple form acknowledging that it understands the Policy.
    1  Compliance assistance is sometimes called compliance assessments, compliance audits,
or technical assistance.

    2  Legally mandated environmental requirements include currently effective requirements
and requirements which have been enacted by Congress or promulgated by EPA and thus
will become effective within a few years.

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September 1995                                                                     page 2
Qs and As - Interim Policy on Compliance Incentives for Small Businesses


       At the end of the compliance assistance visit, the government agent should provide the
facility with a list of all violations observed.  (Any violations that do not fit within the
penalty mitigation guidelines in the policy - e.g., those that caused serious harm — should
be identified.)  If the violations cannot all be corrected within 90 days, the facility should be
requested to submit a schedule for remedying the violations within a short period after the
on-site visit, usually no longer than a month.  Documentation explaining the nature of the
compliance assistance visit and the  penalty mitigation guidelines is essential to- ensure that the
facility understands the Policy.  These documentation procedures are not burdensome and
many States already use similar procedures.
3.     What are the goals and objectives of this Policy?

       The ultimate goal of the Policy is to bring more small businesses into compliance in
order to protecTpublic health and our environment.  To this end, the Policy has two
objectives:  to stimulate demand  for compliance assistance and to stimulate the supply of
such programs.  First on the demand side, the Policy is intended to encourage small
businesses to use government sponsored on-site compliance assistance programs.  On-site
compliance  assistance programs have tremendous potential to help small businesses
understand their obligations to comply.  Without the incentives of penalty elimination or
mitigation offered by this Policy, small businesses may be reluctant to have government
agents visit  their facilities to identify compliance problems.  Thus, EPA hopes the incentives
created by this Policy will encourage small businesses to seek out compliance assistance.

       Second, on the supply side, the Policy is intended to stimulate the growth of
compliance  assistance programs by providing EPA offices, States and local governments with
the flexibility and the incentives  to create successful compliance assistance programs.  EPA
recognizes that compliance assistance programs are currently not available in all  states for all
programs and thus hopes this Policy  will stimulate the creation of additional programs.
4.     What are good faith efforts to comply under the Policy?               ' .
                                                                             i
       President's Clinton Executive Memorandum on Regulatory Reform of April'26,. 1995
(60 FR 20621) directs each federal agency, to the extent permitted by law,.use its
enforcement discretion to mitigate or waive penalties "only where there has been a good
faith effort to comply with applicable regulations and the violation does not involve criminal
wrongdoing or significant threat to health, safety, or the environment [emphasis added]."
Each federal agency has  the discretion to define what are good faith efforts to comply.

       In an effort to expand the existing compliance assistance policy under the Clean Air
Act to all media programs, and to provide the regulatory community .with clear guidance on
when EPA will eliminate or mitigate penalties pursuant to this Policy, EPA has defined
good faith under this Policy as receiving compliance assistance from a non-confidential
government or government supported program in which the violations are detected

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September 1995
Qs and As - Interim Policy on Compliance Incentives for Small Businesses


during the compliance assistance. This is the first criterion (in section E of the Policy)
which a small business must satisfy in order for a civil penalty to be either eliminated "
entirely or for the gravity portion to be mitigated. The specific penalty mitigation
guidelines set forth in subsections F(l) and F(2) of the Policy only apply where the
violations were detected as part of the compliance assistance* visit and assuming all other
provisions of the Policy have been satisfied.

       The second criterion for penalty mitigation in the Policy ~ that the violations detected
in die compliance assistance visit are first time violations - also relates to good faith.  If a
small business has received a warning letter, notice of violation, field citation, or other
enforcement  action by a government agency  for a violation within the past five years,
subsequently seeking compliance assistance for that violation "does not qualify as good faith
under the Policy.  Good faith efforts to comply are proactive and occur before the initiation
of die enforcement action.  The objective of this Policy is to stimulate new incentives for
compliance in "which companies seek help*!? complying before an enforcement action occurs.


5.     What penalty mitigation is available if a small business makes a good faith effort
to comply, but compliance assistance was not available or was not sought?

       Good faith efforts to comply require a company  to take some proactive efforts to
comply before a government agency discovers a violation or issues a notice of violation, a
warning letter or otherwise takes an enforcement action. Under this Policy, EPA has
specifically defined good  faith as receiving compliance assistance from a non-confidential
government or government supported program in which me violations are detected during the
compliance assistance.  This is the first of five criteria in section E of diis Policy which a
small business must satisfy in order for a civil penalty to be either eliminated entirely or for •
me gravity portion to be mitigated.

       As stated in subsection F(3) of the Policy,  if a violation was not discovered through
compliance assistance, but the company has otherwise made a good faith effort to comply,
EPA has discretion, pursuant to other applicable policies, to refrain from filing an
enforcement  action seeking, civil penalties or to mitigate its demand for penalties to die
maximum extent appropriate.  Subsection F(3) does not modify any of the existing
enforcement policies, but only serves to highlight the discretion that already exists in
these policies to mitigate penalties based on good faith.  Many of the media specific
penalty policies  have specific mitigation factors for good faith compliance efforts.  Further,-
in some media specific penalty policies, if good faith efforts are undertaken, the penalty
calculation automatically factors  in such efforts through a potentially smaller economic
benefit or gravity amount.  Penalties also may be mitigated pursuant to the Interim Revised
Supplemental Environmental Projects Polity  of May 1995,  or the Guidance on Determining a
Violator's Ability to Pay a Civil Penalty of December 1986.

       Finally, another way a small business (or any business) may receive penalty
mitigation is  by conducting a voluntary compliance evaluation.  If the small business,

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September 1995        '                                                             page 4
Qs and As - Interim Policy on Compliance Incentives for Small Businesses


discovers its violations through a voluntary compliance audit or self-evaluation and
voluntarily discloses its violations in writing to the appropriate government agency and
otherwise complies with the conditions in EPA's Voluntary Environmental Self-Policing and
Self-Disclosure Interim Policy Statement, 60 FR  16875 (April 3, 1995), EPA may reduce or
eliminate the gravity portion of the civil penalty.

       In contrast, some businesses have argued  that their prompt efforts to remedy a
violation after the government agency has discovered the violation through an inspection or
filed an enforcement action should be considered as good faith.  While EPA appreciates and
expects companies to promptly remedy violations after a notice of violation or an,
enforcement action has occurred, such efforts to  comply are not good faith efforts. If such
efforts were considered as good faith, there would be no incentives for companies to make
any effort to  comply until after an enforcement action had been initiated.  Good faith efforts
to comply require a company to take some proactive efforts to comply before a government
agency discovers violations through an enforcement action, issues a notice of violation, or
otherwise takes an enforcement action.                                    '—
6.     Why does the Policy only apply to "nonconfidential" compliance assistance
programs?

       EPA recognizes that many technical and compliance assistance programs offer
services to the regulated community on a confidential basis — i.e.. information about specific
companies or facilities is not shared with the enforcement agency.  Nothing in this Policy
affects the continued operation of these programs.

       The purpose of this Policy is to encourage small businesses to use compliance
assistance programs.  With respect to programs hi regulatory -agencies or sponsored by such
agencies,  the policy provides an opportunity to correct violations within a specified period of
time without being subject to penalties, while assuring  that EPA or the State retains the
authority to  address serious environmental  problems and criminal  behavior.
                                                                             *

       In the case of a confidential compliance assistance program, such an incentive is not
necessary or appropriate because the company is not exposing itself to enforcement by virtue
of its participation in the program.  Nonetheless, as indicated in the Policy, a company that
wants an opportunity to correct violations without being subject to penalties after receiving
confidential  assistance may do so by disclosing the violations to the appropriate enforcement
authority, provided it complies with the other provisions of the Policy.
7.     What impact does the Policy have on citizen suits?

       Many of the statutes EPA implements contain provisions authorizing citizens to
commence actions seekkg civil penalties and injunctive relief for certain violations. These
provisions generally  require citizens to follow certain procedures in bringing these suits (e.g.,

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September 1995                   .
Qs and As - Interim Policy on Compliance Incentives for Small Businesses


provide the alleged violator and EPA with advance notice of the suit) and bar such suits if
the violation is being appropriately addressed by a state or federal enforcement action.
Whether a small business that receives compliance assistance pursuant to the terms of this
Policy will be protected from citizen suits will depend on the specific facts ot the case and
the specific citizen suit provision of the relevant statute.


8.     How does the Policy define a "small business";  how does a parent corporation fit
in?

       For purposes of this Policy, "small business"  means a business owned and operated
.by a person, corporation, partnership, or orner entity that employs 100 or fewer  individuals
on a company-wide basis.  This means that a facility with 50 employees that is a division or.
subsidiary of a_cprporation that has more than 100 employees on a corporate wide basis is
not a small business.  Thus, any business tSat'is owned by a parent company where the
aggregate employee number exceeds 100 persons is ineligible for consideration -as a small
business under this" Policy.   The number of employees should be considered as full-time
equivalents on an annual basis and does not include contractors and consultants.   Employees
who work less than 35 hours per week are generally  not considered full-time employees.
For example, for purposes of determining the applicability of this Policy, a company with
150 employees, with 120 of those employees working only 20 hours per week, would be
considered to have 90  full-time equivalents and thus would fit the definition of a small
business.
 9.     Does the Policy apply to violations that occurred prior to the effective date of the
       Policy?

       Yes. Section D of the Policy states:  " This Policy applies to all [enforcement] actions
 filed after the effective date [June 13,- 1995] of. this Policy, and to all pending cases in which
 the government has not reached agreement in principle with the alleged violator on the
 amount of the civil penalty."  This means that the date when the violation occurred is
 irrelevant for purposes of determining application.  Cases hi which an agreement on(a civil
 penalty had not been reached to prior to June 13, 1995, are potentially subject to the Policy,
 assuming all other conditions of the Policy are satisfied.

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         UNITTD STATIS LNTIRONMENTALBROXECTION AGENCY
                       WASHINGTON, D.C 294M'
                                5 £84

                                                     or
                                                       ANDCOMPUAXQ*


 MEMORANDUM

 SUBJECTS . Guidance for Calculating ch» Economic Benefit of
        \ : Nonccapliance for a. Civil Penalty Assessaent
                            M   —•—  i*V *-S   •
 PROM:     Courtney M. Price (^J&4mL-^ * *j T7X * f.r-  ,
          Assistant Administrator for Enforcement
            and Compliance Monitoring

 TO:       Regional Administrators
          Associate Enforceaent Counsels
          OECM Office Directors
                                        ^
                                                               w


 I.   PURPOSE •

     This guidance amplifies  the material in the Appendix of
 GH-22,  'Framework for Statute-Specific Approaches  to Penalty
 Assessment."  The Appendix presents ^'"'description  of how to
 calculate the economic benefit of nonc'ompliance as part of
 developing a civil penalty.   A new ccmputer-'mcdel, BEN, is a
 refinement of the aethodology for calCuIaYihg the  econccic
 benefit cf nonccnpliancei •          ";;;"   "::

     By refining the aethodc  by which we calculate the cconcaic
 benefit cf noncompliance, wo  will:

     1.  Respond to the problems that ehfcrcesent  and progres
 off icon identified concerning methods :fo? :.*.lcul^ting ths
 eecnoaic benefit component of a civil penalty;

     2.  Ensure among the a«dia programs appropriate* consistency
 in calculating the economic benefit ccacponent cf a civil penalty;

     3.  Ensure that the economic benefit cf noncomplitnc*  Con-
 tinues to be a fairly valued, reasonable component of  a  civil
penalty; and

     4.  Ensure that the assumptions  and data used in  SSN to
calculate the econonic benefit component can be de^?nded at
either an adainistrative hearing or  a judicial  proceeding.

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                          Exhibit I .
           •         '         BEN
A.  Accessed via ttrainal to EPA's IBM computtr in Durhaa, N.C.
B.  Can  be run in either of two oddest
                                       •
    1.   Standard mode:
         a)  Requires  5  inputs:
             i.   Initial Capital Investment
            ii.   Annual  Operating and Maintenance Expense
           iii.   First Month of  Honcompliince
            iv.   Conpliance Date
             v.   Penalty "Payment Date
         b)  Relies on realistic standard values for
             reaaining variables:          . '   '             .
             i.   A set of standard values for private
                 companies
            ii.   A set of standard values for nunici-
                 pally-owned or  not-for-profit  coapanies
                         •
         c)  Would be  used for final calculation of econoaic
             benefit, unless the  violating firm  objected and
             supplied  all its own financial data
    2.   Specific node:
         a)   Requires  13 inputs             •               .
         b)  Would be  used if violating firm supplied .data or
             if  EPA staff researched data
C.  Is «as£-to use
    1.   Optional on-line docuaontation will guide inexpori«ncod
         users through each step of the model
    2.   Written documentation will be available by December
         1984
D.  Is based on codern  financial p-.-ir.ciplcy

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                               -2-
 II.  SCOPE

      This guidance describes BEN, the new computer model, in
 terms of how this model resolves the identified problems related
 to the us* of CIVPEN.  EPA personnel can use BEN to calculate the
 economic benefit, a violator gains frca delaying capital expend!-*
 turos for pollution control equipment or-froa avoiding the costs
' of operating and maintaining pollution control equipment.
 Exhibit I summarizes BEN,

      EPA personnel cannot use BEN to calculate the economic
 benefit component of a civil penalty if a violator's action
 does not* involve a delayed or avoided expenditure.  Under
 these circumstances, program, offices may elect to develop
 statute-specific formulas as provided in GM-22 for calculating
 the economic benefit component of a civil penalty.  These
 formulas would be used to develop civil penalties in response
 to actions such as certain TSCA marking/disposal violations or
 RCRA reporting violations.  The rule of thumb in the general
 penalty policy would hot be appropriate for these types of
 violations.

      OPPE is considering the feasibility of developing a second
 computer model or rule of thumb formula that could be applied
 uniformly to violations that do not involve delayed or avoided
 expenditures.


 III.  NEW CIVIL PENALTY POLICY APPROACH •
                           •
      Regional personnel may use the rule of thumb described in
 GM-22 to develop a preliminary estimate of the economic benefit  .
 component of a civil penalty.  Th* rule of thusb is for the
 convenience of EPA and is not intended to give a violator a lover
 economic benefit component in a civil penalty.  Regional personnel
 should consider whether an estimate of economic benefit derived
 with  the rule of thumb would be lower than an estisate calculated
 with  BEN.   For example, the longer the period of noncoepliance,
 one more the rule of thuab underestimates the economic benefit
 of noncompliance.

      If EPJfcpreposes and a violator accepts the rule of thucb
 calculation-*. Regional personnel can develop the civil penalty
 without further analysis of economic benefits.  It a violator
 disputes th« economic benefit figure calculated under the  rule
 of thuab,  a more sophisticated method to develop  the economic
 benefit  component of the penalty is required.

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                               -3-

      In floral,  if the estimate under the rule of  thumb  is
 Its* than $10,000,  the economic benefit ecnponent is  not  ne
 to develop • civil  penalty;! the other factlrs in cS-2? i-J
 apply.   If the rule of thumb estimate is acre than  $lo7ooo,
 Regional personnel  should use BEN to develop  an estimate  of
 the economic benefit component.


 IV.   DSINC BEN TO CALCULATE ECONOMIC BEKEFI?  OF NONCOMPLIAMeg

      EPA personnel  should use the revised computer model  SEN
 whenever:

           1.  the rule of thumb indicates that the
          •  .   economic benefit of noncompliance is
               greater than $10,000;  or

           2.  the violator rejects the rule of thumb
               calculation.

      BEN uses 13  data variables.  At the option of  the user,
 BEN substitutes standard values for 8 of the  13 entries,  and
 the user only provides data for 5 variables.   (See  Exhibit I.I

      BEN also has the capability for EPA personnel  to enter
 for those 8 variables the actual financial data of  a  violator.
 In appropriate cases, EPA should notify a violator  of the
•opportunity to submit actual financial data to use  in SEN
 instead of the 8  standard values.  If a violator agrees to
 supply  financial  data, the violator must supply data  for  all
 the  standard values.


 V.    ADVANTAGES OF  BEN OVER OTHER CALCULATION METHODS

      The computer aodel BEN has advantages over previously
 used methods for  calculating the economic benefit component
 of a civil penalty.  BEN does not require financial research
 by EPA  personnel.   The five required variables are  information
 about capit*&_costs, annual operation and maintenance costs,
 and  the datanVfor the period of noncompliance.  Further,  BEH
 has  tho flexibility to allov a violator who cooperates with
 EPA  to  provide actual financial data that may affect  the  penalty
 calculation..
I/ Although the general penalty policy cut off.point  is  S10,000,
each program office nay establish a cut otf point for the
progrca's medium-specific policy.
                                 \<\n

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                               -4-

      An economic  benefit  component  calculated  with  BEN  can be
 defended La «n administrative  or judicial proceeding  on the
 grounds that the  standard values used  in BEN are derived from
 standard financial procedures  and the  violator had  an opportu-
 nity to provide financial data to help develop the  civil penalty.

      The use of BEN  or statute-specific formulas when appro-
priate gives the  Regional Offices flexibility  in determining
 the economic benefit of nonccmpliance.  Regional personnel
 have a consistent method  for developing a civil penalty under
 several statutes  for multiple  violations that  involve delayed
 capital costs and avoided operation and maintenance costs.

      BEN is easy  for a layman  to use*  The documentation  is
 built into the program so that a Regional user always has
 updated documentation and can  use the  program  with minimal
 training.   States are more likely to follow EPA's lead  in
 pursuing the economic benefit  of noncompliance through  civil
 penalty assessments  because the method available from EPA to
 serve as a model  does not require extensive financial research.

 cc:   Regional Enforcement Contacts
      Program Compliance Office Directors

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       i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON. D.C. 20460
                             DEC I  6 1986
 MEMORANDUM

 SUBJECT:  Guidance  on Determining a Violator's
          •Ability to Pay  a Civil Penalty

 FROM: .    Thomas L.  Adams, Jr.  A«V.
           Assistant Admins trator for
             Enforcement and Compliance Monitoring

 TO:       Assistant Administrators
           Regional  Administrators


 I.   PURPOSE  '
      •                                          .
                                • '*
      This guidance  amplifies the discussion in the Uniform
 Civil Penalty Policy on how to adjust a penalty target figure
 when a  violator claims  paying a civil penalty- would cause
 extreme financial hardship.  This guidance was developed to
 meet the commitment  made  in the Unif orm . Civil Penalty  Policy
 issued  February 16,  1984, and in response to Regional  Office
'requests for amplification of the "Framework for Statute-
 Specific Approaches  to- Penalty Assessments" (GM-22).


 II.   APPLICABILITY

      This guidance aoplies'to the calculation of civil
 penalties under  medium-specific 'policies  issued in  accordance
 with  the Uniform Civil- Penalty Policy that EPA imposes on:

      1.   For-prpfit publicly or closely held entities; and

      2.   For-profit entities owned by not-for-profit entities.

      This guidance does not apply to:

      1.   The calculation of civil penalties that EPA imposes
 on municipalities and other not-for-profit entities; o.
     2.  A violator who files for- bankruptcy or ^.
proceedings after EPA initiates  the enforcement ac

                                                            FEB 2 5 '9

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 III.  SCOPS                       .  •

      This guidance  only gives  a "general evaluation  of the
 financial health of a  violator and the possible effects of
 paying a civil penalty' for  the purpose of settlement.
 negotiations.  It describes when to apply the ability to pay
 factor and provides a  methodology for"applying the  factor"
 using a computer program, ABEL.

      The guidance does not  prescribe the amount by  which EPA
 may reduce a civil  penalty  if  the ability to pay factor is
 applied.  The methodology, in this guidance will not calculate
 a specific dollar amount that  a violator can afford in civil'
 penalties nor does  it  provide  a way to predict whether paying
 a certain amount for a civil penalty will cause an.  already
 financially troubled firm to go out of business.

      For an ability to pay  analysis, EPA needs "specific financial
 information from a  violator (see section V).  EPA includes the
 financial data in a litigation report only when the data are
 requested by the Department of Justice or'offered by  the violator..


 IV.   THE ABILITY TO PAY FACTOR '"

      Under the Uniform Civil Penalty Policy, EPA-may  consider
 using the ability to pay factor to adjust a 'civil penalty
 when  the assessment of a civil penalty may result in  extreme
 financial hardship.  Financial hardship cannot be expressed
 in absolute terms"   Any limitation on a violator's  ability
 to pay depends on how .soon  the payments must' be made  and
 what  the violator has  to give  up to make the payments.  A
 violator has several options for paying a civil penalty:
                                     '—       '           ~-%
      1.   Use cash on hand;

      2.   Sell assets;               '                         ,

      3.   Increase debt by commercial borrowing;

     4.   Increase equity by selling stock;

      5.   Apply toward  a civil  penalty for a period  of time
what would"otherwise be distributed as profit; or

     6.   Use internally-generated future cash  flows by deferring
or eliminating some planned future investments.

     Each of these  options  will affect a for-profit violator's
operations  to seme  degree.  EPA must decide whether to adjust

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                               -3

 a proposed penalty
 the gravity of  th€
 specific guidance.


 V*   INFORMATION TO DETERMINE ASTLTTV TO ?AV

                           *   issue' EPA *** request from, a
   e vi«««      -*i  information the Agency needs to eva
 the violator s claim of extreme financial hardship.  A vio
 wno raises the issue has  the burden of providing informati
 to demonstrate extreme  financial hardship.         .«««»-4

      Financial information to request from for-orofit enti
 may include the most recent three to five years" of:
     f                     ,
      1.  Tax returns;

      2.  Balance sheets;

      3.  Income statements;

      4.  Statements of  changes in financial position:
                              •   * *
      5.  Statements of  operations;
                                                 **   ,
      6.  Retained earnings statements;

      7.  Loan applications, financing agreements,
 security agreements;

      8.  Annual reports; or

      9.  Business services, such as^jpompustat, Dun  and
 Bradstreet,  or Value Line.                           ~~

      Tax returns are the most complete and in the most  cc
 tent  form for analysis.  Tax returns also provide f inane:
 information in a format for direct 'input into ABEL.  Anm
 reports are  the most difficult to analyze and may r«cuir«
 the assistance of a financial analyst.

     When requesting information informally or through
 interrogatories or discovery,  EPA should ask for «£••  £<
 five vears of tax returns  along with all other financial
 information  that a violator regularly attains as  busin.
 records.   If  a violator refuses^to give  »*_£• "flfti
 to evaluate the violator's ability to pay,  r.PA should ••
the full  calculated penalty amount under the  assumption
the violator  can  pay-

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                              -4-

 VI.  CONFIDENTIALITY OF FINANCIAL INFORMATION

      A violator can claim confidentiality for financial
 information submitted to EPA.  In accordance with the  regu-
 lations on confidential business information,  40 CFR 2.203,
 EPA must give notice to a violator that the violator nay
 assert a business confidentiality claim.   EPA's  notice must
 contain the information required in 40 CFR 2.203.   The notice
 must include a statement that if the violator submits  financial
 information without a confidentiality claim,  EPA may- release
 the information without further notice to the violator.

      The violator can make a claim of confidentiality  for
 financial information in a cover letter accompanying the
 information.  Information in published annual reports  would
 not be entitled to confidential treatment.
 VII.  APPLYING TEE ABILITY TO  PAY FACTOR

      Under the terms  of a consent decree,  a violator pays  a
 civil penalty in addition to  making  any capital  investment
 necessary to come into compliance.-  EPA considers  the  costs
 of attaining compliance when  applying the  ability  to pay factor
 to a  civil penalty calculation.

      EPA determines whether to apply the ability to pay"
 factor using a four-step process:

      1.   Determine, if possible,  whether a violator plans  to
 claim extreme financial 'hardship;

      2. •  Determine'whether criteria  in the Uniform Civil
 Penalty Policy and medium-specific guidance require consideration
 of ability to pay;      •-'.,•'                •

      3.   Evaluate the overall financial health of  a violator's
 operations by analyzing financial information provided- by  a
 violator  or from other sources,  such as business services; and

      4*   Project the  probabilities, of a violator having future
 internally-generated  cash flows  to evaluate how paying a proposed
 civil penalty may affect a violator's financial-decisions.


 VIII.  FINANCIAL COMPUTER PROGRAM

      EPA's computer program,  ABEL, assists in evaluating the
 financial  health, of for-profit entities, based on  the estimated
 strength  of internally-generated cash flows.  A3EL uses financial
 information on a violator to  evaluate the  overall  financial
health of  a violator  (step 3  above).  The  program  uses standard

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 financial  ratios  to evaluate a violator's abili-ty to bo—ow
 money and  pay current and long-term operating expenses.

      ASEL  also projects the probable availability of
 future internally-generated cash flows to evaluate some  of a  "
 violator's options for paying a civil penalty (step 4 above).
 EPA  is developing a user's .manual to provide self Instruction
.in the use of A3£L 'in addition to the documentation and  heln
 aids  in.the computer program.

      Exhibit 1 is a hypothetical use"of ABEL to evaluate a
 violator'^ financial health.  If the ABEL analysis indicates
 that  a violator may not be able to finance a civil penalty
 with'internally-generated cash flows,  EPA should check all
 available  financial information for other possible sources
 of cash flows for paying a civil penalty.

      For example,  in corporate tax returns,  item'26 of
 Schedule A (cost  of goods sold) sets forth deductions  for
 entertaining,  advertising, and professional dues.   Schedule E
 shows  the  compensation of officers. -In Schedule L (balance
 sheets), item 8 sets forth investments'that may include
 certificates  of deposit or money market funds.   These  types
 of assets  and expenses 'do not directly affect operations and
 may vary considerably from year to year without adversely
 affecting  the violator's operations.  Because a civil  penalty
 should  be  viewed  as a one-time expense,  these kinds of assets
 and expenses  could be sources of cash  for a  civil  penalty.

     Using  the  sources of financial information from the example
 above,  liouid assets such as certificates of deposit and
 money market  funds could be used to pay a penalty.   Expenses
 for advertising,  entertaining, or professional  dues could be
 reduced for a short period to pay a'civil penalty.   A  corporate
 officer might even be willing, to take  less compensation  for •
 a short period.  A combination of options like  these may
 produce enough  cash flow to pay a civil penalty Y«hout
 causing the violator extreme financial hardship in meeting
 operating expenses.


 Attachment

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                        -.---.              ui.
                       --•   >        -.-              - iL_n'— '—-'ic^n\vIP r
             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY?^
                       WASHINGTON. D.C. 20460           J >vi  OCT 2? 1392
                                                       :E Or SEGIOSil. «••!»«


                          QCT ! 3 '332
HZMORA1TOCX

SUBJECT:   Change in Kethodology f or^Pcttteaiping the BSN Hodel's
           Discount Rate
FROM:   .   Herbert H.  Tate,  Jr.
          , Assistant Administratdrf or" 'Enforcement
                         ^      *
TO:        Assistant Administrators
           Regional Administrators


     Effective thirty days  from the issuance of this memorandum,
the  Office of Enforcement (OE)  will employ a different
methodology for calculating the BEN computer model's discount  '
rate.   As a result of this', change, the discount rate will decline
from the current 17.2% to 11.9%.   The purpose of this memorandum
is to  notify you and your .respective staffs of the change and to
discuss some of its implications.


Background

      .  The Office of Enforcement first developed an economic
benefit model in 1978.  One qf the central theoretical  issues in
the  model's development was deciding on an appropriate  discount
rate to evaluate pollution  control^expenditures. • The^discount
rate is an interest rate employed by the model -in performing
•benefit analyses.  After extensive.- study of this issue, and
careful consideration of our corporate finance consultant's
views,  OE decided on an "equity* based rate.  The equity discount
rate approach was later adopted in 1984 when the Agency developed
the  BEN computer model.2-   The Agency based its decision on its
understanding of prevailing corporate financing of compliance
expenditures, which was that pollution control investments did
net  contribute to a firm's  profit-malcing activities.  Thus it vas
logical to assume that a firm raised the capital for
      1 The ABEL model,  which calculates a violator's financial
ability  to comply,  clean up or pay a civil penalty,  will socn
employ a WACC discount rate.  The-. discount rate plays a different
role in  ABEL:  ABEL is concerned with a firm's  overall financing
as  opposed to just the financing of pollution control equipment.
                                            .   ipq

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 investment by selling shares of sto^v  / •
 one of the most expensive wavs>«J?   U'e: •**** financing),
 expensive the finScSrofSi^^^3'  **•
 larger the economic
 main   mpng^^                    *«"* rejected^
 capital (WACC).  WACC is SF.JLS2  ^S^ avera*e cost of













     The equity financing assumption remains a viable
 methodology,  and is supported by a segment -of expert opinion
 22™ ^S^i1?1*' *?! f*211* fJ»»S°» assumpliol 8 no?
 wrong.   Nevertheless, it is our view and the view of many top
 corporate  finance experts that the WACC financing assumption is
 the more convincing theory.  In addition,  the WACC assumption is
 more progressive than the equity assumption  in that it regards
 pollution  control expenditures as normal business expenses.  This
 is more  consistent with the Agency's perspective  in this area and
 is more  in the corporate finance mainstream  than  assuming only
 equity financing.  For these reasons, the Agency  is now adopting
 a WACC based  discount rate for BEN model analyses.   A new version
 of the BEN model, BEN92, will be -available on the mainframe
 computer in thirty days.  Users will have a  choice  of which mod«l
 to use "until  February 1, 1993.  After that date,  only BEN92 will
 be available.   New BEN User Manuals should be in-  the mail in
 early January.             .


 Impact of the Chanoe on •Economic; Benefit Calculations

     Because WACC is a weighted average  of both borrowing and
 selling shares  of stock, the cost for financing pollution control
 investments, as calculated by BEN,  is now  substantially lover.
 Since the cost  of financing is a key assumption -.in  the BEN aodcl ,
 lowering the discount rate  from 17.2* to 11. 9* , will result in
lower benefit calculations  for businesses.   (It will have no
effect on not-for-profit entities.)  In a typical case, the

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                                 3 .

 benefit analysis will be 25% to 30%. lower.2

      The 11.9% standard value represents the average WACC rate
 for a business.  The BEN model automatically defaults to this
 value unless an alternative WACC rate is substituted.  If the
 Agency's own expert witness feels a different WACC value is more
 appropriate, then that value can be substituted.  (In some cases,
 the corporate-specific WACC rate will actually be higher than the
 standard WACC value.)  'EPA enforcement professionals, should not
 make this determination on their own, or on the recommendation of
 a violator's expert.  Determining alternative WACC values is a
 complex matter that must be.left for the Agency's experts.  At
 the same time> it is important .to note that nothing in this
 memorandum prohibits EPA"-iLitigation teams'from using an'^egui^y-
 based discount rate should*our expert feel it is appropriate.''


 Application to Aaencv Enforcement Actions

      The need to recalculate benefit analyses will depend upon .
 what stage the case is in.   For. purposes of this memorandum, we •
 will divide the cases into-three categories: 1) cases that  are.
 settled, 2)  cases where no penalty  analysis has been transmitted
 to the defendant other than the figure in the complaint, and
 3)  cases where a figure has been transmitted to the defendant,
 but the case has not settled.

      1.   Settled Cases
                       •
      If a case has settled or there is agreement as to the
 penalty figure even though there is no final settlement, there
 should be.no recalculation of the benefit.  It is important to
 emphasize that the equity theory is^not  wrong, and those
 settlements/agreements were arrived at through good-faith
•negotiations. .There is no reason to disturb those results.

      2.   Cases Where the Government Has Not Presented the BEN
           Analysis to the Defendant

      If a case is at the stage where the defendant has not y«t
 seen any BEN analysis, then the litigation team will use BEN92
 even if that requires recalculating the  benefit portion of the
 penalty.           •   •                   •
      2  The actual change in the benefit figure may be less than
 25% or  more than 30%.  The 25% to 30% range is for the typical
 case.   The extent of the change depends on the cost and data
 inputs  used in the analysis.  For example, a BEN analysis for a
 short tera violation involving a mostly operation and maintenance
 expenses might only decrease slightly with, the new discount rat*.

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                                 4
     3.   Cases Where the Government Has Presented the B2N
          Analysis to the Defendant, But There, is No Final
          Agreement as to the Penalty                 *•««.

     The more complex situation- is where the  defendant has' seen
an Agency benefit analysis, but there is neitherlm agretLS
over the penalty nor a settlement,  in these  cases,  the
litigation team may decide in its discretion  whether to
recalculate the benefit component using BEN92.  Each case is
unique, and it makes sense to allow this flexibility rather than
to impose one rule for all the cases in this  category.  While we
are allowing each litigation  team in this situation tie
flexibility to use either .version of BEN, the litigation "team
should be cognizant of the' implications of staving with'BENSO
the previous version of .BE*;.   There are two points to keep-in-
mind.

     First, the change in the discount rate will  be  public
information shortly.  Many defendants, particularly  those facing
substantial penalties based on economic benefit,  are likely to
become aware of the change.   The litigation teams that stay with
equity-based benefit analyses should carefully  consider the
impact on negotiations if the defendant hears about  the change
from sources other than the Agency's negotiators.

     Second, if the litigation team negotiates  over  an equity-
based number but .starts discovery, our expert witness would most
probably support the WACC view since it will  be the  official
Agency position.  Thus, the litigation team might be faced with
the anomalous situation of seeking a larger economic benefit
amount at settlement than it  would in discovery or at trial or
hearing.  Depending on the. amount- of economic benefit contained
in the proposed penalty,  this could create an obvious incentive
for defendants to hold out for a trial or hearing rather,than
settle-the case.  Litigation  teams, should carefully  consider the
impact on their cases in  deciding whether to  recalculate the
benefit using BEN 92.                                      ,
  * "

Litigation Practicalities

     Because the WACC-equity  dispute"became a major  issue in a
number of our enforcement actions, several litigation teams us«d
it as a reason to justify a lower bottom line settlement penalty.
While we entertained those considerations in  the past, the ch&ng*
in methodologies will" remove  this issue from  the  "litigation
risk" category.  So while the bottom line settlement  figures aay
drop due to tie recalculation of the benefit  number, the bottom
line figures should not be affected henceforth by  any litigation
risk over the discount rate.

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     Should you have any questions about this memorandum,  please
contact Jonathan Libber of my staff. • He may be reached at
(202) 260-6777.'                    .


cc:  Enforcement Counsels
     John Cruden, Department of Justice
     Regional Counsels
     BEN Users'

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              ,UNrrEDSTATESSNV«ONMENTAl.PROTECnOf* AGENCY
                         WASHINGTON. D.C. 20460                    h


                                                               ">
                              13
                              * ^^
                                                          OFFCEOf-
                                                        ENFORCEMENT AND
                                                       COMPLIANCE ASSURANCE
STJBJ2CT:  BEN   ABEL and CASHOUT Models on National LAN Platform
PROM:     Rolaen, Director
        •  Office of Regulatory Enforcement

TO:      ' Addressees                                   •


     EPA's  Office of Enforcement and Compliance Assurance (OECA)
is making available on the Agency LAN platform three financial
analysis/penalty assessment computer models.   OECA developed
these three computer models to assist the enforcement program in
its penalty assessment and cost recovery responsibilities.  The
three models deal with three different financial issues that
.frequently  arise in enforcement cases: l) calculation of the
economic 'benefit from delayed and avoided compliance;
.2} assessment .of ability to pay for clean-ups, compliance and
civil penalties; arid 3)  determining the appropriate share of a
Superfund clean-up for small contributors.
                           V
     These  models, when used in conjunction with their respective
user manuals,  allow our enforcement professionals to deal
effectively in settlement negotiations with the above mentioned
financial issues.  They can achieve this effectiveness regardless
of their exnertise in finance or accounting.   But these models
are only tools; they are hot rules.  If a litigation team
believes it" has a superior alternative for evaluating any of the
above three financial issues,, it should discuss that alternative
with the appropriate pebple in the Multimedia Enforcement
Division.
                                                             t
     To access the models, select the Agency LAN Services or
ALSMenu option on your local LAN menu.  Next, select INFORMATION
SERVICES.   ABEL, BEN AND CASHOUT are located under
LEGAL /REGULATORY category.  For those Regional personnel who
already have the models on your local LAN's,  you should request
your -espective LAN administrators to remove those versions of
the models.   From now on you should just use the models on the
Ace~-v L*N  Se-vices or ALSMenu option as only the National LAN
pfatforTwill" be periodically .updated.  In fact, the first update
is 'scheduled for mid-December.

-------
     There are user manuals for all three models.  They explain
how -to use the models and how to understand their outputs.
Copies can be obtained from Jonathan Libber of the Multimedia
Enforcement Division at (202) 564-6011, although they should be
available through a Ian or bulletin board in the near future.
All the models and their respective' user manuals are available to
the public through the National Technical Information Service
(NTIS).


The BEN Model

     The economic benefit or nBENw model, developed in 1984,
calculates how much violators save when they delay or avoid
compliance with environmental requirements.  Agency personnel
should only use BEN in settlement negotiations.  Should a case
appear headed for a trial or hearing, the litigation team should
obtain an expert to calculate the economic benefit.  The expert
will conduct his or her own evaluation based upon his or-her own
expertise, not upon the model's.


The ABEL Model
^^^^^^^^^^^^^^^^^^^^^^^^^•^•^^•"^•^^^^                                                 » *

     The'ability to pay or "ABEL" model, developed in 1986,
evaluates for-profit violators' claims of inability to afford
penalties, clean-up costs or compliance costs.  Violators raise
the issue of inability to pay in most of our enforcement actions
regardless of whether there is any hard evidence supporting the
claims.  ABEL was designed to permit our enforcement
professionals to quickly determine if there is any validity to
those claims.

     In order to simplify the 'analysis for our enforcement
professionals, the ABEL model focuses only on cash flow.  Because
it ignores"such sources of funds as assets, inflated/unnecessary
expenses,  and. corporate manipulation^ it is biased heav-iiy'  in
favor of defendants.  Thus if the litigation team finds  a
negative or indefinite ABEL analysis, the team must  look at these
other sources.  For that effort, the litigation team may ne€d
expert assistance.

     Should a case appear headed for trial or hearing,  the
litigation team should obtain an expert to perform  this
evaluation.  The expert will conduct his or her  own evaluation
based upon his or her own expertise, not upon the model's.


The CASHOUT Model

     The CASHOCT model, developed in 1992, determines in current
year dollars what all the future costs  of  a  Superfund site will

-------
 be.  Since those costs could be as much as 50 years in
.futur;,  this allows the enforcement professionals in t
 Superfund program to quickly determine what tee total
 cost of  a clean-up would be.  Then they can use that
 "cash out" of the case tee small contribuSrS?  They nus'
 appropriate portion of tee CASHOUT number, and teen they are  out
 °V^r-CaS?;  «»;J»3« contributors have to stay-in tee SJe
 But this allows tee enforcement staff .to focus their effort!  on a
 more manageable number of potentially responsible, parties.

     As  with the BEN model, :CASHOOT prompts tee user for costs
 dates and certain interest and tax rates.  And as with tee other
 two models, if the case appears headed for trial, tee litigation
 team should obtain an expert to perform this evaluation.  The
 expert will conduct his or her own evaluation based upon his  or
 her own  expertise, not upon the model's.


 Expected User Community .                                 ^.

     The projected users of these three models are the
 environmental enforcement professionals in EPA, the Department of
 Justice, • State and ' local' government environmental .enforcement
 professionals and State Attorneys.General.  There are currently
-about 600 users of tee models who access teem through the EPA's
 mainframe computer.   This includes users from EPA Headquarters,
 the Department of Justice, the 10 regional offices and over 40'
-States.


 Sgniioaent Needed

     No  special equipment is needed to operate tee models.  Any
 IBM compatible mainframe computer will work as long as it is
 connected t.o a LAN containing tee computer model.


 Training                    -   .       .          .

     All three models are very user friendly, and users need  not
 know anything about corporate finance, accounting or computers to
 be effective at using the models.  OECA will be making available
 video taoe courses on. tee BEN and ABEL models to all governmental
 personnel.  Users are encouraged to contact Jonathan Libber
 should they have any questions or concerns about the models'
 operation, or effective use in enforcement actions.


 Updating

     OECA updates tee models annually, usually some time in the
 late summerV  The Agency LAN's will be updated shortly after  the
                                JMf

-------
updates are completed.  For further information about the models,
contact Jonathan Libber of the Multimedia Enforcement Division at
(202) 564-6011.     •"
                                         «
                                         /

Addressees          •

Director, Office of Compliance
Director, Office -of Site Remediation Enforcement
ORE Division Directors
Regional Counsels -   .          .
Water Division Directors.
Hazardous Waste Division Directors
Air and Toxics Division Directors
IRM Branch Chiefs     .   -

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                 /EJJ7IR°NMENTAL PROTECTION AGENCY

                      E£S355? ***> COMPLIANCE ASSURANCE
                       ?°RCEMENT  INVESTIGATIONS CENTER
                      53, BOX 25227, DENVER FEDERAL CENTER
                        DENVER, COLORADO 80225
                                             DATE:   Hatch-Si,  1996
MEMORANDUM

SUBJECT:   Financial Analysis / General Synopsis
           Electronic File Name is NEICFA01.GEN

FROM:      Kimberly A.  Zanier CPA
           Senior Financial Analyst
           Information Services Section
           National Enforcement Investigations  Center

TO:        ORC Attorneys
           OECA Attorneys
           Enforcement Personnel  Involved in Litigation  Support
           Financial Analysts
                                               c

     The Information Services Section (ISS)  at the  National
Enforcement  Investigations Center (NEIC)  has been providing
training for financial analysts charged with the responsibility
of making  ability to pay determinations.   To assist with this
training the attached General Synopsis has been developed. The
attachment is intended to be used by financial analysts  who have
experience with the financial transactions being evaluated.

     We are  distributing this document to other enforcement
personnel  in an attempt to:

     1.    Provide insight into a complete ability- to-pay
           analysis.   The document outlines the various steps an
           analyst will generally go through  in performing such an
           analysis.   The reader must keep in mind that all steps
           will not necessarily be performed  for each  case.  For
           example,  if  the ABEL run indicates an 80% probability
           of payment,  there is no need to perform additional
           analysis.  Also there are instances  where,  after havir.s
           obtained the initial financial  documents, a
           determination can be easily made that the ability to
           pay adjustment factor should not be  made.   Those steps
           completed are determined on a case by case  basis.

     2     Provide the  reader with some understanding  as  to the
           potential  time factors involved in an analysis to
           facilitate .the planning process.

     3.    Assist the regions in gathering the  appropriate
           documentation for those situations where  an analyst
           will be needed.
                              A13

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     4.   Provide awareness to EPA personnel of the importance
          of, acting as a team, and continuing communication
          throughout the enforcement process.

     5.   Provide awareness of the value of bringing in an
          analyst early.

     6.   Inform personnel of the availability of sources of
          financial information (ISS) and assistance (CIs).

     The attached general synopsis is available in electronic .
form from the Information Services Section at NEIC.  Please
contact Char Ressequie at (303) 236-3636 ext. 546.

     If you have any suggestions,  comments, or questions with
respect to the attached document,  please contact Kimberly Zanier
at (303) 236-3636 ext. 555.
                                            t

Attachment

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                                 CONFIDENTIAL
               FINANCIAL ANALYSIS/GENERAL SYNOPSIS
           NATIONAL ENFORCEMENT INVESTIGATIONS CENTER


GENERAL COMMENTS

     This  worksheet  is  provided  as  a  guide and  reflects  oniv
general  documentation  to  be obtained  to  perform  a  financial
analysis.  It provides only limited insight  into potential issues.

     An important point to keep in mind,  while reviewing the below
information,  is the benefits associated with bringing an analyst in
early.

     Early involvement in  the case will  allow the analyst to:

    . •    Acquire historical  knowledge of the case

     •    Provide assistance  in on the spot  reviews or discussions

     •    Provide  assistance  in other  financial  areas  besides
          ability to  pay  -

     •    Provide enough  interjection to persuade the respondent
          that  raising the  ability  to  pay  issue  would not  be
          prudent

     •    The case will be handled in a more timely fashion because
          an ability to pay  case can take  anywhere  from  2  to  12
          months.    Waiting  to  start   this  process,  when  the
          liability issues are  resolved, will add  (potentially)
          another 2 to 12  months to the  case.

So, consult with any analyst  EARLY.

STEPS

I.   INITIAL DOCUMENTATION TO BE PROVIDED BY ATTORNEY

     A.   Request memo detailing the  following:

               Synopsis of the case  (complete history)
               Inspection  date
               Program  personnel  involved  - names  and  phone
               numbers
               Violation details
               Penalty amount
               Current status of case
               Description of business  activity,  type  of entity
                (individual or corporation)

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                ENFORCEMENT CONFIDENTIAL
          FINANCIAL ANALYSIS/GENERAL SYNOPSIS
       NATIONAL ENFORCEMENT. INVESTIGATIONS  CENTER

     •    Details of ability to pay
          What is Respondents position?  - Respondent needs to
          provide this  in writing,  not only their position
          but   also   all   documents   substantiating  their
          position
     • •   Description of  documents which  have been provided
          by Respondent and include copies
     •    Attorney's opinion  as to ability  to pay argument
          settlement
     •    Hearing potential

B.   Copies of  the  complaint,  answer,  rehearing exchanges,
     motions,  etc.

C.   Respondents written  position in  re:  Ability to Pay and
     copies of all supporting documentation received

D.   Provide ABEL results

     •    If 80%, attorney can rely on ABEL for negotiations.
          No  need to bring analyst  in except  for general
          advice.   If  settlement fails  then  discuss with
          analyst.  ABEL  is not to be used in  trial.

E.   Tax returns and financial statements (5 year) -copies only

F.   Form 8821 Tax Information Authorization  signed and dated
     by the respondent.   NOTE:  60-day expiration date.  Must
     have to the IRS within 60 days.

G.   Depreciation  schedule,  all  inclusive   since  date  of
     incorporation

H.   Affiliation schedule, detailing corporate affiliations

I.   D&Bs and other data  base searches

J.   Other considerations

     •    Has an asset search been run?
     •    Has an executive  search been  run?
     •    Have the SEC filings  been reviewed?
     •    Provide copies  of all above output.

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                                 CONFIDENTIAL
            immiv^T	ANALYSIS/GENERAL SYNOPSIS
            NATIONAL ENFORCEMENT .INVESTIGATIONS CENTER

IX.  WHEN TEE CASE  IS RECEIVED

     A.   Review package,  and pre-plan case.'

               Make sure you have only GOBIESI: originals are to be
               maintained by  attorney.

               Make sure  all  requested information   has  bee"
               received.

               Review  synopsis  of  case  to  get general idea o?
               status of  case.

          •    Read   through   complaint,   answer,    rehear ina
               exchanges,  etc.

     B.   Call  program personnel  involved  in the  case  to get
          general history and additional details as to what he/she
          knows about the entity, its officers, business  dealings,
          etc.

     C.   Discuss with attorney.

     D.   Begin set up of  case  file.

          •    Develop time line
          •    Organization chart
          •    Options available

     E.   Verify that all  the appropriate  (to date)  searches have
          been done.  IF NOT, ORDER THOSE NECESSARY.

     F.   Review the return to  determine other assets,  locations,
          officers, related entities,  legal  actions,  new loans.
          etc.,  for which additional  data base searches  should be
          conducted. These services can be obtained  through your
          regional  library  or  by   contacting  Irene  Erhart.
          Information Services, NEIC  (303) 236-3636,  ext. 558.

     G.   Review the ABEL output provided by the attorney.

     H    Consider  civil  investigator  (CD  involvement  in your
          region (primarily Superfund)  or Multi-Media  CI Support
          from NEIC. CIs  can  collect other financial information
          which may help validate  and/or supplement information
          provided  by  the  respondent  and other  sources.   Some
          services offered  by the NEIC  Civil Investigator program
          include:

-------
     L.

     M.

     N.


     0..

     P.

     Q.
           ENFORCEMENT CONFIDENTIAL
     FINANCIAL ANALYSIS/GENERAL SYNOPSIS
  NATIONAL ENFORCEMENT INVESTIGATIONS CENTER

     Asset information gathering
     Corporate affiliation and structure identification
     Witness location and interview services
     Other information gathering services
     For more information contact the Civil Investigator
     Branch Chief,  Jeff Lightner, at  NEIC  (303) 236-3636'
     ext. 504.   Telephonic  discussion of proposed case
     specifics   and   requirements  prior  to  official
     request is desirable
                      *
If necessary,  research counties which are not online, and
request assistance  from them.  Have them call the various
counties, etc.,  to request the needed information.   (This
is performed if return information and data base searches
already  conducted  indicate the  firm  cannot pay the
penalty.}

If any lawsuits  discovered,  review  synopsis  and possibly
order copies of complaint and decision.

Identify issues.  Research applicable  laws  (environmental
and tax,  etc.),  where necessary so  that  you will know
what elements need to be addressed in your write-up.

Review applicable penalty policies.

Develop organizational chart and time line.
                              i
Discuss  up-to-date  status  with  attorney.    Outline
alternatives,  etc.

Develop document request.

Develop initial interview questions.

Schedule initial interview through the  attorney.
III. CONDUCT TEE INITIAL INTERVIEW
IV.  REQUEST ADDITIONAL DOCUMENTS

     NOTE: EPA has the burden to prove the penalty is appropriate.
     "Ability TO Pay" is one element to be considered in evaluating
     the appropriateness of the  penalty.

     A.   Voluntary document request  submitted

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                                 CONFIDENTIAL
                FINANCIAL ANALYSIS /GENERAL SYNOPSIS
            NATIONAL ENFORCEMENT INVESTIGATIONS CENTER

     B.   Subpoenas -  Where statute provides authority

                May be  used in instances where they have provided
                information which superficially indicates inability
                to pay.                                          *

     C.   File_a motion requesting the court  to grant permission to
          acquire the information  needed [see 40 CFR 22.16 "and
          40 CFR  22.19(f)].  Other  discovery . .; will  be permitted
          only upon determination by the Presiding Officer:

          •     That  such   discovery  will  not  in   any  way
                unreasonably delay the proceeding

          •     That  the  information  to   be  obtained  is  not
                otherwise obtainable

          •     That such  information has   significant probative
                value

V.   WEEN ADDITIONAL INFORMATION IS RECEIVED

     A.   Review  the additional information and identify additional
          sources of funds.  Address issues  which were  identified
          in step II,  such as thinly capitalized,  additional debt
          capacity,  loans to shareholders = capital, liquid assets,
          unnecessary  assets,  unreported income,  etc.

     B.   Third party  contacts.   The attorney should  have already
          discussed this with the respondent when ability to pay
          was  initially raised.   Third  party  verification  is  a
          necessary step in a financial  analysis.

     C.   Go out'to the  field if necessary.

VT.  DISCUSS WITH ATTORNEY CONCLUSIONS AND COURSES OF ACTION
     TO DATE

VII. SCHEDULE  CONFERENCE CALL OR SETTLEMENT  MEETING

     A    Discuss  conclusion  with  respondent;   ask  additional
          questions to  further  support  our case and answer ar.y
          questions they may have.

     B    Depending on the course of the  case, this may be the time
          to identify to whom we may need  to issue  subpoenas i*
          conflicting  or missing information.

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                     ENFORCEMENT CONFIDENTIAL
               FINANCIAL ANALYSIS/GENERAL SYNOPSIS
            NATIONAL ENFORCEMENT INVESTIGATIONS CENTER

VIII.     ISSUE SUBPOENAS FOR ANY ADDITIONAL INFORMATION REQUIRED
          TO SUPPORT OUR CASE IN COURT

     A.   Make sure we have ALL the necessary evidence to support
          our case/rebut their position.

IX.  SETTLE THE CASE.

     OR

X.   GO TO COURT

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                 ENVIRONMENTAL PROTECTION AGENCY
              TON
              ™^^°SS?S? INVESTIGATIONS CENTER
              BUILDING 53, BOX 25227, DENVER FEDERAL CENTER
                        DENVER, COLORADO 80225

                                              DATE: August 2, 1995

MEMORANDUM


SUBJECT:  Financial  Analysis Memorandum 12
          Obtaining  Financial Documentation/Discovery Motion
          Electronic File  Name is  NEICFA02.DIS

FROM:     Kimberly A.  Zanier, CPA  X'-Stv*^
          Senior  Financial Analyst  U
          Information Services Section
          National Enforcement Investigations Center

TO:       ORC Attorneys
          OECA  Attorneys
          Enforcement Personnel Involved in Litigation Support
          Financial  Analysts


     Information  Services  Section  (ISS)  at  NEIC  has been
assisting in obtaining financial documentation,  with respect  to
ability to pay  determinations, from various Respondents using a
number of different  options.  These options have included 3008
and 104 (e) requests,  voluntary submissions, subpoenas, and
discovery motions.    Based on this experience, the attached
Complainants Motion  for Issuance of a Discovery  Order has been
developed to provide assistance with generating  these types of
requests .  This sample motion is a combination of a number of
motions and affidavits previously  filed.  ISS will be
continuously updating this document as  new  issues are identified
and raised in cases.
BACKGROUND

     There were  a  number of instances where it appeared the
Respondent and/or  the  Judge was unaware of what and why we were
asking for certain financial documents and, therefore,  we were
being denied access to them.  To overcome this,  we are  including
an attachment with our motions, which includes two explanatory
paragraphs for each document being requested.   One paragraph
explains what the  document is,  and one explains the relevance of
the document.  We  have had good results using  this format.
Hence, the attached accumulation of explanatory paragraphs
pertaining to all  documents pursued in this manner to date.

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 THE MOTION AND ATTACHMENT

      As  stated,  the attached Discovery Motion  provides  a
 description of the financial documentation  being  requested and
 explains the necessity  and relevance  of  the information being
 requested.   By providing this cumulative listing  of  financial
 documentation we are not recommending the acquisition of  all
 documents included in the attachment.  Which documents  to request
 are determined on a case-by-case basis.   There are some instances
 where copies of the Respondents tax returns may be sufficient to
 conclude that the ability to pay adjustment factor should not be
 applied.

 PROCESS

      The most effective process identified  to.date is to  first
 request  the following initial documents  voluntarily.

      1.    Details of the Respondents  position  in  writirig,  and any
           substantiating documentation Respondent would like to
           provide

      2.    Tax Returns and Financial Statements past  5 years (one
           year prior to inspection)

      3.    Depreciation  Schedule

      4.    Affiliations  Schedule

      5.    Signed Form 8821 Tax Information  Authorization.  NOTE:
           60-day expiration date;  must have to the IRS  within  60
           days

      6.    Initial Questionnaire  (depends on case, ISS  is
           currently working on this)

      We  have found the  Respondent  will usually provide  these
 initial  documents, although there  are exceptions. After  a review
 of the initial documentation is completed,  a subsequent document
 request  should be issued for additional  financial information
 needed to continue the  analysis.   At  this point it may become
 necessary to issue a subpoena or  file a  motion etc., to obtain
-the documentation, in which case  I hope  the attached Discovery
 Motion will be of use to you.  A  listing of documents included to
 date is  provided on the following  page.

      The described Motion and Attachment is available in
 electronic form from Information  Services Section at NEIC.
 Please contact Char Resseguie at  (303)  236-3636 ext. 546.

      If  you have any questions, comments, additions or
 suggestions please call me at  (303)  236-3636 ext. 555.

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LISTING OF DOCUMENTS INCLUDED IN DISCOVERY MOTION/ATTACHMENT
                       DATED JUNE 19, 1995
                        GENERAL DOCUMENTS
1.   Year-End Trial
2.   Chart Of
3 .    General
4 .    Tax Returns
5-    Financial
6.   Depreciation
                        SPECIFIC DOCUMENTS
1.   1099s. 1098s. and W-2s
          1099-Div.
          1099-B
          1099-S
          1099-MI5C.
          1098
2.   Lease Agreements
3.   Financial Institutions Identification and Disclosure
     Authorization fsee sample form attached ^
4 .   Assets - sold or transferred
5 .   Assets - bought
6.   Bank statements
7 .   Outstanding loans to
8.   Shareholder loans to
9.   Managements representation letter
10.  Other investments
11.  Liabilities
12.  Interest income
13.  Leases
fUnderlined Items represent

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
In the Matter of:        )
                         )    Docket No.
                         )
                         )    COMPLAINANT'S MOTION
                         )    FOR ISSUANCE OF A
                         )    DISCOVERY ORDER
Respondent .     )
     Pursuant  to Section 22.19(f)  of the  Consolidated Rules of
Practice Governing the Administrative Assessment of Civil Penalties
and the Revocation and Suspension of Permits (Consolidated Rules),
40  C.F.R.  §'22.19(f),  Complainant  United  States  Environmental
Protection  Agency,  Region 10  (EPA) moves for  the issuance of a
discovery  order  to  obtain  financial  information  to evaluate
Respondent's ability  to pay the  proposed  penalty.
                            BACKGROUND
     EPA issued a Complaint in this matter on May 28, 1993,  for the
assessment of a civil penalty  for nine reporting  violations under
Section 313 of the Emergency Planning  Community Right to Know Act
(EPCRA), 42 U.S.C. 11023.
     Consistent  with EPA's   Enforcement  Response  Policy,  the
Complaint proposes a  penalty  of  $150,800. . In its  Answer,
alleges inter alia that B(t)he proposed  penalty,  and any penalty.
would exceed        ' ability  to pay."  Paragraph 34.

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                             ARGUMENT
     Section  22,19(f)  of the  Consolidated Rules  establish the
procedures  for obtaining  discovery beyond  that  provided by the
prehearing  exchange.   Specifically,  Section  22.19  permits the
Presiding Officer to issue a discovery order if the Officer  finds
that  (1)  the discovery will not unreasonably  delay  proceedings,
(2) the  information  is  not otherwise  obtainable,  and  (3) the
information  has  significant probative  value.   EPA's  discovery
request meets  all three elements.
A.   The discovery  will not unreasonably delay the  proceedings.
     Currently the  parties  are scheduled  to begin the formal
hearing  on April             .   Provided Respondent  provides the
requested documents by  April        , EPA will have adequate time
to complete preparations  for the hearing.
B .   The   financial  information   requested   is   not   otherwise
     obtainable.
     The information requested below is not otherwise obtainable.
The  documents that are the  subject of this  request are in the
possession of  Respondent  (or its parent     . , which        has
                               »
asserted is the appropriate entity to evaluate to determine whether
Respondent  has  the ability to  pay),  financial  and  auditing
                                  f
companies, and the Internal Revenue Service. On March 7, 1995, EPA
requested         to provide the documents listed below and  other
documents .  While on March          ,  .        did provide many  of
the  documents EPA  requested,  it did  not produce the  documents

listed below.
                                                   Offlc« of Regional Cou«*«

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     C.   The information has significant probative  value.

     The  financial  documents will  permit  EPA  to  confirm  the

appropriateness of the penalty or adjust it if necessary.   While

the,  information  which  Respondent  has  provided  includes  some

evidence regarding the ability to pay issue,  it does not allow for

a complete assessment  of Respondent's financial position  and its

ability  to  pay the  penalty.   In most  instances,  the  requested

documents should  be easy to retrieve.   For  these reasons,  EPA

requests  production  of  the documents listed  below.   A  detailed

explanation supporting each of the requests  is attached hereto.

                    DOCUMENTS REOtJESTED

     EPA requests the following  financial documents:


PROVIDE A LISTING OF THE DOCUMENTS ONLY,  EXPLANATIONS INCLUDED IN
ATTACHMENT
                            CONCLUSION

     For the reasons discussed above, Complainant EPA respectfully

moves for the issuance of a discovery order.

     Dated this 	 day of March 1995.
                               Assistant Regional Counsel
                                                   Offle* of Regional Count*

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                           ATTACHMENT
                                                   *
                 EXPLANATION OF DOCUMENT REQUEST

     The following  is a description  of  the  financial  information
requested,  its necessity,  relevance,  and an  explanation as  to how

the information requested will be used in determining Respondent's
ability to .pay the  proposed  penalty.

                        GENERAL DOCUMENTS
      GENERAL  FINANCIAL RECORDS  - Please provide copies of the
following documents:

TAX RETURNS

1.     's tax return  for the  fiscal year ending June 30. 1994, or,
     if  this  return  has  not yet  been  filed,  a  copy  of the
     preliminary draft
(decided an explanation was unnecessary; however, in next, issuance
will provide)
FINANCIAL STATEMENTS

2.   	' s most current financial statements
     These are  centrally relevant documents  and will  provide the
most recent financial data available.   Both documents are essential
to  my general analysis.     The  documents  will  be  analyzed  to
determine  whether  there have been any  recent  changes  in      's
financial  status  which should be  incorporated into  my ability  to
pay analysis.

YEAR END TRIAL BALANCES

3.
                                   r* ^-—.•  — •••—•  • •-•• w TT-I-..I  i •    	—
                                  1994  (time period determined  on
     case-by-case basis)
     A year-end trial  balance is a  listing of all  the  accounts
maintained by a company for accounting purposes and the respective
year-end balances in each of the accounts identified.  A number of
these-accounts  may  be grouped together  prior to transferring the
total dollar amount balances  to  the tax return and  or financial
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statements. For example, a company may maintain numerous contract
labor  accounts,-  including  contractor  dollars paid  to  outside
entities, contractor dollars paid to     's  corporate officers  and
or  shareholders,  and year-end bonuses paid  to  corporate officers.
In  the tax  return,  however,  these four accounts may be combined,
totaled,  and  listed under  the single heading  "cost  of  labor"  and
included  in     's cost of  goods sold.  To analyze    's ability to
pay the proposed penalty, knowledge of the components which make up
each of the specific accounts listed on the tax return is necessary
so  that  the  relevant assets,  expenses,  and  liabilities may  be
evaluated to  determine the necessity and appropriateness of each.
The trial balance must be reviewed first to identify those accounts
which  are relevant  to    's ability to pay the proposed penalty.
     In addition to containing relevant substantive data, the trial
balance is  also a finding  aid thereby reducing the amount of time
spent  by  both the Respondent and EPA with respect to an ability to
pay analysis.
         's  year-end trial balances  have been requested  for  its
fiscal years  ending June  30, 1993 and June  30,  1994,  since these
are the most recent trial balances  and  will provide me with the
most recent account data available.

CHART  OF  ACCOUNTS

4.   	's chart of accounts for the fiscal years ending Jane 30,
     1993 and June  30.  1994
     A chart of  accounts is  a  listing,  by  account  number and
description,  of  each  account included  in  a  company's financial
•records.  Certain company-generated documents (including entries in
the general ledger, and sometimes  the trial balance) may identify
accounts  by  account  number only.   If  the account   description
associated with the account number is unknown,  a proper  analysis of
the accounts and substantiating documents cannot  be  performed,
since  the analyst .will be unable to  determine which accounts  are
relevant.  Thus,    's chart  of accounts will be used to facilitate
the financial analysis by making the process as quick and efficient
as  possible.

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GENERAL LEDGER

5a>  	'? general ledger  for th«» ^onth ending June  30.  i
5b-  	's  general  l^dg^r  for  -hhe  timp  neriod January  1   1004.
     through June 30. 1994                              y—^—Liai-

     The record used to record increases and decreases in  a single
asset, expense, liability, or equity amount is  called an  account.
All  these separate accounts  are  usually  kept in  a  loose-leaf
binder,  and the  entire group of  accounts is  called a  general
ledger.   The  general ledger documents requested will  provide the
transactional detail pertaining to  the specified time period.  For
example,  if  account #201  reflects loans made  by  the  company to
shareholders,  review of  the  general ledger account  1201 would
indicate  all  additional loans made to the shareholders,   and any
payments made by the shareholders with respect  to  the outstanding
loans.
     The general ledgers for the time periods identified represent
a  sample,  which will  be  used  in  conjunction with  the other
documentation requested to make  numerous  determinations including
the  necessity  of  specific   expenditures,  the  accuracy  of  the
accounts   being   analyzed,   and  the  validity  of   the   amounts
identified.

DEPRECIATION SCHEDULE

6.   Provide the  depreciation schedule for	.  Tnc. .  and the
     all  inclusive  since the  date of incorporation

     A  depreciation  schedule  is  a  detailed   schedule  of   a
corporation's assets which have a useful life of one year  or more.
It  provides a  description  of  each asset,  date  the asset was
purchased, cost of  the  asset, expected useful  life,  depreciation
expense currently taken, the accumulated depreciation to date,  book
value of the asset  and when and  if the asset was disposed of.  If
an asset  has  been sold or otherwise disposed of,  it  would still
appear on  the depreciation schedule as a previously  owned asset.
The  same  holds  true  if  an  asset  has  been  fully  depreciated
(expensed).
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The  depreciation  schedule  has relevance in  an  ability  to pay
analysis  for  a  number  of different  reasons.   The  depreciation
schedule:
      (a)  Will show if any assets have recently been purchased and
          the associated cost  of the asset.   If  the corporation
          paid cash for these  assets, the assets may  be used to
          secure a new loan.  The proceeds from the loan could be
          used to pay the penalty.
      	-*-iti«»s. Treasury Regulation 1.267.
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          a minimum represent a receivable to .the corporation.  The
          receivable would provide the corporation with additional
          funds to pay the penalty.  ,
     (d)   Will show the actual amount that the company paid for an
          asset.   This amount  generally does  not  represent the
          current  fair market value  of the  asset.   Fair market
          value  may  be substantially higher  than  the  asset's
          historical cost to the corporation.  If that is the case,
          such assets  listed^ on the depreciation schedule may be
          used to obtain a new loan, the proceeds of which may be
          used  to  pay  the  penalty.    Or,  the assets  may  be
          liquidated, in which case there would be additional funds
          for payment of a penalty.

SPECIFIC DOCUMENTS
1099s, 1098s, and W-2s
7.   Provide  copies of all  completed 1099.  1098.  and  W-2 forms
     issued to all  officers  and  shareholders  of	Inc. , and
     the	Corporate Group  for the years  1991,  1992.  and 1993

     Each of the forms identified above is required  to be  filed by
      ,  Inc. and/or the Corporate  Group with  the  Internal Revenue
Service and the recipient of the reported income (in this  case the
officers  and shareholders).   The  amount reported  on  each form
represents  the  total amount paid  by the  corporation  to  each
shareholder/officer for each of the  income  categories described
below.
     (a)   Form 1099-INT will show  how much  interest a shareholder
          has received from the corporation.  A determination must
          be made  as to the  validity of  the underlying loan and
          whether the  interest  rate is competitive with rates of
          outside lending  institutions.   If  the interest paid to
          the shareholder/officer  is  excessive in relationship to
          interest paid to nonrelated parties, the excess  interest
          should be allocated back to the corporation providing
          additional income  to be  used to  pay the penalty.
     (b)   Form  1099-DIV  will  show  how  much  each shareholder
          received  in  dividends  for  the  year.    Corporations
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     generally issue  dividends:   (1)  in  times of  strong
     financial health because the income is- not needed to meet
     financial obligations, or  (2) when corporate assets have
     been liquidated  and the  proceeds  received from  such
     liquidation  are being distributed  to the shareholders.
     The issuance of dividends  is,  thus, a strong indication
     that  the  firm  will  be   able   to  meet  its  penalty
     obligations. Also, dividends can be held back from being
     distributed  and used to pay a penalty.
(c)   Form  1099-B identifies   the  value  of  any  bartering
     exchanges which  have  taken  place.    With regard  to
     bartering transactions which have taken place between the
     corporation  and the shareholder/officers (where goods or
     services are exchanged for goods or services), the fair
     value of these exchanges  must  be  determined.   If the
     corporation  has received less than  fair market value for
     what  it  exchanged,  a   receivable  representing  the
     difference between the value received and the fair market
     value of what it gave up would result.  This receivable
     would provide  additional  income  to meet  the  penalty
     obligation.
(d)   Form 1099-S  identifies the dollar amount a shareholder or
     officer received from the  corporation as a  result of the
     sale of  real  estate to  the corporation.   Sales and
     exchanges between the corporation  and related parties
     must be reported as  an arm's-length transaction.  If the
     reported sale  price  is  above .fair market value, the
     difference   between  the sale  price  and the fair  value
     would be reclassified to the corporation as income.  This
     additional income would be available  to pay the penalty.
(e)   Form 1099-MISC shows how  much a shareholder or officer
     received for rent and/or  other miscellaneous payments.
     Here again,  the fair value  of these payments must be
     determined.    If the  payment made  to  the  shareholder/
     officer is  for  property rental and the cash payments  are
     substantially higher in relationship to other rental fees
     charged for similar  type  property,  then the  difference

                             23 -^              Office of Regional Count*

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          between the actual payments and the fair rental value of
          the payments represents a receivable to the corporation.
          This  receivable  would  provide  the  corporation  with
          additional income to pay  its penalty.
     (f)  Form 1098 will  show if there is a mortgage between the
          corporation and one of the officers  or shareholders.
          A determination would have to be made  as to whether the
          underlying  loan  is a  valid  loan with  a  competitive
          interest rate/ and whether the  asset was transferred at
          fair market value.  If it  is determined that the interest
          rate is below the market rate or the asset changed hands
          at less than fair market value,  then a receivable  for the
          additional  interest  or  sales  proceeds  due would  be
          established.     This  receivable   would  provide  the
          corporation with  additional  income to  pay the penalty.
     (g)  Form W-2 will show the amount of wages received by the
          shareholders and officers as well as any fringe benefits
          they  have  received.    These   forms  are necessary  to
          determine if the officers  and shareholders are being paid
          reasonable salaries in light of the  amount of time they
          devote  to  the business.  If it is determined that the
          salary  of an  officer or shareholder  is  excessive or
          unreasonable,  that portion  which is  determined to be
          excessive  should be allocated back  to the corporation.
          This  reallocation  would  provide  the  corporation with
          additional income to pay  the penalty amount.

     The 3 years  of documentation requested for  each of the above
categories is necessary to  determine any significant increases or
decreases in reportable amounts.  A  3-year comparison will allow us
to determine if the corporation has authorized any such  increases.
Salary increases, additional fringe benefits and dividend payments
are all indications of  a financially secure corporation and  provide
evidence that the corporation has the  ability to meet its  penalty
obligations.  If  the corporation is able to steadily increase an
officer's salary,  provide for additional fringe benefits,  and/or
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declare dividends, it is a clear indication that the corporation is
experiencing growth and is in. a strong financial position.
     Please note,  if the  above scenarios  do  not pertain to this
corporation then the documents outlined above will  not exist and,
therefore, understandably will not be provided.
                                                        V,

LEASE AGREEMENTS
8 .   Provide copies of lease agreements fox all  property  rented fe
           , Inc. since 1991.   Include an   amendments to such
     agreements

     Lease  agreements  will   show  the  parties  to  the  lease
arrangement and  identify  related party  transactions.   The lease
agreements  which  involve  related  parties must be  reviewed to
determine if they  are  consistent with fair rental value.  If the
company's lease  payments are  in excess of fair  rental value, the
difference between the  payments and the fair rental value can be
allocated back  to  the corporation  and made  available to pay the
penalty.

     The  leases  may  also  show  that the  corporation is leasing
luxury automobiles or nonessential assets.  In such circumstances,
the leases  could be cancelled,  freeing up additional cash which
could be used to pay the penalty.

DISCLOSURE AUTHORIZATION FORMS
9 .    Please identify all financial  institutions  which _ .  Inc.^
     and the _ Corporate Group have done business with over the
     past 5 years,  and  sign the attached disclosure authorization
     form for each institution

    . The  disclosure  authorization  form allows  the  financial
institutions to release information  concerning liabilities, credit,
and additional loans.   The authorization  form will allow EPA to:
     (a)  Verify  the  accuracy  of  liabilities   to  financial
          institutions  included on  the tax return.  The tax return
          may reflect greater  liabilities  than actually exist.  If
          the actual liabilities are  less  than the amount reported
          on the tax return, it would indicate that the corporation

                                234
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          is in  a better  financial position to  pay the penalty
          amount.
     (b)  Verify the amount of loans outstanding against corporate
          assets  and  determine  if  additional  funds  could  be
          borrowed against these assets.
     (c)  Review  financial  statements provided to the bank which
          may  disclose  additional  assets   not   listed  on  the
          depreciation  schedule.    These assets  may be  sold  or
          leveraged to pay the penalty.
       *                          '
ASSETS SOLD OR TRANSFERRED
10.   If any  assets have been  sold by	;	, Inc. or the	
     Corporate Group within the past 5 years. provide copies of the
     sales  agreement, bill  of sale,  deeds  transferred  and any
     information  pertaining  to  such sale

     The  documents requested  in  paragraph 6  will  describe the
assets  sold,  the date the asset was  sold,  the sales price, the
parties to the transaction, the date of transfer,  and the terms of
the sale.

     This information, in  conjunction with  the 1099-Ss  issued and
the  loan  information requested  is  necessary to analyze  asset
transfers which  have taken place.   In  addition,  this information
will provide the  following information:
     (a)  If an asset was transferred to a related party at a sale
          price  which was below  fair market value,  a  receivable
          would   be  due to the  corporation  for the  difference
          between the sale price  and  fair  market  value.   This
          receivable  would provide the  corporation with additional
          income  to pay  its penalty obligation.
     (b)  If the  corporation financed the sale of  one of its assets
          and  is  holding the note  on the asset,  the payments  the
          corporation is receiving  pertaining to this note would be
          a  source of cash available for payment of penalties.
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ASSETS BOUGHT
11.  If anv assets  have  been bought by       .  Inc.  or the
     Corporate Group within the past 5 years. provide copies of
     sales  agreement,  bill  of sale,  deeds  transferred,  anc^
     other information pertaining to such purchase

     The  analysis of  these documents  in conjunction with  loan
information requested will provide:
     (a)  Verification  of  the accuracy  of  the cost of  assets
          reported on the balance sheet and depreciation schedule.
          If an asset's  purchase price is ""higher than the  amount
          reported on the balance sheet and depreciation schedule,
          it is an  indication  that the corporation is in  better
          financial condition than appears because the  value of the
          corporation's  assets would be higher  than  reported.
     (b)  Information as to whether the assets were purchased with
          cash, in which case the corporation may be able to obtain
          a new loan against the asset.  The proceeds from this new
          loan could be  used  to meet  the  corporation's  penalty
          obligation.
     (c)  Information  as  to  whether   the  assets  purchased  are
          essential  to  the business.    If  the assets  are  not
                       »
          essential  to the business,  they can be sold.   The cash
          generated  from the sale could be used pay the penalty.

BANK STATEMENTS
12.  Provide copies of all bank statements for the past 3 years for
     all bank  accounts of	,  Inc.  and  the	Corporate
     Group

     Bank  statements  detail   all  banking  activity  during  a
particular month  for each of  the  different types of  accounts an
entity  maintains   including,• but  not  limited   to,  deposits,
withdrawals, checks written, and balances.  An analysis of the bank
records may:
     (a)  Uncover   unreported   income.    Unreported  income  is
          additional income available to the corporation to pay the
          penalty.
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     (b)  Disclose  an installment  sale which was  reported in a
          previous  year for  which  payments are  being received
          currently.  These payments provide an  influx  of cash to
          the  corporation  which  would be  available to  pay the
          penalty.
     (c)  Disclose  large  or unusual withdrawals or checks which
          would indicate further analysis  is  needed.  This analysis
          may  lead  to  the  discovery  of luxury  or unnecessary
          purchases.  Such purchases could be sold  or withdrawals
          reclassified, making  additional funds available to the
          corporation.

     The provision  of documentation on all  bank accounts allows
review of any money market accounts, certificates of deposits, or
other investment accounts which       may possess.   These types of
accounts are liquid and represent a source  of available funds to
pay a penalty.

OUTSTANDING LOANS TO
13.  For all outstanding loans to	, Inc. or the	Corporate
     Group, provide copies  of loan applications, loan  documents,
     notes, etc.

     This information:
     (a)  May  disclose  unrecorded assets.   Such assets could be
          used to  secure new loans  or could be sold to generate
          additional income.
     (b)  May identify a loan to        from a related party which
          is not an arm's-length transaction. If the interest rate
          on the loan  is  excessive,  the difference between the
          stated interest rate  and  the current market rate  can be
          reclassified  to  the  corporation  as  income,  thereby
          providing additional  income  to  pay the penalty.
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SHAREHOLDER LOANS TO
14.  For any loans from a shareholder of	. Inc. or the
       Corporate  Group,  provide  copies  of  the  cancelled
     written to the corporation and loan  documents

     This information:
     (a)  Will allow, verification that a reported loan was actually
          made.   If  the payment  to          was  not  made,  the
          corporation  would  not  owe  the  amount  of  the loan.
          Therefore,  the corporate  liabilities would be reduced,
          allowing  for  additional  funds  to  meet  the  .penalty
          obligation.
     (b)  May show that the money  infused into the  corporation was
          not a loan  but rather a contribution of capital.  This
          situation would reduce the liabilities of the corporation
          and provide the  corporation with additional  capital to
          pay the penalty.

MANAGEMENT REPRESENTATION LETTER
15.  Copies  of  documents  and  documentation  of  communication
     addressing any information provided  by	or	to the
     Independent Auditor with regard to  the 1995  and 1994 Audits
     regarding:   fal  any litigation  involving the  company which
     could  have  a  material  impact  on   the  company's  financial
     statements, and  (b) the  going concern oi;	and	_,.
     Professional auditing standards recommend that the Independent
Auditor  request of  a  company's  management   its  representations
regarding many issues, including:   loss contingencies; litigation,
claims, and assessments; violations or possible violations of laws
or regulations; and  any other such matter that the Auditor deems
appropriate—all  of  which would  then be addressed  in  the Audit
Report by accrual or  disclosure.  With respect to the litigation,
claims and assessments, the Auditor is advised to direct inquiries
to the corporation's  legal counsel -

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                              assert  in  the Affidavit  that both
companies may have difficulty continuing  as going concerns and that

       is in litigation with the IRS and  may have to make a payment

of more than $700,000.  While the  "going concern"  issue was noted

in the 1990,  1991,  and 1992 Audit Reports, no such  statement was

made in the 1993 Audit Report.  The responses to this request will

indicate whether and how the companies presented their concerns in
these regards to the Auditor.


OTHER INVESTMENTS

16.  OTHER INVESTMENTS

     a.   With reference to the "Other investments"  in  the amount
          of $103,259,  listed in column  D of  the Balance Sheet at
          Page 4  of - 's  tax  return  for the fiscal year ending
          June 30 ,  1993 > please list  and identify each  investment
          separately.   Including  a   description  of  the asset/
          investment, the estimated fair  market value of the asset/
          investment,  the  purchase price, the purchase date, and
          the  name and address of the  broker  who  initiated the
          purchase.

     b.   With reference to the other investments referred to in
          paragraph 2. a.  above,  please  provide copies of  the
          following documents:

          (1)  All  brokerage statements  from  June 1. 1992 through
               the  present

          ( 2 )  All  IRS  Forms   1099  reflecting  dividend  income
               received b       since  Januar  1.  1993
     c.   If there are any brokerage firms and/or j^v^nala whom
              has  dealt with  since June 1.  1992 whl^n have not
          provided  statements,  please  identify all _ such firms
          and/or individuals by name and address.

     Other  investments  generally  represent  assets  owned by an
entity such as  stocks,  bonds,  and  certificates  of  deposit, which
may be sold, or utilized as collateral to obtain a  loan or loans.
     The IRS Forms 1099  requested will provide current details with

regard to the rate of return (dividends)  being generated by some of

the investments  identified.  The estimate of fair market value is

necessary since  the  historical cost basis  (purchase  price) of an
asset does not necessarily reflect its current fair market value.

The value of  the asset may  have- appreciated, depreciated,  or

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remained the same.  In any event, it is necessary to  estimate  the
fair market value of   's assets because the value of  these assets
represents a source from which     would have the ability to  pay
the proposed penalty.
     The brokerage statements and broker identification information
requested will be used to verify if      has provided  a  complete
list of its other  investments  and to verify that assets owned  by
   have remained  in the  corporation and have not been distributed
to shareholders or other related individuals.
     In general,  the requested information will provide details as
to       's other investments,  including  what investments
currently has (and therefore can be sold to pay the penalty), which
have  been  sold   recently  (thereby  already  having generated
additional cash flow), and what type of return     is  getting with
regard to these  investments on a continuing basis  (available  for
payment of the penalty).

LIABILITIES
17.  LIABILITIES  -      s  tax  return  for the fiscal  year ending
     June 30.  1993,   indicates outstanding   loans   as  follows:
     Mortgages, notes, bonds payable in less than 1 year - 54,324:
     and  Mortgages,  notes,  bonds payable in  1  year  or  more  -
     $1.260.  If   any  new  loans have  been initiated  or  are  now
     outstanding  which are  not reflected  in  the balance sheet  of
      's  tax  return  for the  fiscal  year ending  June 30.  1993^
     please provide copies  of the following  documents,   and  the
     following information
     a.   All   loan   documents.   settlement   sheets,   closing
          statements,  and  other documents pertaining  to each loan
     b.   An explanation as to why the loan was necessary  and what
          the proceeds were  used  for
.                                                               i
     These documents and information will  evidence and describe any
new loans initiated by      after June 30, 1993.   This data will
provide  updated   information   with   respect  to         's  total
liabilities, which must  be taken  into account in evaluating    's
ability to pay the proposed penalty.
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INTEREST INCOME
18..  INTEREST INCOME - Please provide coping of all IRS Forme inoo
     reflecting anv interest income Darned by    in 1993 and 1004
     The Form 1099-INTs  received by        will  show  reportable
interest received by     during each year from a specific  company
or individual.  A determination must be made as to  the validity of
the underlying loan  and whether the interest  rate  is  competitive
with  outside  lending  institutions.   If  the  interest  is being
received from a related party, and  is  substantially less then the
market rate, the additional interest due would be a receivable from
the  related  party.  Payment  of  the  receivable  would  provide
additional cash flow to be used to  pay a  penalty.   The Form 1099-
INTs  will  also  provide  information  as  to whether       holds
substantial  funds  in  a  financial  institution,  which would be
available for payment of a penalty.

LEASES

19.  LEASES - Please provide a copy  of any lease agreement pursuant
     to  which	rents  property from the  officers  of	u
     including the original lease and  any amendments thereto.
     Lease  agreements   will  show  the  parties   to   the lease
arrangement and  identify  related party transactions..   The lease
agreements  which, involve  related  parties  must be reviewed to
determine if they are consistent  with fair rental value.  If     's
lease payments  to related parties  are in  excess  of  fair rental
value,  the  difference between the payments and the  fair rental
value can be  allocated  back to     and made available to  pay the
penalty.   The leases may also show that      is  leasing luxury
automobiles or other nonessential assets.  In these circumstances,
the leases  could be cancelled,  freeing up  additional  cash which
could be used to pay a penalty.
                                                   owe* of Regional Couiw*
                                18

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                                                  ^

           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                         WASHINGTON, D.C 20460

                              JAN  2 4 1990

 MEMORANDUM

 SUBJECT:   Use of Stipulated Penalties  in  EPA Settlement
           Agreements
 FROM:     James M.  Strocl     _
  ,        Assistant Administrator

 TO.:       Addressees


     This memorandum provides guidance on the use of"
 stipulated penalties in settlement of enforcement actions.
 For each issue  discussed,  a  preferred approach is stated
 along with its  rationale.  These preferred  approaches should
 be followed^absent  unusual circumstances dictating an alter-
 native approach.  The guidance applies to judicial settle-
 ments except that it does  not supersede the September 21,
 1987 Guidance on the Use of  Stipulated Penalties in Hazardous
 Waste Consent Decrees.  It also applies to  administrative
 cases where EPA has legal  authority to assess stipulated
 penalties.

    . Stipulated penalties  are penalties agreed to by the
 parties to a settlement agreement for violation of the agree-
ment's provisions.  " These, penalties are then made a part of
the agreement,  and  are enforceable if it is violated.  In EPA
settlement agreements, the primary goal of  a stipulated
penalty is to act as an effective deterrent to violating the
settlement agreement.      .                  .
                                              ^

     I.   Types of  Requirements to Which stipulate t>*>nf7*igs
          Should Apply

     Any clearly definable event in a settlement agreement
may be appropriate  for stipulated penalties in a given case.
Such events include testing  and reporting requirements,
interim and final milestones in compliance  schedules, and
final demonstration of compliance.  The government litigation
team assigned to a  case should carefully consider which

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                                -2-


 consent agreement provisions are' appropriate for stimila^ed
 penalties and be prepared to vigorously enforce then*   st-ou-
 lated penalties can even be attached to consent ayeesen4-
.provisions requiring payment of up-front penalties so  long as
 the stipulated .penalties are higher than the interest,    .
 computed at the statutory interest rate, on"the underlying
 amount.  Every consent agreement requirenent to which  stipu-
 lated penalties are attached should be drafted to ensure tha+-
 the standards for. determining compliance are clear and objec-
 tive, and that any information required to be submitted to
 EPA is clear and unequivocal.

 '     In general, stipulated penalties are narticularly impor-
 tant for requirements of- the consent agreement which do not"
 represent-regulatory or statutory violations for which the
 agency could potentially get statutory maximum penalties.
"Such provisions may include a requirement to install specific
 control equipment where the regulations and statute" involved
 require only compliance with a discharge or emissions  stan-
 dard, or environmental auditing or management requirements
 designed to ensure future compliance.  Without stipulated
 penalty provisions, penalties for violation of such provi- -
 sions in judicial cases are only available at the judge's
 discretion in a contempt action under the court's inherent
 authority to enforce its own order.
       :taching.stipulated penalties to violations of  consent
agreement provisions which are  also violations of a statute
or regulation with, a specified  statutory maximum penalty has
advantages and disadvantages  which Agency attorneys should
consider carefully in the context of a particular case.  The
advantage, is ease of enforcement.  . The Agency can pursue
violations without .having to  faring a new enforcement  action
or, In the judicial context,  a  contempt action.   The  disad-
vantage  is where stipulated penalties for such violations are
set at less than the statutory  maximum, parties may"argue
that the government has  bargained away some of its'
enforcement discretion.      •                         »

     If  a particularly egregious  statutory or regulatory  •
violation occurs for which the  government feels'the applic-
able stimulated  penalties are not adequate, sources may claim
the government is equitably estopped from pursuing other  ^
enforcement responses.   Sources may argue in the context, o. a
contempt action  or new enforcement action that, the govern-
ment has already conceded in  the  consent agreement that a
fair penalty for this type of violation is the stipulated
penalty,  and therefore,  the court should not require  any

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                     »
                                                            •
 additional penalty.  'Sources nay make this argument even if
 the government has reserved all rights to pursue various
 enforcement responses for consent agreement violations.1
                                                            •
                               +     - • • .x
      II- Level of Stipulated Penalties

      Because the statutes EPA is charged with enforcing vary
 so widely, penalty schedules for all media or types of- viola-
 tions are not practical.  There are,  however, several impor-
 tant criteria which should always be considered in setting
 stipulated penalty amounts.  Each program office., in concert
 with the appropriate OECM Associate Enforcement Counsel,  may
 vant to consider providing further, more specific guidance on
 appropriate levels or ranges for stipulated penalties based
 on the criteria below.

      One key element which applies to setting .the levels of
 all stipulated penalties for violation of a consent agreement
 provision is that the defendant is by definition a-repeat '
 offender when the provision is violated.  For this reason,
 such stipulated penalties should be higher on a per day basis
 than the initial civil penalties imposed.  See Guidelines for
 Enforcing Federal District Court Orders in Environmental
 Cases (GM-27).

      The economic benefit accruing to a source due to a
 violation should be recovered in order for the stipulated
 penalty to be an effective- deterrent.   For some types of
 violations, such as notice provisions, the economic benefit
 of ncncompliance may be minimal, though significant stipu-
 lated penalties may be appropriate based on other criteria as
 discussed below..  For these types of violations, no formal_
 BEN analysis is necessary.  For violation of provisions which
.involve quantifiable delayed or avoided costs, such as
 installation of control eguipmen£ as part of a compliance
 schedule, the minimum stipulated penalty should be ^JTe  .
 economic benefit of noncompliance.  However, the recidivism
 factor will nearly always justify a"penalty well above this
 minimum, which often serves as the point of departure for a
 minimum initial penalty.

      The source's ability to pay can be another important
 criterion to consider.  How much of a deterrent a stipulated
 penalty is will depend on how financially significant it is
 to the source. , The same stipulated penalty may be
      1 In considering whether to attach penalties to violations
uncovered by an environmental audit, the November 14, 19S6 Fjn*
.EPA  Policy on the Inclusion of Environmental Auditing Provision
in Enforcement Settlements (GM-52) should be consulted.

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                                 -4-


 financially crippling to-one source,  while merely a routine
 business  expense for another.  However,  the'burden is always
 on  the  defendant to raise  such issues during negotiations and
. to  Dustify lower stipulated penalties than the government h=s
 proposed.   Financial ability to pay a-penalty can be     -
 determined using the ABEL  computer program for corporate
 violators  and the MABEL computer program- for municipal
 .violators.                '

      _It should be emphasized that this factor should not be
 considered a reason for lowering the  level of stioulated
 penalties  below the level  equal to the' economic benefit,  it
 would mainly affect the degree to which  this base minimum
 amount  is  increased to account .for the recidivist nature of
 the violation.   The key concern is that  stipulated penalties
 should  be  set at levels which are significant enough to deter
 violations  rather'than resulting in a "pay-to-poliute"
 scheme.-             .

      Another criterion which should be considered in setting
 stipulated  penalty amounts  is the gravity of the violation,
 i.e.. how critical is  the requirement to the overall
 regulatory  scheme and  how environmentally significant is the
 violation.   The  environmental significance factor should
 include consideration  of potential • and actual harm to human
 health and  the environment.   In general, consent'agreement
 provisions  which are central  to a particular regulatory
 scheme should have higher stipulated  penalties than
 provisions  that  are considered less significant.  It is up to
 each enforcement program to make judgments about the relative
 importance  of respective requirements.  As-previously noted,
 some consent agreement requirements such as notice provisions
 may have little  or no  associated economic benefit, but nay
 nevertheless be  critical to the regulatory program in
 question and would warrant higir* stipulated penalties.

      Another consideration related to the•gravity component
 is the source's history of compliance.  If the source has a
 record of previous  violations,  a higher stipulated penalty
 may be necessary because earlier enforcement responses were
 ineffective in deterring subsequent violations.

      Another option to  consider whenever setting stipulated
 penalty levels is  an escalating schedule-, in which the
.stipulated penalty  increases with the length of the       ^
 violation.  For example, violations of up to two weeks mig-.t
 have stipulated -penalties of  $1000 per day while violations
 of two to four weeks might have stipulated penalties o. 5-wJ
 per day, and so on.

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                                -5-
      III.  Method of Collection

      Settlement agreements should state the method by which
 stipulated penalties will be collected. -Two  options are  for
 the settlement agreement to provide that the  penalty is -
 automatically due upon the .occurrence or no'h-occurrence of a
 specified  event, or it may make the penalty, payable only_on
 demand by  the government.

      Automatic payment is the preferred approach.   It saves
 resources  which would otherwise be devoted to making demands
 for payment and may put the government in a more advantageous
 position should the source declare bankruptcy.  If payment is
 made on demand, the consent agreement should  make  it clear
 that the legal liability, of the source for the  stipulated
 penalty attaches immediately upon violation,  and i± is only
 payment of the penalty to the Agency which is not  due until
 demand is  made.

      Settlement agreements should always state  where and  how
 the penalty should be paid and how the check  should be draft-
 ed,  'gee SPA Manual on Monitoring and Enforcing Administra-
 tive and Judicial Orders for additional guidance.   In
 addition,  settlement agreements should not agree to pre-
 enforcement review of accrued stipulated penalties.

      IV.   Timing of Enforcement Responses

      Prompt action to collect stipulated penalties due under
 any .consent agreement is crucial.  If stipulated penalties
 are due on demand,  it is very important such  demands be
 timely.  The government encounters significant .difficulty
 collecting stipulated penalties if it sits on its  rights.
 Delay allows penalties to increase to levels  parties may
 argue are  inequitable.  Sources* may also raise  equitable
 defenses such as laches" or estoppel, arguing  that  the govern-
 ment cannot fail to exercise its rights for extended periods
 of  time allowing stipulated penalties to continue  to accrue
 and then move to collect unreasonably high penalties.' The
 government,  of course, can and should always  rebut such
 claims  by  arguing it is simply enforcing the  decree or agree-
 ment as agreed to by defendant, and is not subject to such
-equitable  defenses.   However, this unnecessary  complication
 should  be  avoided.

      A  cap on the amount of stipulated penalties which can
 accrue  is  generally not a preferred solution  to this prcblen.
 The  stipulated penalty would lose its deterrent value once^
 the  cap is reached.   Also, the main goal of  any enforcement
 action  must be compliance with the law so that  public hea-*S
 and  welfare is protected.  If consent agreement provisions

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       -                         -6-


 are allowed to be violated long enough for a cap to 'be reach-
 ed, serious environmental • consequences may .have occurred.

 . ,.   Providing that stipulated .penalties only apply for a  •
 specific, reasonably ..short period-of tine in conjunction with
 reserving to the government all available enforcement r»s3on-
 ses for violation of. the consent agreement, however, solves
 nary of the problems mentioned above.  By. its own terms,
 stipulated penalties will not accrue to levels defendants  can
 argue^are inequitable.  The government will be in a-strong
 position when it pursues other enforcement options, such as
 contempt actions or a new enforcement action-to get
 additional penalties, because it can argue that the penalties
 in  the original consent agreement were not enough to deter
 the defendant from further violations and the possibility  of
 additional penalties was clearly contemplated.

      V.   Reservation of Rights
             •                             <      *
      All consent agreements must' contain a provision which
 reserves to the government the right to pursue any legally
 available enforcement response for violation, of any consent-
 agreement provision.  These enforcement responses would
 include  civil contempt proceedings and injunctive relief,  and
 criminal contempt proceedings for particularly egregious •
 violations.   However,  for provisions mandated by statute cr
 regulation and which have stipulated penalties attached, a
 reservation to pursue statutory penalties is suggested but
 not required.   For model language, see the October 19,  1933
 Guidance for Drafting Judicial Consent Decrees (GM-17).

      VI.   Collection of Stipulated Penalties

    -The government should be prepared to collect the full
 amount of stipulated penaltiea.^ue under a consent, agreement.
 No  agreement should ever anticipate  compromise by specifying
 instances where it will be allowed,  aside from a standard
 force najeure clause.   In rare," unforeseeable circumstances,
 however,  the equities  of a case may  indicate that the govern-
 ment may compromise the amount it agrees to collect.   For
 penalties payable on demand,  the government may also exercis*
 prosecutorial  discretion by declining to proffer a demand  for
 stipulated penalties for minor .violations of a consent agree-
 ment.
     It. may  also be appropriate to provide that stipulated
penalties for violation of interim milestones in a compliar.c*
schedule will be forgiven if  the final deadline for achieving
compliance is met.   This is clearly inappropriate where  ...ere
is significant environmental  liana caused  by the defendant
missing the  interim deadlines.  If such a provision is used.

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                                -7-
 the defendant  should generally be required to  place  accrued
 penalties in an escrow account until' compliance  by the final
 deadline is achieved.   -                  -
                                . ...   .      • •    •
      In judicial- cases, the Attorney General, and his
 delegatees in  the Department of Justice (DOJ)  have plenary
 prosecutorial  discretion to compromise stipulated penalties.
 This authority stems from 25 U.S.C. § 516, 'which reserves to
 DOJ authority  to conduct the litigation of the United States,
 including cases in which an agency of the United states is a
 party, and the cases and regulations broadly interpreting'
 this authority.
  >
      In administrative cases handled solely by EPA,
 stipulated penalties should be collected pursuant to the  •
 enforcement authority granted to EPA under the statute gover-
 ning the case.  This -authority to collect and  compromise
 stipulated penalties varies from statute to statute.

      Separate  from the process for collecting  stipulated
 penalties, EPA must keep track of money owed the federal
 government "(accounts receivable) resulting out of the acti-"
 vities of the Agency, including administrative penalty
 assessments.  A stipulated penalty becomes an  account receiv-
 able when the appropriate Agency official determines that a
 violation of a consent agreement provision with  an attached
 penalty has occurred.  Under Agency financial  regulations and
 policies for monitoring accounts receivable, stipulated
 penalties due and owing must be reported within  three days to
 the Regional Financial Management Office (FMO).  The FKO is
 responsible for entering the stipulated- penalty  as an
 accounts receivable into the Agency's Integrated Financial
 Management System (IFMS).   The "appropriate agency .of ficial"
 who determines the existence of a stipulated penalty account
 receivable is responsible for'-keeping the FMO  updated on the
 status of enforcement penalty collection afforts.  A nore
 detailed account of these procedures is included in the
 Manual on Monitoring and Enforcing Administrative and Judi-
 cial Orders. •
 Addressees:

      Regional Administrators
      Regions I-X
i

      Deputy Regional Administrators
      Regions I-X

      Regional Counsels
      Regions I-X

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                            -8-
,  E. Donald Elliott
  General Counsel  •  ,               .

 . Headquarters Compliance Program--Divisions Directors

  Mary T. Smith, Acting Director
  Field Operations and Support.Division
  Office of Mobile Sources

  David Buente, Chief
  Environmental Enforcement Section
  U.S. Department of Justice

  Associate Enforcement Counsels

  Workgroup Members

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      01/11/-1900 14:37  FROM                    TQ
          i NIr>u M \n> ENVIRONMENTAL PROTECTION AGENCY
                                ».o.c.»-          £TC-&-/99^o
          Guidance on Cercification of Compliance
          Enforcement fccceeaents
                                                     \
          Thomas L. Adams, Jr.
          Assistant Administrator for Enforcement
            and Compliance Monitoring

TO:     '  Assistant Administrators
          Regional Administrators
          Regional Counsels


I.  ' SACKGPOOKO

     Over the past several years, E?A has  initiated record
numbers of civil Judicial and administrative  enforcement actions.
The vast majority of such actions have been resolved by judicial
consent decree or administrative consent order.

     The terms of many of these settlements require the violator
to oerform specific casks necessary to return to or demonstrate
compliance, to accomplish specific environmental cleanup or ether
remedial steps, and to take prescribed environmentally beneficul
action.

     Settlement agreements typically specify that  the violator
perform certain recuired activities and tneceafter report tfteir
accomplishment to EPA*  Verification that  the required .activities
have actually been accomplished is an essential element" in. the
overall success of the Agency's enforcement program.

II.
     The focus p* this advisory Guidance is on verification of
compliance with settlement agreements vnicn require specific
performance to achieve or maintain compliance with a  regulatory
standard.  EPA has oncoinc responsibility'-'-for ensuring tnat
settling parties are in compliance with the terms of  their
negotiated agreements.  To tnts end, the Agency may require
that a responsible official Us that tern is defined  herein)
oersonally attest to the accuracy of information contained in
comoliance documents made available to SPA pursuant  to the
terns of a settlement agreement.

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                               -2-


     The  inspection  proqraas -of E?A and other .federal recula*orv
 agencies  arejbaaed of  necessity on the concept  that  a United
 number of regulated  facilities will be inspected  each y»ar.
 Conversely, -this means that a  large number of reculated parties
 can operate for extended periods of time without 'being the
 subject of an on-site  inspection by EPA sta^ff.  Rence, it is
 crucial 50 ensure that all recuired compliance  reports are
 received ---tr^m the regulated facility in a timely  manner.  in
 additlon--and eaually  as iaroortant — timely review of such
 reports must oe.. undertaken bv  EPA to ensure that  the reporcs
 are.- adeouate under the terms of the settlement  agreement.

     £?A experience  shows that the majority -of  regulated parties
 make Good faith efforts  to comply with their responsibilities
 under the environmental  laws and regulations,   severtaeless, tae
 Aqency wust' have effective monitoring procedures  to  detect
 instances of noncompliance  with a settlement agreement.   A vital
 component of these orbcedures will be to ensure  that  the environ-
 mental results obtained  in  the enforcement action are indeed
 achieved and that criminal  sanctions, where appropriate/, are
 available to respond to  instances of intentional misrepresentation
 or fraud committed by such  violators. -
                                                                 •
     EPA. vili ensure that all responsible officials entering
 into settlement agreements  with the Agency are held accountable
 for their subsequent actions anc the actions of  any subordinates
 responsible for 'the information contained in compliance  reports
 submit tea to the Agency.


 III. CPIPAH.CE

     ».  certification bv Responsible corporate  Official

   -  ?n« terns of settlement agreements, as well as any  certifi-
 cation languaae in subsequent reports to the Agency,  should
 be drafteo in:-a manner to trigger the sanctions  of  IS O.S.c.
"51001, _£/ in the event that false inf oration is knowing ly^and
 willfully submitted to EPA.  Submission of such  false information
JJ  Onited-states Code, Title  18, Section 1001  provides:

          -Whoever/ in any matter within the  jurisdiction
     of any department or agency of the United States knov-
     incly and willfully falsifies, conceals'-or  covers up
     by'tric*, scheme, or device a material fact, or makes
     any false, fictitious or fraudulent statements or
     representations, or makes  or uses any false writing
     or" document knowing the same to contain  any *»Jse'«
     fictitious or fraudulent statement or entry, shall be

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        01/11/1980 14:33  FROM
 may also expose the defendant (5)  in  judicial consent -decree
 falsification incidents to both civil  and cciainal Contempt
      This provision of law is a key sanction within the  federal
 crininai.code for 'dxscour*gina any  person frost intentionally
 deceivina or misleading the united  states Government.
          '•
          ••1 .   signatories  to

    '• ^Settiewent agreements  should  specify that all future  Cepcrts
 by the settling party to 'trie  Agency, which purport to document
 compliance with the terms of  any agreement, shall be signed by
 a responsible official.  The  term  "responsible official* means
 as follows:^
 •          i
              a.  For a corporation;  a responsible corporate
 officer.   A* responsible corporate  officer aeans:  (a) A president,
 secretary, treasurer or vice-president of the corporation  in
 charge of a  princioal business  function, or any other person who
 performs  similar policy- or decision-making functions for  the
 corporation,  or (b)  the manager of one or sore manufacturing,
 production,  or operating facilities employing aore than 250      ,
 persons or having gross annual  sales or expenditures exceeding
 S35 million  (in 19.87 dollars  when  the conscaer Price Index was
 345.3), if authority to sign  documents has been assigned or
 delegated to  the manager in accordance with corporate procedures.

              b.  ror a partnership or sole proprietorship: a
 general partner or the proprietor, respectively.

          2.   When to secuire  a  Certification Statement

     The  reouirement for an attestation by a responsible
 official  is always useful as  a  natter of sound regulatory
 manacenent practice.   Such  a  requirement is ooce urgent,
(Note 1, cont'd)
                                .                              r
     fined not more  than '$10/000:or  imprisoned not more than:
     five yta,rs,-or  both.*

There are four basic elements  to  a Section 1001 offense: (1) a
statement; (2) falsity;  (3)  the raise statement be made "knov-
inoly and willfully"; and  (4)  the false statement be made in a
-matter within the jurisdiction of any department or agency of
the Onited States".   Onited  States v. Harchisio, 344 F.2d 653,
666 (2d Cir. 1965).

_J/ For UPDES matters,  the definitions ©£ "responsible official"
and "certification",  as set  forth in 40 CF* 5122.22, may be used
as alternative language  to this quidsnee.

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                              -4-
 however, where  a  regulated party has a history .of  npncompuane*
 or wher« prior  violations place one's veracity into" question  3/
           >"*                                            '-

         3.  Terras of a  Certification statement

     An.example of an appropriate certification  stateaent foe
 inclusion %n reports  suomitteo to trie Agency  by  regulated par-tes
 who are .signatory to  & settlement acreetaent is as-follows:

      • •                                               •
                "I certify that tne information contained
           in or  accompanying this (submission)  (document)
           is true, =.-curateJ and complete.

              "As to  (the)  (those) identified  portion(s)
         '  of this (submission) (docuaent) for which I
           cannot personally verify (its)  (their)  truth
         •  and  accuracy,  I certify as the company  official
           havinc supervisory responsibility for the
           person(s) wno, acting under sty direct instructions/
           znade the verification, that.this inforaation is
           true,  accurate, and completr."_*/
                                                                 •
                                           •      .

     B.   Documentation to Verify Compliance

     Typical settlesent  agreeaents require specific steps to
 &e undertaken by  the violator.  As £PA statf wembecs engage in
 settlement neqotiations  and the drafting of settleoent docuaents,
 they should identify that docuaentation which  constitutes the
_3/  While personal liability is desirable to promote coapliance,
it sftould be noted that corporations may be convicted under 18
tf.S.C.   S1001 as well.  A corporation nay be held criminally
responsible £or the crioinal acts or . its enpioyees, even if the
actions of the employees vere againstrtorporate policy or-express
instructions.  s«« o.S. v. Automated MedicalLaboratories, 770
P.2d 339 (4th Cir. 1985); U.S. v. Riehjoend, 700 P.2d 1183 (8th
Cir. 1983).  Moreover; both a corporation and its agents Bay'
be convicted-for the same offense.  See O.S. v. Basic Construc-
tion co. , 711 F.2d 570 (4th Cir. 1983).

J±J  It is inevitable that in negotiating consent agreements,
counsel for respondents will seek to insert language in the
certification statement as to the truth of'the submissions to be
to tne  -best inforcation" oc to the "fullest understaneing" oc
"belief- of the certifier.  such qualifiers should  not be
incorporated, since the provisions" of 18 U-S.C- $1001 proviae
*or prosecution foe Baking false statements knowingly and
*iJlruily--not for forming erroneous beliefs, etc.

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                              -5-

                                             •
 most userul evidence tnat the action  requires .nas actually
 undertaken. ..The aost useful evidence would be  that  information
 or docueent molten tbat best and cost easily allows tae Agency
 to verify compliance with the terns (including  milestones) of
 a settlement agreement.   Examples  of  documentation to substantiate
 compliance include,  but  are not limited to, invoices, work
 oraers,i,dtsposai records,  an* receipts or manifests.

      Attachment A is a suggested type of checklist that can be
 developed tor use within each program area._•»/  -^e  checklist
 includes" examples or specific documentary evidence wnicn can De
 required to substantiate that prescribed actions have, in fact,
 been undertaken.

 IV.   SCMMASY

      This.Guidance is to Drovide assistance to  SPA employees
 who  negotiate and drart  settlement documents:   It is appropriate
 when circumstances so dictate that such documents contain
 sufficient certification language  for ensuring, to t&e maximum
 extent  possible, that all  reports  cade to EPA,  pursuant to the
 terms of any settlement  agreement, are-.true, accurate, and
 complete, and that such  reports are attested to by a responsible*
 official.
                                                                 •
      The Agency must incorporate within its overall  regulatory
 framework ell reasonable means for assuring compliance by the
 regulated community.   The  inclusion of compliance certification
 language,  supported  by precise documentation requirements, in
 neaotiated settlement agreements may, in appropriate instances,
 mean  tne difference  between full compliance"with both, tn«
 letter  and the spirit of the lav,  and something less than full
 compliance.   In  the  case of the latter, the violating party
 is then  subject  to the sanctions of the federal criminal code.


 Attachment  A
 $/ EPA or a State may  be  unable to confirm the accuracy of
certifications for an extended  period  of  tine.   Therefore,
it is suggested that, whenever  certification by a respondent/
defendant is recruited,  the order/decree provide that "back-up"
documentation—such as  laDoratory notes ana materials of the
tvpes listed in the examples in the text  ab~ove—be retained for
an appropriate period of time,  such as three years*  See, for
example, the 3 year retention time in  40  CFR S122.4Kj)(2).

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                                     MEANS Of CRRTIPYINQ COMPLIANCE
                                         H!Hf CONSENT AGREEHOTTS
                                               (Examples)
I      Action Required By
j      consent Agreement   ,.
\
{•Purchase pollution control
I     equipment.
                                 J
      Violator's urflcial
      Certifies That:
                                                                        nocumonts Acconf»nyin(j
                                                                        Certification!	
 Installation
(•Onnolna operation and main-
I    tenance
I
       itiacharge levels
| 'Labeled transformers
I                     -
|«Do risk study
I
(•litre
I
I
       ocnplyinc) coatings
j—	
|*Train^flpToye*s le.g.» work
•Ekjuipment purchased


•Equipment installed and tested

•Operating as required



•Discharge levels have been not
| •Transformers have been labeled

 •Study has been completed

 •Employees have been hired
I
(•Verifying complying coatings
    are used.
                                                                    •invoice
                                  JMnvolo? for work with photograph

                                  | *Cont i nuotis won i r.or t n
-------
               (continued from previous paqe)
                                                   MEANS OP CBrrr"iWj COMPLIANCE
                                                       WITH OCtlSt...' AGREEMENTS
§
P
              •Dispose of pens    I
              •Replace PCB transformers
              •Realator pesticide certifi-
                 cation of applicator-

              •Remove cancelled product  from
                 the market
                   Action Required By
                   Consent Agreement
                                 1       Viplator*n Official
                                 I       Certifies That;
                                 I
                                 |*PCft3 disposed of in lawful
                                 j;   manner
                                 I
                                 (•New transformers installed
                                 I
                                  •Applicator certification has
                                 |    been accomplished
                                 I
                                   Removal  has been accomplished
                                                                                   Documents Acoonvanylng
                                                                                   rertmnAfrlfini'    '
              •Comply with asbaatoa  removal  |
                 and disposal regulations
              •Monitor waste atream
              *SliK*» removal


              'Conduct qramdwatee monitoring
                                                                               •Copies "of manifests


                                                                               •Copies of purchase and instal-
                                                                                  lation receipts

                                                                               •Copies of certificates
                                                                               •Copies of corceapondance with
                                                                                  custoitwrs and dociimuntation
                                                                                  of removal
                                                                               *Copiea of customer lists for
                                                                                  Independent verification by
                                                                                  EPA and states
                                 |*Cowpllance with asbestos removalJ'List of locations of all
                                 |    and disposal regulations on   j
                                 |    a job-by-job basis
                                  —           ' •	•         |
                                  •ttoete stream hao been properly  MDischarge Monitoring Report
                                     monitored
•Collect and analyze aoli
   samples
\*Rcv
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                                                               -1 7 ¥ - V
             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON,'D.C. 20460 '                    /.


                        -MAR Q 3 1995
HSMOMOTOTIH                                         .
                                          -    •     -    CSMPL1ANC2ASSURANCS
SUBJECT:  Processing Reuefor Use of Enforcement Discretion
 FROM:     Steven A.
          Assistant Administrator

 TO:       Assistant Administrators
          Regional Administrators
          'General Counsel
          Inspector General

     In light of the reorganization and consolidation of the
 Agency's enforcement and compliance assurance resources
 activities at Headquarters,  I believe that it is useful to '
..recirculate the attached memorandum regarding "no action"
 assurances1  as a reminder of both this policy and the procedure
 for handling such requests.   The Agency has long adhered to a
 policy against giving definitive assurances outside the. context
 of a formal 'enforcement proceeding that the government will not
 proceed with an enforcement response for a specific individual
 violation of an environmental protection statue, 'regulation, or
 legal requirement.  This policy, a necessary and critically
 important element of the wise exercise- of the Agency's
 enforcement discretion, and which has been- a consistent feature
 of the enforcement program,  was formalized 'in 1984 following
 Agency-wide review and comment.  Please note that OZCA is
 reviewing the applicability of this policy to the CZRCLA
 enforcement program, and will issue additional guidance on this
 subject.

     A "no action" assurance includes,  but is not limited to:
 specific or- general requests for the Agency to exercise its
 enforcement discretion in a  particular manner or in a given set
 cf circumstances (i,.e., that it will or will not take-an.
 enforcement action)"/* the development of policies- or.other
     1  Courtney H.  price,  Assistant Administrator for Enforcement
 and Compliance Monitoring,  Policy Against "No  Action" Assurances
 (Ncv. is, iss4) (copy attached) .
                                        CO

-------
 for forbearance or action involving enforcement-related
 activities.  The procedure established by this Policy \ requires
 that any such written or  oral assurances have the advance written
 concurrence of the Assistant Administrator for Enforcement and
 Compliance Assurance,                   "           .
                                      *
      The 198.4 reaffirmation of this policy articulated  well the
 dancers of providing "no  action"  assurances.  Such- assurances  -
              legal requirement may severely hamper -later/
 similarly situated.
     Moreover, these principles  are their most compelling _in the
 context of rulemakings :   good public policy counsels  that blanket
 statements of enforcement discretion are not always a
 particularly appropriate  alternative to the public notice-and-
 cosment rulemaking process.   Where the Agency determines that it
 is  appropriate to alter or modify its approach in specific, well-"
 defined circumstances, in my view we .must consider carefully
 whether the objective  is  best achieved through an open -and public
 process (especially where the underlying requirement  was
 established by rule under the Administrative Procedures Act) , or
 through piecemeal expressions of our enforcement discretion.

     We have recognized two  general situations in which a no
 action assurance may be appropriate: where it is expressly
 provided for by an applicable statute, and in extremely unusual
 circumstances where an assurance is clearly necessary to serve
 the public interest and 'which no other mechanism can  address
 adequately.  In light of  the profound policy implications of
 granting no action assurances, .the 1984"*Policy requires - ther
 advance concurrence of the Assistant Administrator ,f or this
•office.  Over the years,  this approach has resulted in the
 reasonably consistent and appropriate exercise of EPA's
 enforcement discretion, and  in a manner which both preserves the
 integrity of the A'gency-and  meets the legitimate, needs served by
 a mitigated enforcement response.

     There may be situations where the general prohibition  on no
 action assurances should  not apply under CZRCLA  (or the
 Underground Storage Tan3cs or RCRA corrective action programs) .
 For example,  at many Superfund sites -there is no violation  of
 law. '  OECA is evaluating  the applicability of no. action
 assurances under CZRCLA and  RCRA and will issue  additional
 guidance on the subject.

-------
     Lastly,  an element, of the 1984 Policy which I want to
highlight is  that "it does not and should not preclude the Agency
from discussing fully and completely the merits of a particular
action,  policy, or other request to exercise the Agency's
enforcement discretion  in a particular manner.  I welcome a free
and frank exchange of ideas on how best to respond to violations,
aindful of the Agency's overarching goals, statutory directives,
and enforcement arid compliance priorities.  I do, however, want-
to ensure that all such" requests are handled iii a -consistent and
coordinated manner.

Attachment

cc:  OECA Office Directors
     Regional Counsels
     Regional Program Directors
                                      $51

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      •t I UNITED STATES .ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON. D.C. 20460           .   '
                                                          Of fid O*
                                                          0*C£M£NT

                                                       CCMPUAMC£ MONITOAINC
 MEMORANDUM

 SUBJECT:   Policv Against "No Action"  Assurances
                             [\   -jr
 FROM:      Courtney M.  Price I __Q> ±x~-^
           Assistant -Administrator  for.Enforcement
             and Compliance Monitoring

 TO:        Assistant Administrators
           Regional Administrators  .
           General Counsel
           Insoector General
      This memorandum reaffirms  EPA policy against giving  .
 definitive assurances  (written  or  oral) outside  the context cf
 a  formal enforcement proceeding that EPA will not proceed with
 an enforcement  response  for  a specific  individual violation cf
 an environmental protection  statute, regulation, or other
 legal requirement.

      "No action" promises may erode the. credibility of EPA's
 enforcement program by creating real or perceived inequities
 in- the Agency's treatment of the regulated community.  This
 credibility is vital as  a continuing incentive for regulated
 parties to comply with environmental protection  requirements.

      In addition, any ccrnniitaent not to enforce  a legal
 requirement against a particular regulated party may severely
 hamper 1-ater enforcement efforts, against that party, who nay
 claim gocc-faith reliance on that  issuance, or  against oiier
parties who claim to be  similarly  situated.

     This policy against definitive no action promises to     '
parties outside ths Agency applies in all contexts, including
assurances requested:

     0  both  prior'to and after a violation has  been committed;

     0  en the basis that a  State or local government  is
        responding to the violation;

-------
      0
         on the basis- that revisions to the underlying lecal
         requirement are being considered;    •   ..".."

         on the basis that the Agency has determined that the
         party is not liable or has a valid defense;

         on the basis that the violation already has beer.
         corrected (or that 'a- party, has promised that it will
         correct the violation)?, or

        'on the basis. that the violation is not of sufficient
         prioritv to merit Acencv action.    '  '
        •    -~          ,J—          .'•
      The Agency particularly must avoid no action prnmii
 relating either to violations of judicial orders, for which a
 court has independent enforcement authority, or to potenti-al
 criminal violations, for which prosecutorial discretion rests .
 with  the United States Attorney"General.

      As  a general rule, exceptions to this policy are warranted
 only                                            .   -  x-.

      e   where expressly provided by 'applicable statute or
         regulation (e.g., certain upset or bypass situations)

      *• "in extremely unusual cases in which a no action
         assurance is clearly neccessary to serve the public
         interest (e.g., to allow action to avoid extreme  risks
         to public health or safety, or to obtain important
         information for research purposes)  and which no other
        niecnanism can address adequately.              ^^
                 *
 Of course,  any exceptions which EPA grants must be in an  area
 in which EPA  has  discretion not to act under applicable law.,

     This poiicy*-in no  way is intended to constrain  the way in
 which EPA discusses and coordinates enforcement plans with
 state or local  enforcement authorities consistent with norma-^
vorkino relationships.   To the extent that a statement or i?A s
enforcement intent 'is necessary to help support or conclude an
effective state enforcement effort, EPA can employ language
such as the following:
EPA encouraces State  action  to  resolve violations  of
            """       _.        .   ..l____^J__,w*«aB« 4» *»    f  W *S ^ ® *
                  *—** ->,^pw— ,_,^. _ _ _ __ ^- --  — _              ^ ^
                  Act and supoorts the actions wnzcn
is -taicinc to address the violations at issue.  To  the exc
that the'state action does not satisfactorily resolve ..-..
vlblations,  ZPA may pursue its own enforcement act:cn.

-------
                              e  c.-  p_
              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                            WASHINGTON. O.C. 20460
 MEMORANDUM

 SUBJECT:   Procedures  to Improve Coordination before the
           Environmental Appeals B
 FROM:      Ray Ludwiszewski     /
           Acting General Counsel
           Office of  General Counsel
           (LE-130)
          Herbert H.  Tate,  Jr.
          Assistant Administrator
          Office of Enforcement (LE-133)

 TO:       Environmental Appeals Judges Nancy B.  Firestone,
          Ronald L. McCallum and Edward E.  Reich


      Attached to this memorandum are procedures  which we are
 adopting  to  improve coordination among the Office of General
 Counsel  (GGC), Office of Enforcement (OE)  and the Offices of
 Regional  Counsel  (ORC)  on positions-taken by each of these
' offices before .the Environmental Appeals Board (EAB).  These
 procedures were developed directly in response to a request from
 the  EAB and  incorporate comments made by Ed Reich on behalf of
 the  EAB.

      These procedures will be effective immediately.  We are
 requesting that the EAB continue its practice of sending copies
 of all of its final decisions to the Regional Counsels, the
 Associate General Counsels and the Enforcement Counsels.  In
 addition, we are requesting that, in addition to sending copies
 of notices to appeal  permit decisions to the affected Regional
 Counsel,  the EAB send copies of these notices to the affected
 Associate General Counsel and Enforcement Counsel.

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     We  believe that these procedures will  go  a  long way toward
 improving coordination among our off ices  on positions  taken
 before the EAB.  These procedures commit  our offices to evaluate
 our- success in implementing these procedures and accomplishing
 our objectives in approximately six months. We  welcome your
 active participation in this process and  hope  that together we
 can improve the Agency's administrative litigation practice. _
v
 Attachment

 cc:  Regional Counsels
      Associate General Counsels
      Enforcement Counsels

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       5  .  _ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
      /                    WASHINGTON. O.C.  20460
  •«* mf^

                               JAN 2 5 1933
MEMORANDUM

SUBJECTS  Procedxires to Improve Coordination before the
          Environmental Appeals Board
FROM:     Ray Ludwiszewsk
          Acting General counse
          Office of General •! Counsel
          (LE-130)
          Herbert H. Tate,
          Assistant Administrator
          Office of Enforcement
          (LE-133)  "


TO:       Regional Counsels
          Associate General Counsels
          Enforcement Counsels


     Attached to this memorandum are procedures which ve are
adopting to improve coordination among the  Office of General
Counsel (OGC), Office of Enforcement  (OE) and the Offices of
Regional Counsel  (ORC) on positions^taken by each of our offices
before the Environmental Appeals Board  (EAB).  As you will '
recall, the EAB requested that we work together to develop these
procedures.                                                '

     The procedures adopted reflect discussions held at the
OGC/ORC management retreat in October 1992  and incorporate OE's
existing policy in this area.  In addition, these procedures
reflect comments received from many of you  and comments received
from Ed Reich on behalf of the EAB.

-------
     These procedures will be effective immediately.  Under the
procedures, each of you responsible for matters which go before
the EAB is requested to designate at least one person to serve as
a contact person to aide in the coordination process established
by the procedures.  The option of whether to designate one or
more persons to fulfill all these functions is up to you.  By
February 12. 1993. please identify the person(s) you are
designating to coordinate matters related to permit appeals to
Susan Lepow (FAX 202-260-7702) and the person(s) you are
designating to coordinate matters related to enforcement appeals
to Fred Stiehl  (FAX 202-260-4201).  They will compile a complete
list of these contacts and distribute them to you.

     We believe that these procedures will go a long way toward
improving coordination among our offices on positions taken
before 'the EAB.  We appreciate the commitment each of you is
making to improve the Agency's administrative litigation
practice.  These procedures commit our offices to evaluate our
success in implementing these procedures and accomplishing our
objectives in approximately six months.  We encourage you and
your staff to actively participate in this process.

Attachment

cc:  Environmental Appeals Board Judges Firestone, McCallum
      and Reich
     Regional Administrators
     Assistant Administrator for Water
     Assistant Administrator for.Air and Radiation
     Assistant Administrator for Solid Waste and Emergency
      Response
     Assistant Administrator for Prevention, Pesticides and Toxic
      Substances

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  OFFICE OF GENERAL COUNSEL, OFFICE  OF ENFORCEMENT AND  OFFICE OF
REGIONAL COUNSEL COORDINATION ON MATTERS BEFORE THE
                  ENVIRONMENTAL APPEALS BOARD

     Under the environmental statutes administered by the
Environmental Protection Agency, the Administrator has delegated
authority to decide appeals of permit decisions made by the
Agency's Regional Administrator's and administrative penalty
decisions made by the Agency's Administrative Law Judges to an
Environmental Appeals Board (EAB).  The specific matters
delegated to the EAB are detailed in a final rule published in
the Federal Register on February 13, 1992, 57 Fed.  Reg. 5320.

     At the request of the EAB, the Office of General Counsel
(OGC), the Office of Enforcement (OE) and the Offices of Regional
Counsel' (ORC) have identified ways to improve coordination on
positions taken by each of these offices before the EAB.  The
Office of General Counsel and the Offices of Regional Counsel
discussed this issue at the OGC-ORC Management Retreat held in
October 1992.  The Office of Enforcement has had an existing
policy in this area.

      Unless and until modified, this memorandum outlines the
policies and procedures which will be followed to coordinate
positions taken with respect to permit appeals and appeals of
enforcement cases  (including significant interlocutory appeals)
before the EAB.  Each Regional Counsel, Associate General Counsel
and Enforcement Counsel responsible for matters which go before
the EAB will designate at least one individual to serve as a
contact person to aide in the coordination process established in
this memorandum.

     A. Permit Appeals

     The EAB sends notice to the Regional Counsel when a notice
of appeal of a permit is filed; the Region has 45 days to file a
response with the EAB.  We will request the EAB to send a copy of
this notice to the affected Associate General Counsel  and
Enforcement Counsel, as well.

     After the notice of appeal  is received by ORC/OGC, staff in
ORC will consult with OGC staff about each case. The discussions
will focus on any  important issues raised by the case.  Each cas«
will be handled in one of three ways:  (1) OGC will sign the
response as co-counsel and will have written or participated  in
writing the response; (2) OGC will  appear as "of counsel"  on  th«
response and OGC will have reviewed the response;  or  (3) OGC  will
not be on the response and though ORC will have coordinated with
OGC, OGC will not necessarily review the  response.

     OGC and ORC will both need  to  consent to  the  appropriate
level of handling  for each case.  Staff  in each office will
consult with their supervisors,  as  appropriate.   Any
disagreements between the Regional  Counsels  and the Associate

-------
                                                     Deputy


        is important  to  coordinate positions taken in one case
with other Regions and with the Headquarters program office
Significant enforcement  issues may also be raised in -the context
of certain permit appeals.   In appropriate cases OGC and ORC-
staff need to coordinate with OE,  other Regions1 and their
respective program offices  before  a response is filed.  Upon
receipt of a notice of appeal,  the Enforcement Counsel or OE
Branch Chief will identify  any enforcement issues that should be
addressed in the appeal.  In most  cases it may be adequate for OE
and other Regions to  be  informed of positions taken before the
EAB through the monthly  OGC/OE/ORC branch chief conference calls.
This will be a standing  agenda item for the monthly calls; the
ORC branch chief will generally be responsible for leading this
discussion.

     It is important  for the Regions to coordinate as early as
possible with all Headquarters offices on the issues raised in
permit appeals and requests for evidentiary hearings so that EPA
will be advancing consistent positions.  Some of this
coordination needs to be initiated by the program offices and
some by ORC.

     B.  Enforcement  Appeals

     There is less time  for the Agency to decide its position on
appeals of enforcement cases.  Pursuant to 40 CFR section
22.29(a), enforcement appeals typically obtain as a matter of
right, and the Agency must  file its notice of appeal and an
accompanying brief within 20 days  after service of the' initial
decision or order of  the Presiding Officer.  See 40 CFR section
22.30(a). 1

     In a May 3, 1989 memorandum from then Acting Assistant
Administrator Edward  Reich, a process was established to provide
for review of adverse decisions of'-ftils as well as favorable
decisions that are appealed by the respondent.  (See attached
memorandum.)  That process  is still an appropriate method to
provide an efficient  way to identify and address important issues
in a case that should be raised to the EAB. It should be noted
that important legal  and policy issues warranting an appeal may
be raised in cases even  though the Agency prevailed in the relief
sought.  This memorandum reaffirms the procedures of the earlier
memorandum with the following modifications.
     1   In appropriate circumstances, agency counsel, however,
may seek leave from the  EAB for extensions  of time in which to
file such appeals or briefs, if they can satisfy the requirements
of 40 CFR section 22.07(b).  Depending on the circumstances,  it
may be advisable to seek an extension only  for the filing of  the
brief,  rather than the notice of appeal.

-------
     The ORC attorneys will consult directly with the Regional
Counsel (or Deputy Regional Counsel if so directed by the
Regional Counsel) to discuss their recommendation as to whether
EPA should appeal each enforcement case.  This view should be
included in the summary of the decision forwarded to the OE
Branch Chief, the OGC Branch Chief, and the ORC contacts.  The
Regional Counsels will report on decisions to appeal enforcement
cases in their weekly report to Headquarters.  Decisions in
Headquarters cases will be reported. in OE's Weekly Highlights.
As with permit appeals, each case where a decision is made to
proceed with an appeal, will be handled in one of three ways:  (i)
OE will sign the brief as co-counsel and will have written or
participated in writing the brief;  (2) OE will appear as "of
counsel" on the brief and OE will have reviewed the brief; or (3)
OE will not be on the brief and though ORC will have coordinated
with OE, OE will not necessarily review the brief.

     The Regional Counsels and Enforcement Counsels will take
personal responsibility to decide what kind of coordination is
necessary with OGC before a decision is made to seek, or forego,
an appeal of an enforcement case.  OGC agrees to identify any
generic areas where it needs to be consulted on a routine basis
before a decision to appeal or not to appeal is made.

     C.   Headquarters Assistance to EAB
     *
     Subject to the prohibition on ex parte communications,
nothing in this memorandum is intended to derogate the ability of
OGC or OE to provide technical assistance to the EAB when the EAB
deems it appropriate.

     As part of their participation in the review of appeals, OGC
and OE should assure that any relevant policies or new
regulations: are brought to the attention of the Board, since
Headquarters offices will often be more aware of such matters
than Regional offices.

     D.  oral
     The attorney best able to present the Agency's  position
should present oral argument to the  EAB.  This will  be decided on
a case by case basis. The Board has  a strong preference in favor
of having a single attorney present  the Agency's  argument.
Nevertheless, the Board has allowed  more than one attorney to
divide the argument where the Agency deemed  it essential for the
effective presentation of its case.  Accordingly, there should be
an opportunity for Regional and Headquarters attorneys to argue
before the Board in appropriate cases.

     Any disagreements between the Regional  Counsel and the
Associate General Counsel or Enforcement Counsel regarding who
should present the oral argument  to  the EAB  will, be elevated to
the appropriate Deputy General Counsel or  Director of Civil
Enforcement.

-------
     The Agency attorney(s)  presenting oral argument should be
able to represent to  the fullest extent .possible that the
positions taken in  argument have been coordinated with, and
approved by, ORC, OGC and OE,  as appropriate.

     E.  Decisions

     .The EAB sends  copies of all final decisions -to the Regional
Counsels, the Associate General Counsels and the Enforcement
Counsels.
     F.  Follow-up

     Our success in implementing these procedures and
accomplishing our objectives will be evaluated in an ORC/OGC/OE
conference  call in approximately six months.

Attachment

-------
  ,uo **,.
 ^ ^ v*

     ^
                        -
       ! UNITED-STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON. D.C. 2046O
                                MAY  31989
                                                         C»o«« utwr MO
MEMORANDUM

SUBJECT:  Strengthening the Agency's Administrative
        '  Litigation Capacity

FROM:   •  Edward E. Reich        ^	J
          Acting Assistant Adninistrator

TO:       Regional Counsels
          Regions I-X


     In my memorandum to you of January 31, 1989, entitled
"Issues Relating to Administrative Litigation1*, I asked for
comment on a proposed process for dealing with decisions on
whether or not -to appeal ALJ decisions.  Your comments were
generally supportive of the proposal.  Following discussion of
this issue at its most recent meeting, the Enforcement Management
Council affirmed the proposal contained in the' earlier draft with
the modifications set out below. . Accordingly, we are instituting
a process, beginning July 1, 1989, to provide for the
incorporation of national program and other Regional perspectives
in the decision whether or not to appeal adverse ALJ decisions.
This memorandum describes the mechanism.

     Administrative enforcement is 'a-^significant and dynamic
element of the Agency's enforcement program.  As new programs
develop and mature programs evolve, decisions by the ALJs and the
Chief Judicial Officer (CJO) mold and influence the direction of
these programs.  Adverse decisions can not only cause problems
relative to the specific issue and program giving rise  to the
decision but can also, particularly when rendered at the CJO
level, significantly impact enforcement programs outside of the
one immediately addressed in the decision.  For this reason it is
important that the Agency's enforcement managers pay proper
attention to the decisions issued by the ALJs and CJO.  As I
noted earlier, the process set out below was affirmed at the
most recent meeting of the Enforcement Management Council.  This
                                 .276

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                                -2-'

 process is also in line with the agreeaent''reached' at the Atlanta
 Regional Counsels' meeting.

    ^  In order to initiate the next phase of this effort,  please"
 designate an attorney in your office 'who will serve as the
 standing contact for receipt of materials relating to appeals of
 administrative decisions.  This contact will receive material as
 identified below for all media for appropriate distribution  and
 action xn your Region.  This person does not necessarily have to
 be the person representing the Region on the substantive -
 conference calls that will take place but will, as necessary,
 facilitate the Region's participation.  Please send the naae of
 your designee to Fred Stiehl (LE-134P), by June 1, 1989.  Fred
 will prepare a master list and distribute it to all Regions.

      Starting in July, the affected Region is to provide to  the
 relevant Associate Enforcement Counsel in DECK and the designated
 standing contacts in the other Regions a notice and an
 opportunity to consult on all adverse decisions of the ALJs  and
 all favorable decisions that are appealed to the Chief Judicial
 Officer by Respondents.  This process will allow for
 consideration of issues of national interest that may go beyond
 the concerns of the involved Region.  The process will be
 initiated by sending a "fax" of. a copy of the decision and a
 brief summary of the decision by the Regional Counsel Branch
 Chief to the appropriate OECM Branch Chief, the appropriate  OGC
 Branch Chief, and the ORC standing contacts within 3 days of
'"receipt of the adverse decision.  -That transmission will also
 notify all parties of the time of an OEdf-Regional Office
 conference call to discuss appeals issues.  This call should
 take place as soon as possible after receipt of the summary, but
 no later than 4 calendar days after the "fax" is sent.V
 OGC will be invited to participate inHthis call if they choose to
 •do so.  If your Region wishes to participate in the appeal
 decision, your contact should advise the .initiating Regional'
 Counsel Branch Chief of your views prior to the phone call to
 OECM and can choose to participate in the call.  The Regional
 Counsel Brancn Chief will advise OECM if a conference operator is
 needed to include more than one Region in the call.  In the  event
 of agreement to file an appeal, the discussion will center  on
 identifying issues for appeal, what support will be available to
          A workgroup is considering amendments  to the
 Consolidated Rules of Practice is  lengthen the  time  J           _
 Until such time as the rules are changed,  however, the Agency has
 20 days from service of the order  to  file  this  notice of appeal
 and supporting briefs.  40 C.F.R.  22.30.
                                  a-?/

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                               -3-
                                          /
assist the lead office, and how the national and regional
perspectives can be incorporated into the briefs. , The views .of
the Headquarters program office-will be solicited by the
Associate Enforcement Counsel and factored into the discussion"
between the Region and Headquarters.  In the event there is
disagreement at the Branch Chief level as to whether to appeal,
the question will be elevated to the Regional Counsel and the
Associate Enforcement Counsel for resolution.'

     Given the very short time available to file appeals, this
process will assure, at minimus cost, national program input and
regional'consistency in a timely manner.  The process should be
evaluated in light of our experience after one year to see if
adjustments are appropriate.

cc:  Deputy Regional Administrators
     Enforcement Management Council
     Headquarters Enforcement Office Directors
     Deputy General Counsel for Legislation, Litigation,
       and Regional Operations
     Associate Enforcement Counsels

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                                "/?
                                                             *
                       WASHINGTON. D.C. 20460                   *y.
                            JUL 1 1 1994
                                                  OFFICE Of ENFORCEMSWT
MEMORANDUM

SUBJECT:  Redelegation of Authority and Guidance on Headquarters
          Involvement in Regulatory Enforcement Cases

FROM:     Steven A. Hermai
        '  Assistant AdministJ

TO:       Assistant Administrators
          Regional. Administrators
          Deputy Assistant Administrators
          Regional Counsels
          OECA Office Directors and Division Directors


     On May 31, 1994, the Administrator commissioned an effort to
follow up on the issues raised by the Regional Impacts Task Force
(RITF) regarding the division of roles and responsibility between
the Regions and Headquarters  .n the enforcement and compliance
assurance program.  The principal area which needed further
discussion regarded the management of civil judicial and
administrative cases.  The specific question to be addressed
concerned the nature and extent of Headquarters involvement in
case development and litigation.

     A small work group, which included personnel fron^OECA, the
Regions, and OGC, was formed to undertake this follow-up effort.
The work group approached its assignment in two phases.  Phase 1
has focussed on the 'roles issue in the regulatory enforcement
context; Phase 2 will examine the issue in the Superfund context.
Phase 1, on which the work group has completed its work, is the
subject of this memorandum; Phase 2 will be brought to closure in
the near tens.

     The RITF provided a basic framework for the
Headquarters /Regional relationship in the case management arena,
concluding that Headquarters involvement was appropriate in a
number of contexts:  a) cases or issues that rise to a level of
national attention; b) multi-regional cases against the same
company; c) national initiative cases.  The RITF Report
encouraged redelegation of authority for matters that are not of
national Import.  The relevant portions of the RITF Report are
attached to this memorandum as Attachment A.  Also attached to
                                       r—/t f\ l/i
                             3.13        ^ C D I O

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this memorandum are supplemental guidance developed by the
follow-up work group  (Attachment B), giving further definition to
the concept of "national 'Significance,11 and a new redelegation of
authority to the Regions that builds on the work of the RITF and
reflects the views of the work group (Attachment C).
                    •
                          .                       *  /
     This memorandum and its attachments, taken together,
establish the general framework and guidance that the Agency will
hereafter follow in the processing and management of civil
regulatory enforcement cases.  The effective date for
implementation of this new approach will be October 1, 1994.  In
the meantime, we will be developing further the audit:ng concept
outlined .below and visiting the Regions to discuss expectations
regarding implementation.


                   A NEW APPROACH TO OVERSIGHT

     As articulated by the RITF, the fundamental role of OECA is
to provide overall leadership in the enforcement and compliance
assurance arena.  This leadership role ^as a number of different
facets, including devising the "national strategy for the program-,
addressing matters of national policy and concern, ensuring
national consistency,' ensuring the .development of regulations and
laws that are clear and enforceable, representing the Agency
before the Congress and with other agencies, and ensuring
effective implementation of the Agency'- enforcement and
compliance assurance program.

     Although, as discussed further below, there are significant
benefits associated with Headquarters involvement in cases, case
involvement has been historically used by Headquarters at least
in part as a means of overseeing Regional implementation of EPA's
enforcement -program.  The principal vehicle for effecting this
oversight has been-the requirement that Headquarters formally
concur on all Regional settlements of civil judicial matters,
whether or not those matters raise issues of national concern.
This concurrence process has been criticized for  increasing •
transaction costs, causing processing delays, and diverting  •
Headquarters and Regional staff attention from other, more
compelling work.

     with this memorandum, and in keeping with the  principles  of
empowerment, reinvention, and accountability, we  are
fundamentally reorienting our approach to Regional  oversight.
The new approach has the following features:
                           V

     o Value-added approach to case involvement  —  Headquarters
     involvement in cases will operate according  to the "value
     added" principle.  Under this principle,  Headquarters staff
     will be involved in cases when the  case  or  the program at
     large will benefit from such  involvement (see below for

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     furthey discussion). .

     o Focus on "nationally significant" matters and issues —
     The concurrence process will no longer be used for. purposes
     of routine oversight.  Instead, it will be reserved for  -
     cases or issues which call for Headquarters sign-off because
     of their national significance — i.e.. because they are
     national in terms of their impact or attention, are
     sensitive in nature, raise unresolved policy issues,
     establish an important .precedent, arise in an area where
     national consistency is of paramount importance fe.g.. Shell
     Oil- where an adverse legal decision raised major
     programmatic concerns under RCRA), or otherwise affect the
     overall program.  The new approach eliminates the
     distinctions between administrative and judicial cases, as
     cases in either forum can be nationally significant and can
     raise issues of national consequence.  Attachment B .provides
     specific examples of nationally significant matters.
     Because of its unique national perspective and its role as
     policy-maker and national "voice" for the enforcement and
     compliance assurance program, Headquarters staff involvement
     during the pendency of the litigation and ultimately the
     AA/OECA's review and sign-off in these circumstances adds
     value to program implementation and is essential to
     effective program implementation and public accountability.

     o'Redelegation of authority — Regional civ .1 judicial and
     administrative cases which seek a bottom line penalty1  of
     less than $500,000 will be presumed to not be nationally
     significant.  Accordingly, consistent with the attached
     delegation, I am redelegating to the Regional Counsel the
     AA's authority to concur on settlements undertaken by the
     Regional Administrator (or Regional Division Director, where
     the RA'S authority has been redelegated), provided such
     settlements adhere to national policy and guidance-*nd do
     not raise issues of national significance.  The Regional
     Counsel will, in the first instance and in keeping with thi*
     guidance, make and document the determination whether such  a
     matter raises an issue of national significance.  Judicial
     and administrative cases involving a bottom line penalty of
     §500,000 or more assume a sufficient national profile so as
     to be presumptively nationally significant and will be
     'Under the Agency's penalty policies,  this generally means
recovery of the economic benefit of noncompliance plus a gravity
component.  Where the Region has not-prepared a bottom^line
penalty before filing an administrative case, cases will be
presumed to be nationally significant if the proposed penalty
sought in the complaint to be fil«d is greater than or equal wo
$500,000.
                                275

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     reserved for the AA/OECA's  concurrence.2

     o Flexible involvement — Flexibility is  built into  the
     redelegation.  If a nationally  significant issue  arises in a
     case with a bottom line penalty under the $500,000,
     threshold, the delegation will  require the Region to consult
     with the appropriate division in the Office of Regulatory
     Enforcement (ORE)  in OECA;  OECA would, at the Division
     Director level, then have the authority to opt in for
     purposes of concurrence if  appropriate.3  For the $500,000
     and over cases, the redelegation would give OECA,  at the
     Office Director level, the  authority to opt out for  purposes
     of concurrence if,  for .example,  there are no issues  of
     national significance and the case is not likely  to  assume a
     "national profile.

     o Differential oversight — The case-by-case approach to .—
     oversight will be replaced  with a systematic approach to
     accountability which will include, at a minimum,  periodic
     auditing of regional compliance with the  reguiremerv" s of the
     redelegation, regular docket  reviews, and after-the-fact
     review of regional decision documents. Regional  Counsel
         delegations that are currently in place for
administrative penalty actions under,  e.er.. • the Clean Water Act'
(2-52-A),  the Clean Air Act (7-6-A),  RCRA Subtitle J (S--.3), and
TSCA (12-2-A), reserve the OECA  Assistant Administrator's
authority  in "multi-Regional cases,  cases of national
significance or nationally managed programs."  Consequently, the
approach outlined in this memorandum for administrative cases is
consistent with delegations relating, to these authorities.
Because the delegations that are currently.in place for RCRA
Subtitle C and the"Safe Drinking Water Act^o .not include this*.
explicit reservation, we will need to make conforming amendments
to the Administrator's delegation under these authorities.  This
will be done as part of the third phase of delegations
adjustments associated with the  reorganization.  In the meantime,
as a function of their reporting relationship with the OECA AA,
the Regional Counsels will be expected to consult with OECA,
consistent with this memorandum, on nationally significant
administrative matters arising under these authorities.

     *Where OECA opts  in,  the concurrence  requirement will be
fashioned  to reflect the character of the matter at hand.   In
some circumstances, OECA's concurrence will be required only for
resolution of the nationally significant issue  (as opposed to
requiring  concurrence on the settlement) ; in  others,  such as
where the  nationally significant issue is so  fundamental  to the
case that  the resolution of the  case inevitably speaks to the
issue in an important way, the Assistant Administrator's
concurrence will be required for the Battlement.

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forth below:
     o  "National Program'* eases — These are cases that arise in
     programs that are not implemented at the Regional level,
     such as the Mobile Source .program and enforcement of the  .
     adverse effects reporting requirements under TIFRA, and
     cases which are Headquarters-driven because the data systems
     necessary to identify noncompliance are maintained at
     Headquarters fe.g..-CFC import and export cases, certain
     acid rain cases, etc.)-  In these cases, Headquarters has
     the lead role, with little or no regional involvement.4

     o  "National Violator" cases — These are cases against a
     single "entity involving violations at facilities in more
     than.one Region  fe.cr.. the Louisiana Pacific multi-facility
     case).  In these cases, Headquarters will have the EPA lead
     for overall case direction and coordination.  Generally,
     Regional  personnel will be responsible for developing and
     supporting those components of the case that arise in their
     Region.  In national violator cases in which a
     disproportionate number of violating facilities are located
     in a single region, OECA may determine that it is more
     appropriate for personnel from that Region to play the lead
     role, essentially reporting to OECA in this capacity.

     o  ."National Initiatives" — These are clusters of cases
     involving more than one Region centered around a sector of
     the regulated community fe.o.. the pulp and paper
     initiative), a geographic area fe.a.. the Mexican border), a
     pollutant fe.q.. the lead initiative), or a particular kind
     of regulatory requirement fe.a.. the RCRA non-notif ier
     initiative).  In these circumstances, OECA.personnel will
     have a lead role in coordinating the overall project,
     including developing initiative guidance, screening cases
     for inclusion in the initiative;—and giving direction in
     terms of timing of activities, communication strategy, etc.
     Generally, Regional personnel will serve as the Agency lead
     for the individual cases that are included in the
     initiative.

     o  Single Region cases — This category includes cases which
     arise in the ordinary course of events within a Region as
     well as self-contained regional initiatives.  Regional
     personnel will serve as the Agency lead for cases  in this
     category.  Headquarters involvement will be determined
     largely by the redelegation of authority.  Thus, in
     redelegated cases,. Headquarters personnel will  ordinarily
     4In the near term, I will be doing an additional delegation
of authority within OECA for settlements  in cases  falling into
this category. .

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     not be involved;  in non-rede legated  cases,  Headquarters
     personnel v'ill be involved for the purpose  of. providing
     national perspective and expertise,  keeping the AA/OECA and
     other critical Headquarters decision-makers advised, and
     informing AA/OECA concurrence.  Whether or  not Headquarters
     is involved,  the  Regional Counsels will,  by providing copies
     to ORE of referrals to the Department of Justice and through
     regular reports and periodic consultation,  be responsible
     for keeping the AA/OECA and ORE informed regarding program
     activities.

     This guidance regarding Headquarters involvement should not
be viewed' rigidly.  Rather, it should be  viewed  flexibly, with an
eye towards using the  overall resources available to the program
to get the job done.  Thus, where, for example,  a national
initiative calls for work that is beyond  a Region's resources,
OECA personnel may be  deployed to the Region to  work with..
Regional management in leading .case developing efforts.

     Similarly, apart  from the redelegation, the need to provide
training opportunities that will leave Headquarters personnel
better able to perform their policy and regulatory role may
suggest involvement in circumstances not  expressly contemplated
above.  Additionally,  OECA retains the authority to take action,
after consultation with the Regional Administrator, in the place
of a Region in the rare situation where the Region is unprepared
to respond to a problem of national concern or to assume the-lead
in a case which is of  such paramount national interest as to
require daily involvement by the AA/OECA  fe.q..  Love Canal).

                            CONCLUSION

     In sum, this guidance and redelegation should help  the
Agency turn a corner in the Headquarters/Regional relationship in
the enforcement and compliance assuratfifce  arena.   Our new "approach
not or.ly will preserve, but reinforce OECA's leadership  role- for
the enforcement and compliance assurance  program, particularly as
it relates to nationally significant cases and issues.   At  the
same time,  it will empower managers in the Regions to  implement
the Regional enforcement program in a more efficient manner.
Moreover, the accountability mechanism contemplated here —
systematic audits, after-the-fact  review of pertinent  decision
documents,  and differential oversight — should  leave  OECA better
able to identify problems and respond to them holistically than
is possible under the current system.  Frequent  and regular
contacts between Headquarters and  Regional managers will be
essential to the success of the new system.  At  the one-year
anniversary of the effective date  ©f this memorandum we will
review this guidance and redelegatisn to determine whether any
adjustments are needed.

Attachments

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      REPORT OF THE EPA



REGIONAL ENFORCEMENT IMPACTS
         TASK FORCE
           MAY 1994

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                                                   V. Roles and Responsibilities
 should have the lead, with participation from the other, depending on the nature of
 the matter.

      6.    Case Development and Management         :

            a. Genera! Background

      The area of case development and management presents the largest
 challenge for setting out appropriate roles and responsibilities because there are so
 many functions, so much work, and legitimate disagreements over dividing
 responsibilities between the Regions and  Headquarters.  The Task Force spent a
 great deal of its time and effort dealing with roles and responsibilities in this area.

      The Task Force believes that a number of principles should guide the
 Headquarters/Regions relationship in case development and management including:
 Use resources efficiently and effectively;  avoid duplication of effort and second
 guessing; maximize delegations; use a team approach to problem solving based on
 trust, cooperation, and respect; determine roles based on need for unique
 perspectives and  knowledge; provide clear and timely Headquarters guidance that
 allows Regions a specified degree of flexibility and sets out a process for greater
 flexibility based on the facts of a specific case.

      The Task Force's recommended roles and responsibilities between Regions
 and Headquarters reflect the general and normal delineation of roles and
 responsibilities that would take place for  case development and management and
 should not be  viewed as an absolute. Overall, there needs to be a balance
 between empowerment and consistency. Specific case facts relating to
 precedential-concerns, the need to deviate from established policies, or other
 matters  may warrant the need for greater Headquarters involvementT However,
 with the exception of nationally run enforcement programs, the presumption is that
 Regions manage their cases.

      Currently, responsibility for administrative cases is largely delegated to the
 Regions with minimal Headquarters involvement.  Headquarters involvement is
 usually limited to  administrative cases resulting  from national programs that are
 managed entirely  out of Headquarters (e.g.. mobile sources) and administrative
 actions brought under new statutory or regulatory authority, for which the Regions
typically have  submitted their first three such actions for Headquarters approval.
 However, there are also occasional circumstances when, because of the

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                                                   V. Roles and Responsibilities

precedential nature of issues involved in administrative cases, Headquarters
becomes involved.          '                   .

      Under the reorganized enforcement program, the Task Force generally
believes that development, management, and settlement of the significant majority
of administrative cases should continue to be handled by the Regions. However,
for regional cases that (a) rise  to a level of national attention, (b) are multi-regional
cases against a company, economic sector, or ecosystem, or (c)  are part of
national enforcement initiatives, the Task Force generally believes that some  .
degree of Headquarters involvement (which can range from consultation to
concurrence) would be advisable and that in some cases a Headquarters lead
would be appropriate. The Task Force believes these three types of cases are
likely to be a relatively small percentage of all regional administrative cases.
Whether a Region or Headquarters should have the "lead" and the extent of the
other office's participation and/or concurrence in these cases would depend on the
nature and facts of the case.  There should be criteria and guidance to help guide
these decisions. The most important consideration, however, is that the decision
on the ead responsibility for such administrative cases must be made as early in
the process as possible.

      Currently, Regions have been delegated less authority for initiating,
conducting, and settling judicial cases than for administrative cases.  Headquarters
involve -lent is significant.  Under the reorganized enforcement program, the Task
Force generally believes that development, management, and settlement of the
majority of judicial cases should be delegated to Regions. However, the Task
Force believes that cases that  (a) rise to a level of national attention,  (b) are multi-
regional cases against the same company, or (c) are part of national enforcement
initiatives, could be either Regional lead with Headquarters
concurrence/participation or Headquarters lead with Regional
concurrence/participation/ depending on the nature and facts of each case. As
with  administrative cases, there should be criteria and guidance to help guide these
decisions. The most important consideration, however,  is that the decision on the
lead responsibility for such judicial cases must be made as early in the process as
possible.

           b.  Delegations Proposal

      In light of these considerations, the Task Force.recommends that the
Assistant Administrator for OECA consider a number of  delegations in the context
of overall environmental enforcement case management. These delegations are
                                     15

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                                                   V. Roles and Responsibilities
 appropriate in light of the Administrator's commitment to streamlining, ensuring
 national consistency, and implementing the recommendations of the National
 Performance Review. These delegation principles are not intended to substitute for
 the principle that good communication between Headquarters and the Regions is
 essential for consistent and efficient Agency enforcement.
                    ^
      The Task Force suggests consideration of the. following principles:

      (i)  It is appropriate to further delegate civil judicial case initiation,
 management, and settlement authorities to Regional Administrators/Regional
 Counsels.  The Task Force expects that authority for initiation, management, and
 settlement of the majority of cases will be delegated to the Regions, and Regions
 will be held accountable for appropriate exercise of that authority.  These include
 all cases hot falling within the exceptions to be set forth in guidelines, as noted in
 (ii) below.
   f                                                                •
                             •
      Adr .nistrative  enforcement authorities have largely been delegated to
 regional offices. The Task Force expects that the authorities for initiation,
 management, and settlement of these cases will be maintained in the Regions,
 with exceptions limited to those set forth in guidelines, as noted in (ii) below,

      (ii)  Consistent  with the Administrator's .desire that EPA speak with one
 enforcement voice, the Assistant Administrator for OECA should be included in the
 decision-making process at any time that it becomes apparent that a civil judicial or
 administrative case will raise issues of national precedence or national significance.
 Depending upon the level of national precedence or significance, inclusion and
 participation of the Assistant Administrator for OECA will vary from consultation to
 concurrence in regionally-managed cases to actual Headquarters lead in case
 development and management.          '*"*                    ~~

      The Task Force believes that a number of factors should be considered in
                                                                     i
 ascertaining whether  a case is of national significance or nationally-precedential,
 and what level of delegation is therefore appropriate. These factors include the
 dollar value of assessed  penalties, the precedential character of the case or specific
 issues involved, the degree of national importance and  public interest in the case,
 whether a case covers facilities or environmental contamination problems in
 multiple Regions, whether a proposed settlement is within national norms, whether
a case is initiated within the context of a national initiative, and whether a case is
consistent with legislative proposals under consideration.
                                      .,118

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                                                   V. Roles and Responsibilities
      (Hi} Assuring that the Administrator's goals of national consistency and
 streamlining are met will require that the Assistant Administrator for DEC A
 introduce and implement a system of accountability. In accordance with the
 delegations outlined in (b) above, the system must include some contemporaneous
 review of the case initiation, management, and settlement in nationally significant
 cases, as well as -in cases in which national settlement criteria have not been met
 (&&, recovery of economic benefit of non-compliance}. In addition, the Task
 Force recommends institution of systematic post hoe reviews of regional
 enforcement program performance, and consistency with national enforcement
 policies. The Task Force recommends that this review yield sanctions for non
 conformance with national policy, a recognition of superior performance, and
 consideration of differential delegations if appropriate.
            •
            c.  Recommended  Roles and Responsibilities

      Based on the above discussion, a number of functions should fall into the
 category of Headquarters in the lead with .Regional participation. These include
 .national priority setting anc targeting, technical and legal support on national
 issues, clearinghouse/coordination, development of information systems.
 Headquarters providing technical and legal support on Regional cases, providing  .
 technical experts on key cases, DOJ interface, policy and guidance on case
 management, coordination with OGC, communication  and coordination among
 Regions, criminal case development,  and citizen suit matters.

      Regions should have the  lead on regional targeting  and  screening, and
 communicating  and coordinating with Headquarters and States.

      The Regions and Headquarters should share the responsibility for ensuring
 consistency  with "national policy guidance, but the Task Force recognizes that
^Headquarters should have an audit function witff respect to the Regions."'On
 administrative appeals/the Regions should have the lead with Headquarters  '
 concurrence on both the decision to  appeal and the conduct of the case.  For r '
 judicial appeals, Headquarters should have the lead with Regional concurrence.
 The same is  true for contractor listing.  In defensive litigation, in both pre-
 enforcement review and counterclaims, -Headquarters or the Regions should have
 the lead, with the other participating, depending on the case.

      On most administrative cases, the Regions should have the lead in
 developing, managing, litigating, and resolving'the matters.. In several categories
 of administrative cases, Headquarters should be involved, and on rare occasions

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                                                 ATTACHMENT B,
                Guidelines for Identification of
             Nationally significant Cases or Issues


     The following guidelines and examples set forth indicators
of national significance for purposes  of determining the
involvement of the Office of Enforcement and Compliance Assurance
in Regional enforcement cases, and the exercise of any case
settlement authorities delegated to Regional Counsels.  These
guidelines should not, however, be the sole basis for any
determination regarding the presence of nationally significant
issues in an enforcement action; indeed, what is "nationally
significant" will necessarily reflect  the current climate in
which the Agency carries out its mission.  For example, matters
which would not ordinarily be nationally significant may become
such when they relate to statutory reauthorization or otEer
legislative developments.   Regional Counsels are expected to
consult with the appropriate Office of Regulatory Enforcement-
Division Director on any issr^s of national significance which
have been identified, yet do not otherwise fall within any of the
guidelines set forth below.  These guidelines may be periodically
supplemented or revised to reflect additional indicia of national
significance, or to remove any indicia listed below for which
Headquarters attention is no longer required.


Examples of case or issues which raise indicia of national
significance:

1)   Cases or issues that have precedential character

     o    Initial use of new authorities
     o    New use of existing authority                 -i,
     o    Issue of first impression
     o    Unresolved policy, legal or technical issue
     o    Change in national policy or' legal interpretation ,
     o    Applications of new technology

2)   Cases or issues that rise to a level of national  attention
     or significant public interest
                                                   «
     o    Significant citizen concern (especially  significant
          environmental justice issues)
     o    significant political attention
     o    Major state/local government relationship issues
     o    Cases against municipalities
     o    Major environmental or public  health threat
     o    Shut down of a facility

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     o    International implications  (e.g. trade,  import
         violations,  Basel Convention)
     o"   Major inter-agency implications, including federal
         facilities     -  .                .      ....
     o    Settlements involving cutting edge  Supplemental
         Environmental, Projects


3)    Cases  or issues that are potentially affected by legislative
     proposals under consideration, emerging  regulatory
     proposals, or evolving policy changes

     (e.g.  Clean Water Act reauthorization, municipal
incineration)
                                                      <•
        i
4)    Cases  that are multi-Regional
    •    •
     o    Multi-Regional case against one company
     o    Multi-Regional initiative  (e.g. geographic, sector,
         pollutant, regulation)
    V
5)    Cases  or issues that deviate from the national norm

     o    Deviation from established policy
     o    Deviation from established guidance
     o    Deviation from previous legal positions

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                                                       ATTACHMENT C
             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C. 20460
                           JOL 8 W
                                                  '. OFFICE OF ENFORCEMENT
MEMORANDUM
SUBJECT:  Redelegation of the Assistant Administrator for OECA's
          Concurrence Authority in Settlement of Certain Civil
          Judicial and Administrative Enforcement Actions
FROM:    f Steven A. Herman
          Assistant. Administrator

TO:       Assistant Administrators
          Regional Administrators
          Deputy Regional Administrators
          Regional Counsel
          OECA Office "Directors
          OECA Division Directors


     This memorandum constitutes the formal redelegation of
certain settlement concurrence authorities currently reserved for
the Assistant Administrator for Enforcement ana Compliance
Assurance, and serves as an attachment to the July 8,  1994 OECA
memorandum entitled, "Redelegation of Authority and Guidance on
Headquarters Involvement in Regulatory Enforcement Cases."  The
authorities which are hereby  redelegated are listed below, as
well as the procedure, conditions, and limitations that apply
when such redelegated authorities are exercised by either" the
Regional Counsels or the Director of-fche Office of Regulatory
Enforcement of OECA.  The July 8, 1994 memorandum mentioned above
should be consulted for additional clarification on the
procedures to be used to implement these redelegations, as well
as the expectations and responsibilities that  follow these
settlement authorities.

Authorities

     To settle* or exercise the Assistant Administrator's
concurrence in the settlement of civil -judicial and
administrative enforcement actions which involve a bottom-line
penalty of less than. $500, 000 under  the Clean Water'Act,  the Safe
Drinking Water Act, the Clean Air Act, the  Resource Conservation
and Recovery Act, the Federal Insecticide,  Fungicide and
Rodenticide Act, and the Toxic Substances  Control Act.

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     To .settle or exercise the Assistant Administrator's
concurrence in the  settlement of civil  judicial  and
administrative enforcement actions which involve a bottom-line
penalty of $500,000 or above, in actions under the above-
mentioned statutes  for which the Director  for the. Office of
Regulatory Enforcement of OECA determines  that,  in light of the
issues presented, the concurrence of  the Assistant Administrator
is not necessary.

Ta Whom Rsdslecated

     The Regional Counsels.  This authority may  not be
fedelegated.    ,

Process and Limitations

     The Regional Counsels must consult with the Assistant
Administrator for Enforcement and Compliance Assurance  or" his
designee prior to exercising this redelegated authority under the
following circumstances:   (1) a proposed settlement wou'.d not
comport with applicable penalty policies or recover, the full
amount of economic  benefit of noncompliance from a violator not •
in bankruptcy; or  (2) the case raises issues of  national
significance or otherwise rises to a  level of national  attention.

     The Regional Counsels are responsible in the first instance
for identifying such cases and/or issues as they arise, and are
expected to inform  the Director of the  Office of Regulatory
Enforcement of the  Office of Enforcement and Compliance Assurance
as soon as they are identified.  Criteria  .for determining whether
a case or issue are nationally significant,  or have risen to a
level of national attention, are set  forth in the July  8, 1994
OECA memorandum entitled "Redelegation  of  Authority and Guidance
on Headquarters Involvement in Regulatory  Enforcement Cases."
Particular issues of national interest** or  concern may also be
identified by the'Division Directors  in the Office of Regulatory
.Enforcement.  Regional Counsels should  use discretion in
identifying other issues which are nationally significant, yet do
not otherwise fall  within the guidelines or examples contained
therein.

     Following the  appropriate consultation between the Regional
Counsel and the Director of the Office  of  Regulatory Enforcement
of OECA, or the appropriate ORE Division Director, regarding the
above-referenced- issues, OSCA may, at the  Division Director
level, determine that concurrence of  the Assistant Administrator
is appropriate for  the matter at hand,  in  which case concurrence
will"be required.

     This redelegation-does not extend  to  Headquarters-initiated
cases.

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              UNFTED STATES ENVIRONMENTAL PROTECTION AGENCY
                  .       WASHINGTON. D.C. 20460
                             NQV  3 £34
                                                          OPFTCSCF

                                                      COMPLIANCE ASSURANCE
MEMORANDUM
SU3JZCT:   OECA/Regional Procedures for Civil Judicial and
        '  Administrative  Enforcement Case Redelegation
FROM:    '  Ronen,  Director
           Office of Regulatory Enforcement

TO:        Deputy Regional Administrators/ Regions I - X
           Regional Counsel, Regions I - -X
           Regional Program Division Directors,  Regions I - X

I. "   INTRODUCTION

      Attached for your reference and use are the procedures for
implementing Steven Herman's  July 11, 1S94 memorandum on
"Redelegation of Authority and Guidance' on Headquarters
Involvement in Regulatory Enforcement Cases" ('"Redelegations
Memorandum") .   The attached materials also include media-specific
examples  of nationally significant enforcement issues, a key
concept in the redelegations.   We expect that the redelegations
will  result in a substantial  net reduction of single Region cases
in which  OECA's Office of Regulatory Enforcement (ORE) 'will be
significantly involved,  including a substantial decrease in the
number  of settlements requiring OECA./ORZ concurrence.  As, a
result, we will be able  to focus our involvement on. a far smaller
number  of truly nationally significant cases.

      The  attached materials result from extensive discussions
among the various ORE Divisions and regional program divisions
and counsel offices.  We would like to taJce this opportunity to
thank all of the regional personnel who worked so cooperatively
with us over the last two months to develop both the general
cross-program procedures and  the media-specific lists and
criteria  for defining nationally significant issues and cases.
We expect these procedures to evolve based on our mutual
experience with them, and plan to regularly re-examine and revise
them as necessary.

     Our  intent through  these procedures is to lay out a
consistent process for identifying to OECA those
regionally-initiated judicial and administrative cases that

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present issues of national significance.  Specifically, the
procedures require regional staff to work with the ORE Divisions
and reach agreement oh the appropriate level and extent of
ORE/OECA's formal role in enforcement case management.  In
developing these procedures, we have been guided by the following
principles set out in the Redelegations Memorandum:

     (1)  that OECA will focus its efforts and resources on those
          cases where OECA can add value,

     (2)  that OECA's involvement will be reserved for cases and
          issues of national-sign i-
          that for judicial and administrative case's" that seek a
        1  bottom line penalty of less ttian $500,000, the Regional
          Counsel will be delegated the Assistant Administrator's
          authority, to concur on -settlements., undertaken by the
          Regional Administrator (or the Regional Division
          Director, where the Regional Administrator's authority
          has been redelegated), provided that the settlements
          adhere to national policy and do not otherwise raise
          issues of national significance;

     (4)  thg€"pjCA will be flexible~ln determining the
          appropriate—±evei of involvement (e.g., ORE has the
          flexibility to opt out of a case with a bottom, line
          penalty greater than or equal to $500,000 where there
          are no issues of national significance and the case is
          not likely to assume a national profile); and

     (5)  that OECA will be conducting systematic oversight of
          the Regions through Regional evaluations rather than
          focusing exclusively on a case-by-case "real time"
          .review approach to determine the extent to which
          Regions are complying with^national policy and the
          requirements of the redelegations.

     Finally, in keeping with the spirit of the redelegations, we
want to ensure that ORE'S .involvement in specific cases makes
sense,  and that we facilitate effective and efficient resolution
of any issues.  Regional comments have greatly assisted in
designing a cross-program process which provides an opportunity
for ORE involvement where appropriate.  We appreciate the
significant input received from-you and your staff, and hope that
this constructive dialogue will continue.
                          *
II.  SUMMARY CHART

     The first attachment ("Attachment A1*) is a chart that
summarizes the general ORE/Regional procedures for determining
ORE'S formal involvement in individual Region cases.  The chart
provides a quick overview of the general cross-program

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                               - 3  -

 procedures, but -necessaxily leaves out many  important details.
 Accordingly, Attachment B  (below)  must be consulted to  ensure  •
 satisfaction of all requirements.

 III.  GENERAL PROCEDURES

      The next attachment  ("Attachment B"), entitled -"Outline of
 General Procedures for Regional Enforcement  Case Delegation,"
 contains a full description of the general ORE/Regional
 procedures for determining ORE'S formal involvement in  Regional
 civil judicial and administrative  enforcement cases.  These
 procedures were thoroughly vetted  in an ORE/Regional workgroup-
 that  included representatives from all ten Regions, from both the
 Office o'f Regional Counsel and from various  program divisions.1
 In accordance with Steve Herman's  Redelegations Memorandum, the
•procedures emphasize trust,  common sense  and streamlining, while
 at the same time ensuring  that decisions  regarding OPJZ's case
 involvement are adequately documented.

      For example, in judicial cases Regions  will use an already-
 existing section in the referral's litigation report to both
 document and notify ORE of nationally significant issues in the .
 cases.  For administrative cases,  a simple one-page form will
 serve as documentation and notice.  (For  federal facilities
 cases, Regions should forward the  one-page form to the  Director
 of ,OECA's Federal Facilities Enforcement  Office.)  Moreover, for
 judicial and administrative cases  with bottom line penalties
 below $500,000, ORE will require notice only if the cases present
 nationally significant issues.  Of course, because ORE  will not
 otherwise receive formal notice regarding these cases,  the Office
 of Regional Counsel (ORC)  must provide adequate advance notice of
 subsequent significant developments in the litigation  (e.g.,
 trial or settlement) and of significant press or other  public
 attention.._
                                    * lariit                   -
      Regarding administrative cases with  nationally significant
 issues, the procedures offer some  flexibility regarding the
 timing of coordination with ORE by requiring Regions to notify
 ORE of such issues before  filing the administrative complaint  if
 at all possible, but no later than concurrent with filing.
 Again, this accords with the Redelegations Memorandum's emphasis
 on early warning, trust and common sense: we expect that in most
 situations pre-filing notice will  be achievable, but where not,
     1  With regard  to the procedures, I want to thank Tom Olivier
of Region I, Wilkie Sawyer- of Region II, John Ruggero and Mary Co«
of Region III,  Nancy Tommelle.o and Truly Bracken of Region IV, Jo«
Boyle of  Region  V,  Pam  Phillips of  Region VI, chuck  Figur fron
Region VIII, Ann Nutt of Region IX  and Meg. Silver of  Region X.
These  Regional  representatives  were  critical in  developing  a
workable process for  implementing the redelegations.

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                              - 4 -

concurrent notice will be sufficient.,  (There may be very rare
occasions where even concurrent notice is not achievable; in such
circumstances, notice as close as possible to concurrent with
filing will be adequate.)

     In almost all circumstances, the five ORE Divisions will use
these general cross-program procedures in order to simplify
implementation as much as possible.  In a few narrow
circumstances, media-specific procedures have been established
(see Attachment C below).  These variations are noted in the
attached media-specific guidances, which also identify
appropriate individuals to contact within each Division.

     Moreover, to further streamline these procedures, the Air
Enforcement Division is experimenting with "categoric opt outs"
for certain classes of long-established, familiar cases such as
Clean Air Act Asbestos NESHAP demolition/renovation actions.
These cases will be presumed not to be nationally significant
even if their bottom line penalties are above $500,000.
Accordingly, Regions will not be required to seek ORE concurrence
unless the cases present some other, separate nationally
significant issue.  (This approach is described in detail in the
cross-program procedures.-)  As with other cases for which OECA is
receiving no formal notice, ORC must, provide adequate advance
notice through other avenues of communication, including the
weekly Regional Counsel reports to the.Assistant Administrator,
of major litigation milestones (e.g., settlement, trial) and of
significant press or other public attention.  Based on our
experience with these categoric opt outs, we may expand them to
cover other selected categories of cases in Air or other media.

IV.  MEDIA-SPECIFIC GUIDANCE AND NATIONALLY SIGNIFICANT
     ISSUES LISTS

     Also attached, are memoranda from, each of ORE'S Divisions
that outline media-specific contacts and procedures' where   .
appropriate, as well as media-specific examples of nationally
significant issues ("Attachment C").  Please note that the  ,
Redelegations Memorandum itself contains an attachment with
general guidelines for identifying nationally significant issues
("Attachment D") .  The media-specific examples are intended to b«
used together with the general guidelines; some of the lists of
examples include a listing of the general guidelines for
convenience.  The media-specific .examples will be updated
periodically to remove or add issues as appropriate.

V.   MULTI-MEDIA CASES

     In the interests of streamlining, OECA is seeking to
establish a system whereby, absent extenuating circumstances,  ^
Regions would need to coordinate with a- single office or division
that would serve as the lead on a particular case.  For cases

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                               _ 5 —

 brought under  multiple statutes (except those brought against
 federal facilities), the Regions should contact ORE'S Multi-Media
 Enforcement Division, which will coordinate with other OECA
 offices and divisions as appropriate.

 VI.   FEDERAL FACILITIES CASES                   '-

      As listed in Attachment B to the  Redelegations Memorandum,
 federal facilities matters raise indicia of national
 significance.   OECA's contact in federal facilities cases is
 through the Federal Facilities Enforcement Office (FFEO) rather
 than the Office of Regulatory Enforcement.  Otherwise, procedures
 in federal  facilities cases match those in other nationally
 significant cases.  Thus, Regional Counsels should consult with
 FFEO regarding federal facilities enforcement cases.  Where the
 Region is assessing a bottom line penalty of less than $500,000
 the Director of FFEO or a Division Director level designee may
 opt in for  purposes of concurrence. Where the bottom line
 penalty is  $500,000 or more, the Director of FFEO, at the Office
 Director level,  may opt put of the case for purposes of
 concurrence.   In federal facility cases that present issues of
 national significance in other program areas, FFEO will take the
 lead and will  work with other OECA offices and divisions, as
 appropriate, to address the .issues.

      The above-described process does  not alter the procedures in
' the  "Guidance  on Coordination of Federal Facility Enforcement
 Actions with the Office of Enforcement11 dated October 20, 1992,
 which continue as before, and provide  for notice to the Director
 of FFEO as  early a possible before certain actions are taken or
 announced against either federal agencies or their contractor-
 operators .

 VII.  CURRENT ENFORCEMENT DOCKETS
                                    * «*•*-*                   •
      Because the Redelegations Memorandum applies to all""
 enforcement cases, the attached procedures and guidance apply to
 both  pending and new cases as of November 1, 1994.  Accordingly,
 for newly-initiated cases, we ask .that you implement the
 procedures  immediately.  For all existing judicial and
 administrative cases, Regions should. focus their initial effort*
 on evaluating  cases with"near-term, action-forcing events, such
 as hearings, trials, filing of dispositive pleadings or
 settlements, that will occur within the next 60 days.  For other
 existing judicial cases, the ORE Divisions will be working with

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                              - 6 -

the Regions to review the judicial dockets and identify those
cases in which ORE will continue to be involved; this should be
completed no later than January 3, 1995.2

     With regard to  all existing administrative cases that do not
have near-term, action-forcing events, we ask that by January 3,
1995, the Regions evaluate each case, complete the "Standard Form
to Specify Office of Regulatory Enforcement Involvement in
Cases"3,  and submit the completed form to  the appropriate  ORE
Division if required by the cross-media procedures.  Because ORE
may receive a very large number of forms all at once, each of
which will require discussions between ORE and Regional staff, we
will process these forms within 30 days rather than 10 days
(sooner if possible).- Future administrative case forms will be
processed within 10  days in accordance with the cross-program
procedures.

     In closing, we  want to emphasize that each ORE Division will
work closely with their colleagues in the Regions to help ensure
that implementation  of the attached procedures is as smooth as
possible.  We want to facilitate issuance of strong enforcement
cases within each Region — that's our bottom line.  .We intend to
approach the implementation of the procedures in that spirit.
Again, thank .you for your assistance and we look forward to
working with you on  this.

Attachments

cc:  Steven Herman
     Scott Fulton
     Michael Stahl
     OECA Office Directors
     John Cruden, DOJ
     Bruce Gelber, DOJ
     Joel Gross, DOJ              .
     2  In some programs  (e.g., Air and Water) , much of the work to
evaluate the existing judicial docket has already been done.  For
such programs,  we anticipate that the  reviews will be  completed
well before January  3, 1995c

     3  See the cross-prograi  ,., ; sedures (Attachment C) at page 8.

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  Judicial
   Cases
 $500,000
 and over
                                                        or Adiniiiisirnliyc Cbiliplnint Singe;
O- When referral it nude. Region will notify OECA of^SIa In
   referral'e liligilion report
O  Separate Mellon In III report will Identify, deicribe NSIi
o  30 diyi for ORB review
o  Appropriate. ORB Dlvlilon *nd Region will dlicui*. agree on
   ORB invnlvemenl
o  Memo front ORB Division Director (DD) to Region*!
   Couniel (RC) will memorialize agreement
O  ORB DD cm opt out of cue entirely where appropriate
  '>  No Nalionnlly Significant JSSHW »,    '
f * '*>.   %  •>    ,\       *•.   flf     A-k <    *    x
••••••••••^™^•*^^*i
 o  When referral la made, Region will notify OEC4 of no
    NSIa In referral'* litigation report             1
 O  Separate lection in lit report will atale that there are no
    NSIa, and recommend thai OECA opt out
 O  30 dayi for ORB review
 o  If ORB agreea that there are no NSIi, ORB will opl out;
    If NSIa, ORB and Region will diacuaa, agree on ORB
    Involvement
 o  Memo from ORB DD lo RC will memorialize
    agreement
                                                                                                                            Post-Filing Singes
                                                                                                                              \'/Vv ^ Newly Emerging. Issues
                                                                                                                              '
O  Region will notify OECA of new NSIa aa toon aa Region
   idenllfiea them
o  Informal notice (e.g., phone caili)
O  Expedited ORB review, with finl priority on rtiponie lo
   NSI rattier than on memorializing agreement
O  ORB and Region will diacuaa, agree on ORB Involvement
O  Memo from ORB DD lo RC will memorialize agreement,
   generally within 30 dayi
O  ORB DD can decide when appropriate that ORB will
   have no Involvement
'" Admin
   Cases
 $500,000
 and over
o. Preferably before filing admlniilralive complaint, but no later
   than concurrent with filing, Region will notify OECA of NSI
o  One page form algned by RC or deiignee, Identifying NSI
•   and propoaing level of ORB Involvement in caae
O  10 daya for ORB review
o  ORB and Region will diicun, agree on ORB involvement
O  ORB DD or deiignee will counlenign ind return form with
   any agreed-upon amendment*; form will be kepi in Regional
   lilea
O  ORB DD can opt out of caie entirely where appropriate
 O  Preferably before filing admlniilralive complaint, bul no
    later than concurrent with filing, Region will notify
    OECA that there are no NSIa               •)
 O  One page form llgned by RC, Haling that there are no
    NSIa in caae and recommending thai ORB opl out
 O  10 dayi for ORB review
 O  If ORB agreea that there are no NSIi, ORB will opl out;
    If NSIi, ORB and Region will dlacuaa, agree on ORB
   .Involvement                                   _  .
 9  ORB DD will counlerilgn and return form with any
    agreed-upon amendment*; form will be kepi In Regional
    file.
o  Region will notify OECA of new NSIi aa toon aa Region
   Idenllfiei them
O  One page form ilgned by RC or deiignee, identifying
   NSI and propoaing level of ORB Involvement In caae
o  10 daya for ORB review
O  ORB and Region will dlacun, agree on ORB Involvement
O  ORB DD or deiignee will countersign and return form
   with any agreed-upon amendnienii; form will be kepi In
   Regional filei
O  ORB DD can decide when appropriate thtt ORD will
   have no Involvement
  Judicial
 .  Cases   •
   under
 $500,000
O  When referral It made, Region will notify OECA of NSIi In
   referral'! litigation report; Region will tend OECA the lit
   report only If the cate conlalni NSIi
o. Separate Mellon In lit report will identify, deicribe NSIi
o  30 daya for ORB review
o  ORB and Region will diicun, agree on ORB Involvement
o  Memo from ORB DD lo RC will memorialize agreement
o  ORB DD can opt out of caw entirely where  appropriate
 O  When referral la made, Region will make and document
   ' lie determination that there are no NSIa in the caae, but •
    no requirement to Inform OECA by providing lit report
 O  Separate aecllon In lit report will itale lint there are no
    NSIi In cue
 o  Decauie OECA it receiving no formal notice oflheie
    caaea, Reglona muit provide adequate advance nolle*
    through other avenue* of communication, auch a*
    weekly RC report!, If ciiei are likely lo attract
   . ilgnlficinl pren or other public attention
 O  ORB Divlilon* will review determination* during
    Regional audita
O  Region will notify OECA of new NSIi aa aoon aa Region
   Idenllfiea them
O  Informal notice (e.g., phone ealli)
o  Expedited ORB review, with finl priority on reaponie lo
   NSI rather than on memorializing agreement
o  ORB and Region will ditcuii, agree on ORB Involvement
O  Memo from ORB DD or deiignee to RC will
   memorialize- agreement, generally within 30 dayi
o  ORB DD can decide where appropriate dial ORB will
   have no Involvement
   Admin
 Cam under
  $500,000
O  Same procedurea ai for admlnlilnllve caiei of $500,000 or
   over
 O  Preferably before filing admin complaint, bul no later
    than concurrent with filing, Region will mike/document
    determination of no NSIa, bul no requirement to notify
    OBCA by providing one page form
 o  One page form ilgned by RC or deiignee, elating no
    NSIi In cue; form will be kept In Regional filei
 o  ORB Dlvliloni will review delermlnaliona during
    Regional amlili
O  Same aa for admlniilralive caaea of $500,000 or over,
   except thai ORB DD or deiignee cm decide when
   appropriate thai ORB will have no Involvement

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                OUTLINE OF GENERAL PROCEDURES FOR
              RESIOKAL ENFORCEMENT CASE REDELEGATIOK

                         November 1,  1994


I.  JUDICIAL CASES W/ BOTTOM LINE PENALTY "OF S500.000 OR OVER

 A.  Referral Stage                 .    .

     .1.  Region identifies case with nationally significant
     issues.1                      .                        .
          *

     Timing:  At same time Region sends referral (i.e., a
     direct/indirect referral, pre-referral negotiation package,
     or consent decree enforcement package) to Department of
   "  Justice- (DOJ), Region will send referral to Office of
     Enforcement and Compliance Assurance  (OECA) as notification
     of nationally significant issues in case.

   -  Method:  Office of Regional Counsel (ORC) will describe and
     discuss nationally significant issues in referral's
     litigation report, 'in a separate section that already exists
     for this purpose.  Region will provide OECA will full •
    ' referral package, including attachments.

     Decision on Extent of Involvement:  Appropriate .Office of
     Regulatory Enforcement  (ORE) Division within OECA will have
     30 days after receipt of notice for'ORE review.  Within this
     timeframe, ORE staff or branch chiefs, as appropriate, will
     discuss case with Regional counterparts and seek agreement
     on the extent and duration of OECA involvement, e.g.,
     concurrence or consultation, to be followed by letter from
     ORE Division Director to Regional Counsel  (RC) memorializing
     agre"ement.2  ORE Division Director can also opt out of case
     entirely where appropriate.  ~£f Division Directdr'and. RC
     cannot agree, elevation to ORE Office Director.
     1  "Case with nationally significant issues" includes all
nationally significant cases or issues as defined inthe
guidelines attached to Steve Herman's July  11,  1994  Redelegation*
Memorandum and  in the various media-specific  issues  lists
prepared by the Office of•Regulatory Enforcement.

     2  "OECA involvement" refers only to OECA's  formal role in
enforcement case  management, not-to informal  ORE/Regional
communications  or activities of other OECA  offices (e.g., Office
of Compliance).

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                              - 2 -
                                                      *
     2.  No nationally significant- issues.      •  • .
                   \
     Timing:  At same tine Region sends referral to DOJ, Region
     sends referral to OECA as notification that there are no
     nationally significant issues in case.
                                     •          .             *
     Method:  In already-existing section of litigation report,
     ORC will state that there are no nationally significant
     issues in case,  and recommend that OECA. opt out.  Regions
     "will provide OECA with data sheet and litigation report, but
     no referral attachments.  OECA will request attachments as
    ' necessary.

     Reyiew of determination:  Appropriate ORE Division will have
     30 days after receipt of notice to review the ORC
     recommendation and decide whether OECA will opt out.  If ORE
     agrees, the ORE Division Director will inform the RC via a
     form letter and' opt out of the case.3 if ORE id&ntifies
     nationally significant issues,, the ORE staff or branch
     chiefs, as appropriate, will discuss them with Regional
     counterparts and seek agreement on the extent and duration
     of OECA involvement, to be followed by letter from the ORE
     'Division Director to RC memorializing agreement.  .If
     Division Director and RC cannot agree, elevation to ORE
     Office Director.    '

     3.  No nationally significant .issue, and a categoric opt out
     case (for example/ Clean Air Act Asbestos NESEAP
     demolition/renovation cases).         •

     Timing:  At same -time Region sends referral to DOJ, Region
     will make and document determination that the- case contains
     no. nationally significant issues and that it falls within a
     pre-approved category of opt outs, but no requirement to
     send referral -to OECA as notification.
                                   '«*»<**        *          -w ^
     Method:  In already-existing section of litigation report,
     ORC will make and document determination that the case
     contains no nationally significant issues and that it falls
     within a pre-approved category of opt outs.  Regions not
     required to provide litigation report or other portions of
     referral.  Because OECA is receiving no formal notice of
     these cases, ORC must provide adequate advance notice
     3  Since after this .point ORE will no longer be formally
involved  in the case unless, a nationally significant  issue  arises
later in  the proceedings, ORC will need to provide OECA with as
early notice as possible regarding subsequent significant
developments in the litigation (e.g., trial or settlement)  and
significant press or other public attention.  This "applies  to all
instances where ORE opts out of a case.

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                             - 3 -
•         *                               -                     '
    through other avenues of communication, including the weekly
    RC reports to the Assistant Administrator, of major
  -  litigation milestones (e.g., settlement, trial) and
    significant press or other public attention..

    Review of Determination: • ORE will review categoric opt out
    determinations during Regional audits.

B.  Post-Referral Stages (in cases where OECA originally
    opted out)	

    Note:  The redelegation itself states that the Regional
    Counsel are responsible for identifying nationally
    significant issues "as they arise", and" for informing OECA
    "as soon as they are identified."  Accordingly, even where
    OECA has originally opted but of a case, there is a
    continuing obligation for the RCs to inform OECA of any
    nationally significant issues that emerge during the course
    of litigation.  This approach accords with the Redelegations
   . Memorandum's overall insistence on flexibility and common
    sense.

    Timing: As soon as issues identified.

    Method:  As informally as possible, with emphasis on trust,
    common sense, and providing the earliest possible warning of
    new issues, rather than .on written notice.  For example, a
    phonecall from ORC to ORE branch chief could serve as
    notice.

    Decision on Extent of Involvement:  ORE staff, or branch
    chiefs, as appropriate, will discuss case with Regional_
    counterparts and seek agreement on the extent and duration
    of OECA involvement, e.g., concurrence or consultation.
    Agreement will be memorialized by letter from ORE Division
    Director to RC as soon as possiBle, generally within 30 days
    after notice; however, first priority will be quick response
    to new substantive issue.  ORE Division Director can al,so
    decide where appropriate that ORE will have no involvement.
    If Division Director and RC cannot agree on approach,
    elevation to ORE Office Director.

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                              -.4 -

 II. ADMINISTRATIVE CASES WITH PROPOSED'OR BOTTOH LINE PENALTY
    O? 5500,000 OR OVER4	

     Note:  Only Toxics and RCRA cases presently fall into this '
     category.                    •        ..-

 A.  Filing Stage

     1.  Region identifies nationally significant issues.

     Timing:  As soon as Region becomes aware of issue.  The
     preference is that the issue be raised prior to filing the
     complaint, but no later than concurrent with filing.5
       '
     Method:  One page form signed by the Regional Counsel or
     designee identifying issues and proposing level of ORE
     involvement, sent to appropriate ORE Division.  Region will
     also provide proposed or-filed complaint, decision"memo
     and/or other existing information to parallel information
     provided in judicial referral.
                                                   *

     Decision on Extent of Involvement:  Within 10 days of
     receipt of notice, ORE staff or branch chiefs, as
     appropriate, will discuss case with Regional counterparts
     and seek agreement on the extent and duration of OECA
     involvement, e.g., concurrence or consultation, to be
     followed by ORE Division Director or designee, as
     appropriate, countersigning and returning one page form
   .  rather than sending separate letter.  (If after discussions
     ORE decides to opt out, the ORE Division Director must
     countersign.)  Note that the administrative complaint can b«
     filed before ORE countersigns form.  Countersigned form will
     be kept in Regional files.  Disputes would be elevated to
     ORE Office Director.

     2.  No Nationally Significant Issues     .        ~~

     Timing:  Same timing as above.  Region will notify ORE,that
     no such issues appear in case.
     .*  If the Region has proposed a penalty in the
administrative complaint without calculating  a  separate bottom
line penalty, the proposed penalty should be  used.  If a separate
bottom line penalty, has been calculated, it should  be used
instead.  See Redelegations Memorandum, p.3.

     *  For a few small classes of RCRA cases specified  in the
RCRA redelegations  approach, ORE involvement  must occur before
filing to comport with existing RCRA delegations or guidance.

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                              - 5 -

     Method:  Same form as above, but will state that there are
     no nationally significant issues and recommend that ORE opt
     out of the case.  Regional Counsel, not designee, must sign
     form because ORC is recommending that ORE opt out.

     Decision on Extent of Involvement:  Same as :abpve, except
     that ORE Division Director, not designee, must countersign
     form if ORE opts out.  This parallels the procedure for
     opting'out in judicial cases over $500,000 (I. A. 2. above).)

 B..  Post-Filing Stages (in cases where OECA originally
     opted out   	

     Timing:  As soon as issues identified.

     Method:  One page form signed by the Regional Counsel or
     designee, sent to appropriate ORE Division.  (Note that
     using this form, the same as for other stages of the
     administrative program, will eliminate the need for a
     separate return letter from ORE to ORC.)

     Decision on Extent of Involvement:   Within 10 days of
     receipt, of notice, ORE staff, or branch chiefs, as
     appropriate, will discuss case with Regional counterparts
     and seek agreement on the extent and duration of OECA
     involvement, e.g., concurrence or consultation, to be
     followed by ORE Division Director or designee, as
     appropriate, countersigning and returning one page form.
     (If ORE decides to have no involvement, the ORE Division
     Director must countersign.)  Countersigned form will be kept
     in Regional files.  Disputes would be elevated to ORE Office
     Director.
                                         *   *

III. JUDICIAL CASES WITH BOTTOM LIKE PEHALTY TOPER $500, OOP

     Note:  Both the Redelegations Memorandum and the
     redelegation itself make clear that it is the Regional {
     Counsel's responsibility to identify nationally significant
     issues in all single Region judicial and administrative
     enforcement cases below $500,000.  "The Regional Counsel
     will, in the first instance and in keeping with this
     guidance, make and document the determination whether such a
     matter raises an issue of national significance."
     Redelegations Memorandum, p.3.   "The Regional Counsel are
     .responsible in the first instance for identifying such cases
     and/or issues as they arise ....."  Redelegation, p.2.

     The proposed implementation plan for these cases  (described
     in detail below) would require ORC to formally notify ORE
     only if the case contained a nationally significant issue.
     For a case with no such issues, RC would still need to make,

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                             - 6 -

    document and file.its determination,  but would not have to
    notify ORE of the case.  ' ORE and the Regions would continue
    to develop informal avenues of communication.

A.  Referral Stage

    l. .Region identifies nationally significant issues.

    Timing:  At same time Region sends referral-to DOJ, Region
    will send referral to OECA as notification/  but only  if
    there are nationally significant issues in the case.

    Method:  Office of Regional Counsel (ORC) will describe and
    discuss nationally significant issues in referral's
  .  litigation report,  in a  separate section that already exists
    for- this purpose.  Region will provide OECA  will full
    referral package, including attachments.
                                                       »—•.
    Decision on Extent of Involvement:  Same as  for judicial
    cases over $500,00.0.   Within 30 days of receipt of notice,
    ORE staff or branch chiefs, as appropriate,  will discuss
    case with Regional counterparts and seek agreement on the
    extent and duration of OECA involvement, e.g., concurrence
    or consultation, -to be followed'by letter from ORE Division
    Director to RC memorializing agreement.  ORE Division
    Director can also opt out of case entirely where
    appropriate.  If Division Director and RC cannot agree,
    elevation to ORE Office  Director.

    2.  No nationally significant issues. •

    Timing;  At same time Region sends referral  to DOJ, Region
    will make and document determination that the case contains
    no nationally significant issues, but no requirement  to send
    referral to OECA as'notification.

    Method:  In already-existing section of litigation .report,
    ORC will make and document determination that the case t
    contains no nationally significant issues.  Region not '
    required to provide litigation report or other portions of
    referral.  Because OECA  is receiving no formal notice of
    these cases, ORC must provide adequate advance notice
    through other avenues of communication, including the weekly
    RC reports to the Assistant Administrator, of major
    litigation milestones (e.g., settlement, trial)' and
    significant press or other public attention.
                          »
    Review of determination:  ORE Divisions will review  .
    determinations during Regional audits.
                               350

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                              - 7 -

 B.  Post-Filing Stages  (cases v7 no prior OECA involvement^

     Timing/ method .and decision on extent of involvement will be
     same as for judicial cases above $500,000 (I.E. above),
     except that letters memorializing 'agreements could be from
     ORE to ORC Branch Chief rather than from ORE Division
     Director to RC:  ORE DD must still sign letter if ORE
     decides to have no involvement sin case.

V.  ADMINISTRATIVE CASES WITH PROPOSED OR BOTTOM LIKE PENALTY
    OP UNDER S500.000	   '   '	


 A.'  Filing Stage

     1.' Region identifies nationally significant issues.

     Timing/ method and  decision on extent of involvement same as
     for administrative  cases over $500,000  (II.A.I. above).

     2.  No nationally significant issues.

     Timing:  In same timeframe as for administrative cases over
     $500,000, ORC will  use one page form to make and document
     determination that  there are no such issues in case, but no
     requirement to provide OECA with form as notification.

     Method: ' Same one page form as above, but will state that
     there are no nationally significant issues.  Regional
     Counsel or designee will sign form, which will be kept in
     Regional files.  Because OECA is receiving no formal notice
     of these cases, ORC must provide adequate, advance notice
     through other avenues of communication, including the weekly
     RC reports to the Assistant Administrator, of major
     litigation milestones' (e.g., settlement, trial) and_
     significant press or other public attention.

     Review of Determination.  ORE Divisions will review
   "  determinations during Regional audits.  .

 B.  Pest-Filing Stages  feases v/ no prior OECA involvement!

     -Timing, method/ and decision on extent  of. involvement  could
     be same as for administrative  cases over $500,000  (II.B.
     above) , except that ORE DD or  designee  can countersign form
     if ORE decides to have  no involvement.

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                                     - 8 -
    * * * PRIVILEGED/CONIIDENTIAL/DO NOT RELEASE UNDER FOIA * * *

        Standard Form to Specify Office of Regulatory Enforcement
                             Involvement in Cases.        :
 Case name:
Location of facility:  City	, State	, 'Region	

Forum (check one):         -             '                                    •

       AU (or other presiding officer)	  EAB	
       District or Circuit Court	 (specify District/Circuit:	_. )

Status of case (check all that apply):

       Profiling, in development 	    Dispositive pleadings imminent  	
       Filed' and pending       	     Trial or hearing imminent      	
       Filed and stayed         	     Settlement negotiations ongoing  	
       Filed and active         	

Primary Violations (narrative or listing of sections):


Nationally significant issue(s):
                                                               •


Regional legal and program staff contacts (names, phone numbers, FAX numbers):


Nature of Office of Regulatory Enforcement involvement/assistance proposed by Region:
Signature:
            Appropriate Regional. Manager           Date Signed
                                  V


Concur
            Appropriate ORE Manager              Date Signed

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                                                            •v
MEMORANDUM
                                  9 I9SO


                                                        OFrCSOF
 SUBJECT:   Documenting Penalty Calculations and Justifications  in
           EPA Enf orcementAci
 FROM:      James M.
           Assistant Administrator

.TO:     •   Addressees          .

     This memorandum institutes a uniform system for documenting
 penalty calculations and explaining how they are consistent with
 the  applicable penalty policy in all EPA enforcement actions.  It
 expands on the September 14, 1987 Guidance on Processing of
 Consent Decrees (GM-64) and requirements .in several media
 specific penalty policies.  The system will allow regional and OE
 management 'to assure that EPA settlement agreements comply with
 applicable penalty policies, and will provide documentation for
 our  actions for -purposes of oversight review.  The memorandum
 sets out the information regarding the penalty which must be
 discussed at each stage of litigation.  The exact format of the
 .discussion is left to the discretion of each program.  All
 discussions of the agency's settlement position regarding
 penalties are, of course, strictly enforcement confidential
 workproduct, should be clearly labeled as such and should not be
 released. .

     • Effective immediately, every settlement package transmitted
 from the Regional Administrator or^Regional Counsel to
 Headquarters for concurrence must include . a written "Penalty
 Justification-"   This should include an explanation of how the
 penalty, including the economic benefit and gravity component,
 was  calculated.  The Region should then discuss in detail the
 justification for any mitigation of either component.  In
 particular, -reference should be made to the" factor or language in
 the  penalty policy that is relied upon to justify the mitigation,
 and  a  discussion must be included .detailing why mitigation is
 warranted in the particular case. • For administrative cases, a
 Penalty Justification should be prepared for circulation within
 the  Office of Regional Counsel with a final consent agreement or
 order.   It may not be circulated to the agency official who signs
 the  final order as the presiding agency official, usually the
 Regional Administrator, because it could constitute *y partc
 communication ' which would have to be shared with defendants under
 40 C.F.R. Part 22.
                                            z3 2 5 £93
                                                         ftwwte an «»e»c*« '

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                               - 2 -
      When the  factor relied upon to justify mitigation is
 litigation risJc,  the Region should state the probable outcome of
 litigation along- with legal and factual  analysis which supports
 its  conclusion.   For judicial cases,  this should be done  in
 consultation with the Department of Justice.   Specific discussion
 of the  evidentiary problems,  adverse  legal precedent,  or  other
 litigation problems in-the case should be included.   If the
 required  discussion of the penalty is contained  in the litigation
 report  or subsequent correspondence between the  ORC and OE,  the
 settlement package from the Region may reference this discussion
 along with an  attachment of the previous documentation.

      A  similar discussion of. Penalty  Justification should also be
 included  in every settlement package  transmitted from the
 Associate Enforcement Counsels for the signature of the Assistant
 Administrator.  The Headquarters staff may,  however,  reference
 the  discussion in the regional memorandum when it is  sufficient.
 Seriously deficient Penalty Justifications will  be returned  to
 the  Region to  allow a proper analysis to be prepared  before  the
 Assistant Administrator for Enforcement  reviews  a consent decrtt
 for  signature.   '       "

      In addition,  each Office of Regional Counsel case file  and
 all  OE  files in cases in which OE is  involved should  contain at
 all  times during  the course of an enforcement action
 documentation  of  the current bottom line agreed  upon  by the
 litigation teas.   For civil administrative cases, this will  begin
 with the  filing of the administrative complaint.   For civil
 judicial  cases, this vill begin with  the litigation report,  which
 should  include the penalty proposed by the Region initially.  Tn«
 litigation report  should clearly indicate hov the gravity and
 economic  benefit components were calculated under the applicable
 penalty policy and discus* in detail  any mitigation that  is
 proposed,   significant uncertainties  which could result in
 further mitigation should also be identified.

      The  OB attorney assigned to the  case vill then determine if
OB concurs vith the. penalty proposed  by  the Region in reviewing
the  referral.  O* concurrence vill be documented in writing,
placed!in the  OE case file and provided  to the Region. If OB
does n%C .concur vith the penalty proposed by the Region in the
referral the  assigned OS attorney vill  prepare  a memorandum to
the  Region stating vith specificity the  basis (es) of the
nonconcurrenc*..

      Once the  enforcement action is initiated or pre-filing
negotiations begin, the litigation teas  should document any
agreed  upon changes to the bottom line penalty based upon new
information'or circumstances which arise during  the course of th«
enforcement action.  This documentation  must, at a minimum,

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                               -  3  -


'include a memorandum to the  file recording how both the gravity
and economic benefit components  were calculated, the basis in the
applicable penalty policy and  in the specific facts of the case
for any mitigation, and the  changed circumstances or new
information which justify modification of the bottom line.  This
will be especially beneficial  in cases where there" are changes in
the litigation team over time.  It will enable new attorneys
assigned to the case ta know what  the current bottom line penalty
is and how that has been determined over the course of the case.
                     *           * -           •

     These requirements will serve several functions.  It will
ensure that management has adequate information to judge
consistency with the applicable  penalty policies in specific
cases and in the various enf grcement programs. overall.  It also
will ensure that every regional  case file and all OE files in  .
cases in which OE is .involved  have written documentation of how
the penalty obtained was calculated and justified in terms of the
penalty policy.  This is essential for reviews or audits "of our
settlements.                                    •
                                •                       *
Addressees:

     Regional Administrators
     Regions I-X

     Deputy Regional Administrators
     Regions I-X

     Regional Counsels
     Regions I-X

     E. Donald Elliott
     General Counsel

     Headquarters Compliance . Program.Division  Directors^ ^

     Associate Enforcement Counsels
                                                            r
     Richard B. Stewart
     Assistant Attorney General      .     f  m
     Environment and Natural Resources  Division
     U.S. Department of Justice

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 From  In  the Matter of Celltech Media.  Inc.. aka Health Care
 Products.  Inc..Docket Nos.  FIFRA  95-H-04, FIFRA 93-H-02F, and
 I.F.& R. VIII-90-279C,  Complainant's Prehearing Exchange  (Feb.
 26, 1996)
 IV.PENALTIES

      Although Complainant  will present at hearing factual

 evidence  relevant to the determination of a proper penalty for

 the  violations charged,  Complainant does not intend to have a

 witness testify to the appropriateness of the proposed penalty

 unless directed to do so by  the Presiding Officer.  The

 appropriateness of the penalty is more an issue of statutory

 interpretation than of fact.  Interpretation of statutory

 language  is an issue of law  and policy, not an issue of fact.

 See  generally Stissi v.  Interstate and Ocean Transport. 765 F.2d

 370,  374  (2d  Cir.  1985), and International Society for Krishna

 Consciousness v.  Rochford. 425 F.Supp. 734, 739 (N.D. 111. 1977).

 It is improper for a witness to present "evidence" on legal

 issues in an  evidentiary hearing.  See Adalman v. Baker, Watts &

 Co.  807 F.2d  359,  368 (4th Cir. 1986); Marx & Co.. Inc. v.

 Diners' Club.  Inc..  550  F.2d 505, 510  (2d Cir. 1977)  (_expert

 testimony on  law  is excluded because _the tribunal does not need

 the witnesses'  judgment...the judge (or the jury as instructed by

 the judge) can determine equally well...._ The special legal

knowledge of  the  judge makes the witness1 testimony

superfluous._);  McCormick on Evidence. § 12 at 26-27  (Such

testimony "amounts  to no more than an expression of the

 [witness1] general  belief  as to how the case should be
                                366
000164

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decided.").  Any  challenges to Complainant_s interpretation and
application  of  the statutory factors  in penalty assessment should
be made through legal and policy arguments rather than through
argument with a fact witness.   Arguments as to the merits of the
Agency's assumptions and statutory interpretations are properly
presented  in briefs and oral argument.
     Complainant_s argument for the appropriateness of the
proposed penalties in these consolidated cases is presented
below.

A.   The Statutory Factors
     FIFRA strictly regulates  the sale, distribution and use of
the one category  of toxic chemicals whose specific, intended
purpose is to cause harm to living things.  Section 14(a)(1)  of
FIFRA, 7 U.S.C. § 1361,  states that a registrant, commercial
applicator,  wholesaler,  dealer,  or distributor of pesticides may
be assessed  a civil penalty of up to  $5,000 for each violation of
FIFRA.  In determining the amount of the penalty, FIFRA requires
that the EPA consider the appropriateness of the penalty to the
size of the  business of the person charged, the effect of the
penalty on the  person's ability to continue in business,  and the
gravity of the  violation.  (FIFRA section 14(a)(4), 7 U.S.C. §
136l(a)(4))

!•   Gravity
     FIFRA does not  define _gravity of the violation_, but it is
reasonable and  appropriate to  interpret this expression as
                                 3,7                          000165

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 encompassing the concepts of  risk, harm, and culpability.  Risk



 is  commonly defined as the combination of the probability of an



 adverse outcome occurring and the severity of that adverse



 outcome.   The possible violations of FIFRA may be roughly ranked



 in  terms of their inherent risk, so that, for example, a misuse



 violation would generally pose a greater risk than would a minor



 error on an annual production volume report.  The former example



 would directly increase risk  to health and the environment as it



 pertains to the actual use of a pesticide in a manner that EPA



 has in essence prohibited,  while in the latter example the only



 direct consequence of the violation is that EPA does not have the



 complete and accurate information it needs to consider the risks



 posed by the pesticide or to  monitor compliance with FIFRA.  It



 would not be reasonable to construe _gravity of the violation_ in



 a manner that did not give considerable weight to this sort of



 ranking of the risks resulting from violations.



      All  violations pose some increase in risk to health or the



 environment,  but not all violations result in actual harm.



 Although  the regulatory provisions of FIFRA generally direct the



 Administrator to act in such  a manner as to minimize



 _unreasonable adverse effects_ that expression is defined at



 FIFRA section 2(bb)  to mean unreasonable risk.  It is appropriate



 to give greater  weight to risk than to harm in assessing



penalties  for violations of FIFRA, in part because whether such



harms  occur  at all often depends on factors wholly outside the



violator_s control.   For example, if two persons commit exactly



the same violation,  one may result in greater harm than the  other






                                                               000

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for no reason other  than  the direction the wind blows, differing
sensitivities among  the exposed persons, or geese choosing to
feed in one field  rather  than another.  Accordingly, while some
consideration should be given to actual harm, risk is a better
measure of the gravity of a violation and should be given greater
weight in assessing  penalties.
     It is also  appropriate to give greater weight to risk than
to harm because  harm is often difficult to assess.  For example,
many human health  harms from pesticide exposure are transient and
mistaken for something else, or else cause long-term effects that
are not manifest for years.  Environmental harms such as wildlife
kills and ecosystem  degradation are typically difficult to
discern and difficult to  attribute to a particular event.  As EPA
observed in the  diazinon  cancellation proceeding,  the number and
frequency of adverse effects on wildlife cannot be precisely
quantified.  _Due  to the  widespread failure to observe, report,
investigate, and diagnose bird kills, reported kills represent
only _the tip of the iceberg_ of total actual kills._ In the
Matter of Ciba-Geicrv Corp. , Remand Decision , 55 Fed. Reg. 31133,
31140 (July 31,  1990).
     The toxicity  of the  pesticide involved in a violation also
influences the risk  associated with the violation, and therefore
the gravity of the violation.   Plainly, the misuse of a highly
toxic pesticide  poses a greater risk than the misuse of a less
toxic pesticide.
     Culpability,  in its  broadest sense, involves elements of
scienter,  malice, recklessness, negligence, good faith, control
                                                              000167

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 over the circumstances and persons involved in the violation, and



 history of compliance or  noncompliance.  Where culpability  is



 greatest,  violations are  treated as criminal violations.  Civil



 enforcement is appropriate for unintentional violations,



 including violations that occur despite a person_s best efforts



 to comply with the law, despite poor judgment by a person_s



 agent,  and despite otherwise unblemished records of compliance.



 While each of these factors is relevant to the gravity of the



 violation,  they must be subordinate to considerations of the



 risks associated with the violation.  Consideration of the



 purposes of FIFRA reveal  why this must be so.



      The overriding purpose of FIFRA is to prevent pesticides



 from causing unreasonable risks.  FIFRA generally prohibits sale



 and distribution of pesticides unless registered by EPA, and



 conditions  EPA approval of registration upon an EPA determination



 that:



  [W]hen considered with any restrictions imposed [by EPA as



 conditions  of registration] ... it will perform its intended



 function without unreasonable adverse effects on the



 environment[,  and]  when used in accordance with widespread and



 commonly recognized practice it will not generally cause



 unreasonable  adverse effects on the environment.



 FIFRA section 3(b)(5).



     Where  Congress includes penalty and enforcement provisions



 in a statute,  those provisions are presumably intended to further



the purposes  of  the statute.  As the primary purpose of FIFRA is



to reduce risk and  prevent unreasonable risk, it follows that






                             „„                            000168

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implementation of the  civil penalty provisions of FIFRA section



14(a) should be harmonious with  that primary purpose.  A degree



of a violator_s culpability does not alter the risk that results



from a failure to comply with  FIFRA or the regulations



promulgated thereunder.  Culpability, therefore, is not relevant



to the main purpose  of FIFRA.  Accordingly, Congress_ goal of



reducing risks of pesticides is  best furthered in penalty



assessment by making the risk  of harm inherent in a violation the



predominate factor in  assessing  a civil penalty, while making



culpability and other  factors  subordinate.







2.   Size of Business



     FIFRA section 14(a)(4) requires that EPA consider the



appropriateness of the penalty to the size of the business of the



person charged.  Size  of business is not defined in FIFRA,  but



could reasonably be  measured in  terms of assets, number of



employees, quantities  of pesticides used and/or produced,  number



of pesticides used and/or produced, etc.  A financial measure



seems the most appropriate choice in light of the financial



nature of civil penalties, and gross revenue is the best-defined



and most easily accessible financial measure of the size of



businesses.



     Once a method of  determining the size of a business is



selected, one must decide how  to take it into account.  One way



to take the size of  a  business into account would be to make



penalties directly proportional  to the size of the business, but



this would make precise quantification of the size of business a







                            3i.                           000169

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key  issue  in  every  case.  An alternative approach of establishing



certain thresholds  would  avoid this burden in the majority of



cases.  It is less  important to distinguish between companies



with gross sales of $500,000 and $600,000 than it is to



distinguish large companies which have  (or reasonably should



have)  sophisticated regulatory compliance programs and smaller



companies  that may  not  be able to afford them.  A three-tier



system which  distinguishes between true small businesses,



mid-size businesses with  substantial resource limitations, and



larger businesses is an efficient and meaningful method of



implementing  the statutory requirement to consider the



appropriateness of  the  penalty to the size of the business.
3.   Ability to Continue  in Business



     FIFRA  section  14(a)(4) requires EPA to consider the effect



of a penalty on the person's ability to continue in business.



The Tenth Circuit has  interpreted this as placing on the Agency



an affirmative duty to include in the record evidence concerning



the effect  of a penalty on the person's ability to continue in



business, even where the  respondent does not contest the penalty.



Katzson Bros.. Inc. v.  EPA. 839 F.2d 1396, 1400-01  (10th Cir.



1988).  Section 14(a) (4), however, does not prohibit the



assessment  of a penalty that would force a company out of



business, as the statute  only requires that EPA "consider...the



effect on the person's ability to continue in business...."
                                                          000170

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B.   Application of the Statutory Factors



     Following interpretation of the  penalty  factors mandated



under  FIFRA section 14, the next step is to consider how these



statutory factors apply to the facts  of the present cases.







1.   Gravity



     All  of the violations at issue pertain to a pesticide



registered for uses such as sterilizing surgical instruments and



disinfecting hard surfaces such as countertops, operating tables,



and medical equipment in hospitals.   The risks associated with



sterilants are two-fold:  There is the risk of adverse effects to



health or the environment as a result of exposure to the



pesticide,  and the risks of infection when the sterilant does not



perform as expected.



     EPA  has established four categories based on acute toxicity,



each requiring a different signal word on the pesticide label to



alert  users to the risk of acute toxicity associated with the



product.   See 40 C.F.R. § 156.10(1).   From lowest acute toxicity



to highest acute toxicity,  the required signal words are



_Caution_,  _Warning_,  _Danger_,  and _Poison_.  WipeOut meets the



criteria  of Toxicity  Category I,  and  requires the signal word



_Danger_.   WipeOut is thus among the  more acutely toxic



pesticides  registered by  EPA,  indicating that the gravity of



violations  involving  WipeOut should generally be considered



higher than average based on acute toxicity alone.



     In the case of a  sterilant,  however, risks of infection



resulting from  inefficacy probably exceed those associated with





                                                        000171

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 WipeOut_s  substantial  acute toxicity.  The single registered



 product  at issue  in these  actions is used for sterilization of



 medical  equipment used in  invasive medical and veterinary



 procedures.   Such instruments  include, for example, dental



 instruments and endoscopes.  These instruments, if not properly



 sterilized,  may transmit pathogenic microorganisms between



 patients.   For this reason, the efficacy of the sterilizing



 solutions  used on the  instruments is crucial, and the gravity of



 inefficacy is severe.



      In  addition,  the  multiple unregistered products are used for



 many  different antimicrobial purposes to protect the public from



 infectious risks  posed by  microorganisms.  None of these



 unregistered products  ever completed the EPA review procedure for



 sterilant  or disinfectant  products.  Moreover, no registered



 glutaraldehyde based sterilant product has glutaraldehyde levels



 as low as  Respondent's unregistered products.  Therefore, persons



 relying  on these  products  were without the expected assurance



 that  such  products work as claimed, and consequently experienced



 an unreasonable risk of infection.



      In  this  case,  as  in most, it is easier to identify the risk



 associated with violation  than it is to identify actual harms.



 It has not been possible to count or to identify the persons who



 contracted diseases as a consequence of misplaced reliance on the



 ineffective  sterilant  WipeOut.  It is fortunate that WipeOut_s



 inefficacy was identified  through EPA_s own testing, rather by



epidemiologists investigating  a disease outbreak.  As discussed



above, it  is appropriate in assessing penalties to give greater







                                                       000172

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weight  to the risk of the violation than to actual harm.



     Turning to the relative risks inherent in the specific



violations at issue,  most present substantial risk.  The majority



of the  counts allege sale of sterilants that are misbranded owing



to their  inefficacy,  specifically, sale of sterilants that do not



kill pathogens as claimed.   The pesticide is intended for use in



hospitals,  under circumstances where risk of infection is high



owing to  the routine presence of pathogens, the likelihood of



surgery and other invasive procedures, and the likelihood that



the persons and domestic animals exposed already have stressed



immune  systems.  Compared to the entire range of risks that FIFRA



is intended to regulate,  the sale of sterilants that do not kill



pathogens as claimed poses risks that are clearly at the high end



of the  spectrum.



     The  second largest group of counts allege sale of



unregistered products.   FIFRA is at its heart a licensing law,



prohibiting the sale and distribution of pesticides unless the



pesticides satisfy the  requirements for registration.  In the



registration process, EPA performs risk assessments on each



pesticide,  and determines the particular uses and conditions of



use, if any,  that will  allow the pesticide to be used without



unreasonable risk.   The introduction into commerce of an



unregistered pesticide  plainly circumvents the entire regulatory



and risk  management system  intended under FIFRA,  and is therefore



a violation of considerable gravity.



     Several  other counts charge Respondent with misbranding by



making on behalf  of the product pesticidal claims that differ



                                                         000173

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 from  those  approved  by  EPA  in registration.  Like the sale of an



 unregistered  product, this  violation thwarts the registration



 system established by FIFRA.  EPA manages the risks inherent in



 pesticides  by approving each pesticide for certain uses and



 disallowing others,  based upon a weighing of the risks and



 benefits posed by each  use.  For each permitted use, EPA



 specifies the amount of pesticide to be used, the timing of the



 application,  and other  precautions to assure that the use does



 not pose unreasonable risks.



      Registrant's WipeOut Cold Sterilizing Solution bears the



 following claims, among others: "May be reused as a high level



 disinfecting  solution and will maintain 100% efficacy for 45



 days..."; "Safe for  Scopes...11; "Disinfection was achieved in 15



 minutes at  68  degrees fahrenheit against M. Tuberculosis and M.



 bovis . . . " ;  "WipeOut  activated solution may be diluted 1 : 1 with



 water. . .After  activation, the WipeOut solution will maintain 100%



 efficacy for  45 days..."; and "For use on all hard non-porous



 surfaces...."   All  these claims are substantially different from



 the accepted  labeling for the product, and all relate to use of



 the product to  protect  humans from infectious pathogens.  The



 risks associated with these differing claims is identical to the



 risks posed by  an unregistered pesticide product, namely that



there has been  no Agency review of whether the particular use of



the product poses an unreasonable risk.  This is a grave and



substantial risk, implicating concerns for public health.



     Respondent is charged with failure to submit to EPA



information concerning  unreasonable adverse effects of a
                                                          000174

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pesticide, as  required under section  6(a)(2) of FIFRA.  _Congress



recognized that  the risk-benefit  balance initially performed at



the time of registration could  change upon reevaluation of the



existing information or as new  information concerning the risks



or benefits of a pesticide became available._ Chemical



Specialties Manufacturers Ass'n v. EPA. 484 F. Supp. 513, 516



(1980).  Section 6(a)(2)  assures  that if, after EPA has



registered a pesticide,   a registrant becomes aware of new



information which indicates that  the  pesticide might pose greater



or different risks  than were evaluated during registration, the



registrant is  obligated to submit such information to EPA for its



consideration.   Depending upon  the significance of such



information, EPA might seek to  cancel or suspend the pesticide



registration,  modify label precautions, require additional



testing, or simply  wait and watch to  see if the adverse effect is



confirmed elsewhere.   The specific information Respondent failed



to submit to EPA was that a batch of  its pesticide product did



not work when  used  in accordance  with its label instructions.



This information, withheld from EPA for more than a year, would



have allowed the Agency to take action to prevent needless risks



to the public  relying on the batch of sterilant Respondent knew



to be ineffective.   Moreover, by  depriving EPA of this new



information concerning the adverse effects of the pesticide,



Respondent delayed  EPA_s  general  reevaluation of  the risks and



benefits posed by the pesticide,  and  prevented EPA from taking



timely actions appropriate to protect health and the environment.



     Respondent  is  charged with failure to maintain the




                                                           000175

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 underlying raw data from studies  submitted to EPA in support  its
 registration application for  WipeOut Cold Sterilizing Solution,
 EPA Reg.  No. 58994-1.
 With respect to retention of  documentary raw data and other
 similar records connected with  registration support data, the
 Agency has concluded that such  data should be retained for the
 life of the registration of the pesticide.  Such retention
 affords both the applicant and  the Agency the opportunity to
 conduct further studies  and investigations at any time during
 which the pesticide is being  used and entering the environment.
 Pesticide Programs; Good Laboratory Practice Standards; Final
 Rule.  48  Fed.  Reg.  53946,  53961-62  (Nov. 29, 1983).
      In the absence of the underlying raw data, it is impossible
 for EPA to assess the accuracy  or reliability of studies upon
 which EPA relies in assessing the risks and benefits of a
 pesticide.   Without recourse  to the raw data, EPA may not be able
 to  determine whether a single batch failure, such as described in
 connection with Count XXXVI,  is an isolated, batch-specific
 failure or whether  failures are likely to occur routinely.
      Respondent is  charged with failure to label its product with
 either  an EPA  Registration Number or an EPA Establishment Number.
 FIFRA prescribes regulatory scheme of cradle to grave labeling of
 pesticides  to  protect man and the environment from unreasonable
 risks.  One of the  major functions of EPA Registration Numbers
 and EPA Establishment Numbers is  to provide a ready method for
 identifying and responding to product which have problems.  These
problems  can include matters  such as contamination,
                              31*                         000176

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misformulation or, particularly for ster Hants such as the
registered product at  issue  in this matter, inefficacy.  A
pesticide label without  the  required identifying information can
make it more difficult for the Agency and the registrant to
appropriately respond  to any unreasonable risk to human health or
the environment posed  by a pesticide.  This inability to manage
risk effectively  creates a significant risk in and of itself.
     As discussed above,  evaluating the gravity of a violation
reasonably includes  consideration of the violator_s culpability.
In the present case, Respondent_s violations apparently have
resulted from negligence.  All of the violations charged could
have been prevented  by Respondent had it exercised due diligence.
Respondent has no history of prior violations, however, the fact
that EPA has identified  so many different violations of different
requirements of FIFRA  indicates that Respondents overall
compliance program is  substantially deficient.  This suggests a
non-trivial level of negligence and a moderately high level of
culpability.
     In summary of the gravity component of the violations in
this case, it is  demonstrated that the violations pose an
unreasonable risk to health  and the environment, that they may
well have resulted in  actual harm, and that Respondent_s
culpability is moderately high.  Consideration of the facts of
this case supports a finding that the gravity of the violations
at issue is great, suggesting that penalties at the high end of
the range would be appropriate.
                                                     000177

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 2.    Size  of  Business

      The size of  a  business may reasonably be determined by a

 company's  gross revenues  from all revenue sources during the

 prior calendar year, as this figure is readily accessible for

 publicly held corporations and provides a meaningful

 characterization  of the relative sizes of businesses.  Respondent

 and  its subsidiary  Meditox had total annual sales of

 approximately 3.8 million in 1992. Respondent is a major

 manufacturer  and  one of the leading companies in the sterilant

 industry.  Respondent_s business is clearly a substantial one,

 and  is of  a size  that  should properly be held accountable for

 strict compliance with laws that protect health and the

 environment.   Accordingly, the penalty assessed should be at the

 high end of the scale  in  consideration of size of business.



 3.    Ability  to Continue  in Business

      Respondent and its Meditox Subsidiary had total annual sales

 of approximately  $3.8  million in 1992.  Respondent has asserted

 that  paying the proposed  penalty would compromise its ability to

 continue in business,  but has made minor effort to substantiate

 this  assertion.



C.    The  PIFRA Enforcement Response Policy
      l.The Role of  the FIFRA ERP in

          Administrative  Penalty Proceedings

     The discussion above presents interpretations of the

statutory factors that must be considered in the assessment of a
                                                       000178

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civil penalty,  and application of  those  factors to the  specific



facts of  the  present case.   While  this analysis is essential in



broadly evaluating the appropriateness of the proposed  penalty,



when it comes time to choose for each violation a specific dollar



figure, an  element of subjectivity inevitably enters  in.  In



order to  avoid  purely ad hoc penalty assessments, with  their



attendant risks of arbitrary and capricious decision  making, the



Agency employs  a collection of penalty policies.



     The  FIFRA  Enforcement  Response Policy  (_FIFRA ERP_) sets



forth a comprehensive, rational and reasonable framework for



applying  each of the statutorily-mandated factors to  the facts of



a case and  places each type of FIFRA violation in context with



the other types of FIFRA violations.  The FIFRA ERP,  like EPA_s



other penalty policies,  is  designed to promote three  specific



goals —  deterrence,  fair and equitable  treatment of  the



regulated community,  and swift resolution of environmental



problems. See EPA General Enforcement Policy # GM-21: Policy on



Civil Penalties,  at 1 (Feb.  16, 1984).



Fair and  equitable treatment requires that the Agency_s penalties



must display  both consistency and  flexibility.  The consistent



application of  a penalty policy is  important because  otherwise



the resulting penalties  might be seen as being arbitrarily



assessed.  Thus  violators would be  more  inclined to litigate over



those penalties.   This would consume Agency resources and make



swift resolution of environmental problems less likely.



     But any  system for  calculating penalties must have enough



flexibility to make adjustments to  reflect legitimate differences





                                                        °00179

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 between  similar  violations.  Otherwise the policy might be viewed



 as  unfair.   Again,  the  result would be to undermine the goals of



 the Agency  to  achieve swift  and equitable resolutions of



 environmental  problems.



 Id.  at 4.



      Any assessment of  a  civil penalty must explain how the



 penalty  assessed reflects the facts of the case and the



 statutorily-mandated factors in order to make a record of the



 agency action  for purposes of judicial review.  This record must



 show that the  Agency interpreted and applied the



 statutorily-mandated penalty factors to the facts of the case



 when assessing a penalty.  The Presiding Officer may adopt the



 interpretations  of  those  statutory factors advocated by either



 party, or may  adopt a completely different interpretation,



 provided that  it is consistent with the statute and prior



 decisions of the Environmental Appeals Board.  Regardless of what



 interpretation of the statutory factors a Presiding Officer



 relies upon in assessing  a penalty, the decision is subject to



 reversal pursuant to section 706(2)(A) of the Administrative



 Procedure Act  if arbitrary or capricious.  Accordingly, the



 interpretation and  application of the statutory factors must be



 rational and consistent,  and must be clearly articulated in order



 to allow for meaningful review by the EAB or the Federal Courts



 of Appeals.  The D.C. Circuit has made it clear that



 administrative adjudications must be supported by findings and



reasons  that appear in the record:



One basic procedural safeguard requires the administrative






                                                            000180

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adjudicator, by written  opinion, to state findings of fact and



reason that support  its  decision. These findings and reasons must



be sufficient to  reflect a  considered response to the evidence



and contentions of the losing party and to allow for a thoughtful



judicial review if one is sought—. Moreover, a court "cannot



'accept appellate counsel's post hoc rationalizations for agency



action'; for an agency's order must be upheld, if at all, 'on the



same basis articulated in the order by the agency itself.1"



Harborlite Corp.  v.  ICC.  613 F.2d 1088, 1092  (D.C. Cir. 1979)



(quoting FPC v. Texaco,  Inc.. 417 U.S. 380, 397, 41 L. Ed. 2d



141, 94 S. Ct. 2315  (1974))  (quoting Burlington Truck Lines. Inc.



v. United States. 371  U.S.  156, 168-69, 9 L.  Ed. 2d 207, 83 S-



Ct. 239  (1962)).  See also Morton v. Dow. 525  F.2d 1302 (10th Cir.



1975)  (agency's decision upheld because the Administrative Law



Judge made the necessary findings on the ultimate issues, clearly



indicated his reasoning,  and gave evidence to support his



conclusions).



     A Presiding  Officer must employ some consistent methodology



for interpreting  the statutory factors and applying them to the



facts of the cases,  or else resort to ad hoc  penalty assessment,



where the necessary  policy  judgments and assumptions are made



anew in each case.   Through an ad hoc penalty assessment, the



penalty for any violation could fall anywhere between zero and



the statutory maximum, depending on how the statutory factors are



interpreted and how  the  facts are weighed in  that case.  An ad



hoc approach would not meet minimum standards of fairness and



rationality, and would be more subject to challenge as arbitrary





                                                          000181

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 and capricious.   Although the FIFRA  ERP does not represent the



 only rational or reasonable methodology for interpreting and



 applying the requirements of FIFRA section 14, the Presiding



 Officer must apply some penalty assessment methodology that is at



 least as rational and reasonable as  that  in the FIFRA ERP.



      Where the Presiding Officer finds that the rationale and



 approach of a penalty policy, in whole or in part, is appropriate



 in a particular case, it is permissible for the Presiding Officer



 to set forth the specific reasons for the penalty assessment by



 reference to the reasoning and approach of the applicable penalty



 policy.   As the Board observed in PIC Americas;



 By referring to the penalty policy as a basis for assessing a



 particular penalty,  the presiding officer is incorporating the



 underlying rationale of the policy into her decision. The



 reference to the policy becomes,  in  effect, a form of "shorthand"



 for explaining the rationale underlying the penalty assessment.



 PIC Americas at 7.   Regardless,  though, of whether the Presiding



 Officer  agrees with the statutory interpretations or follows the



 penalty  rationale advocated by one party, the Presiding Officer



 must in  each case explain how the statutory factors were applied



 to  the facts of  the case to reach the penalty assessed.  The



 Consolidated Rules of Agency Practice require that "the Presiding



 Officer  shall set forth the specific reasons for the increase or



 decrease"  from the penalty proposed  in the complaint. 40 C.F.R. §



 22.27(b).



     The  FIFRA ERP describes a comprehensive five step process to



determine administrative civil oenalties  consistent with the




                                                            000182

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criteria  of  FIFRA section 14(a)(4)  and appropriate to the facts
and circumstances of the particular case:
These steps  are:  (1)  determination  of gravity or "level" of the
violation using Appendix A of  this  ERP;  (2) determination of the
size of business  category for  the violator, found in Table 2; (3)
use of the FIFRA  civil penalty matrices  found in Table I to
determine the  dollar amount associated with the gravity level of
violation and  the size of business  category of the violator; (4)
further gravity adjustments of the  base  penalty in consideration
of the specific characteristics  of  the pesticide involved, the
actual or potential harm to human health and/or the environment,
the compliance history of the  violator,  and the culpability of
the violator,  using the 'Gravity Adjustment Criteria1 found in
Appendix  B;  and  (5)  consideration of the effect that payment of
the total civil penalty will have on the violator's ability to
continue  in  business,  in accordance with the criteria established
in this ERP.
(FIFRA ERP,  p. 18,  CX 83)
     This five step process addresses factors specific to the
violator_s conduct and the consequences  of the specific
violations.  Each of the five  steps outlined above is discussed
below in  regard to the violations charged in each complaint.
     2.   FIFRA 93-H-02
     The  Complaint in FIFRA 93-H-02 proposes a civil penalty of
$200,000.  This proposed penalty was calculated in accordance
with the  statutory factors articulated in FIFRA as captured by
the July  2,  1990  FIFRA ERP (CX 83).
                                                     000183

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 Step 1;   Determination of gravity  or  level of violation



      The first step is to determine the  intrinsic gravity  level



 of the violation.   Appendix A of the  FIFRA ERP contains  a  listing



 of anticipate violations of FIFRA  and assigns to each a  gravity



 level.  Violations with the highest intrinsic gravity are



 assigned to level  1,  and those of  the lowest gravity are assigned



 to level 4.  According to Appendix A  of  the ERP, the sale  or



 distribution of a  pesticide which  is  misbranded, in that the



 label has a statement, design,  or  graphic representation which is



 false or misleading,  as alleged in Counts I-XXXIV, is a  level 2



 violation.  (FIFRA  ERP, p.  A-l,  CX  83; Penalty Worksheet, CX 82)



 The sale or distribution of a registered pesticide if any  claims



 made for it as a part of its sale  or  distribution substantially



 differ from any claims made for it in registration under FIFRA



 section  3,  as alleged in Count XXXV,  is  a level 2 violation.



 (FIFRA ERP,  p.  A-l,  CX 83;  Penalty Worksheet, CX 82)  The  failure



 of  a registrant, wholesaler,  dealer,  retailer, or other



 distributor to file reports required  by  FIFRA, as alleged  in



 Count XXXVI,  is a  level 2  violation.  (FIFRA ERP, p. A-6, CX 83;



 Penalty  Worksheet,  CX 82)   The failure to submit any records



 required by or under  FIFRA section 8, as alleged in Counts



 XXXVII-XL,  is a level 2 violation. (FIFRA ERP, p. A-3, CX  83;



 Penalty  Worksheet,  CX 82)








 Step  2:   Determination of  Size of  Business



     The  second step  is to  consider the  appropriateness  of the



penalty relative to the size of the business.  Penalties under
                                                            000184

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the FIFRA  ERP can vary depending on the size of the business, as



determined by the violator_s gross revenues from all revenue



sources during the prior calendar year  (FIFRA ERP, p. 20, CX 83) .



Business are grouped into three  tiers, large (gross revenues in



excess of  $1,000,00),  medium (gross revenues between $300,001 and



$1,000,000)  and small  (gross revenues $300,000 or less).



     Respondent and its Meditox  Subsidiary has total annual sales



of approximately $3.8  million in 1992.  (Dun and Bradstreet



Reports, CX 82C and 82D) .   Respondent is therefore in size of



business category I,  for section 14(a)(1) violators whose gross



revenues exceed $1,000,000 annually.  (FIFRA ERP, p. 20, CX 83;



Penalty Worksheet,  CX  82)







Step 3:    Determination of Dollar Amount



     Third,  the gravity level and size of business are applied to



the FIFRA  Civil Penalty Matrix to determine a penalty appropriate



for the nature of the  violation  and the size of business.  The



matrix is  designed so  that small businesses that commit less



serious violations are penalized much less severely than large



businesses that commit more serious violations.  For FIFRA



section 14(a)(1)  violators in size of business category I who



have committed gravity level 2 violations, the FIFRA Civil



Penalty Matrix indicates  a base  penalty of $5,000. (FIFRA ERP, p.



19, CX 83;  Penalty Worksheet,  CX 82)







Step 4;  Gravity  Adjustments to  Base Penalty



     The fourth step is to adjust the base penalty for the
                               33--?
                                                         000185

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 toxicity of the specific pesticide involved, the actual or



 potential harm to human health or the environment, and the



 compliance history and culpability of the violator using a set of



 five "Gravity Adjustment Criteria" described in Appendix B of the



 FIFRA ERP.  This process, which assigns a numeric value to each



 of the Gravity Adjustment Criteria, provides additional



 flexibility allowing  EPA to carefully tailor the penalty to the



 facts of and circumstances of the instant case.  The separate



 values are summed as  aggravating or mitigating factors to adjust



 the penalty upwards or downwards.  Accordingly, culpable conduct



 by violators with a poor compliance history creating a great risk



 to human health or the environment will be penalized more



 severely that a merely negligent first time violator who does not



 create a major human  health or environmental risk.



      For the first criteria, _pesticide_, Respondent was given a



 value of 2,  because its product labels contain the signal word



 "danger" based on its acute toxicity. (FIFRA ERP, p. B-l, CX 83;



 Penalty Worksheet,  CX 82)



      For the second criteria, _harm to human health_, Respondent



 was  given the value 5 because of actual serious or widespread



 harm to human health. (FIFRA ERP, p. B-l, CX 83; Enforcement Case



 Reviews,  CX  12B,  SOB, 49C, 51C; Penalty Worksheet, CX 82)



      For the third  criteria, _environmental harm_, Respondent was



 given  a  value of  5  because of actual serious or widespread harm



 to human  health.  (FIFRA ERP, p. B-l, CX 83; Enforcement Case



Reviews,  CX  12B,  30B, 49C, 51C; Penalty Worksheet, CX 82)



     For  the  fourth criteria, _compliance history_, Respondent







                                                           000186

-------
was  given a value of 0 for having no prior violation.  (Penalty
Worksheet,  CX 82)
      For the fifth criteria,  _culpability_,  Respondent  was  given
a value of  2 because its culpability is  unknown but presumed to
be negligent. (Penalty Worksheet,  CX 82)   The sum of the  gravity
adjustment  factors is 14.
      According to Table 3  of  the FIFRA ERP,  a gravity adjustment
value of 18 requires a 15  percent upwards  adjustment of the
penalty (FIFRA ERP,  p. 22, CX 83).   However,  the base penalty of
$5,000 per  violation determined in Steps 1 through 3 above  can
not  be increased for Respondent because  it is already at  the
statutory maximum for FIFRA section 14 (a) (l)  violators. (FIFRA
ERP,  p.  22,  Table 3,  footnote **,  CX 83; Penalty Worksheet, CX
82)

Step 5;   Ability to  Continue  in Business
      The fifth step  is to  consider  the impact of the penalty on
the  violator_s ability to  remain in business.   Based on the Dun
and  Bradstreet Report for  Health Care Products  (CX  82C)  and the
Dun  and  Bradstreet Report  for Health Care  Products  Meditox
Subsidiary  (CX 82D) ,  Complainant believes  that  Respondent can pay
the proposed  penalty  without  significant impact on  its ability to
continue  in business.
      3.   FIFRA  95-H-04
     The  analysis  above  for the misbranding counts  in FIFRA
93-H-02 applies without  alteration  to the misbranding counts in
FIFRA 95-H-04.  Respondent is  also  charged with 40  counts for
                                                            000187

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 sale or distribution of an unregistered pesticide, which  is  a



 Gravity Level 2  violation.  (FIFRA  ERP, p. A-l, CX 83; Penalty



 Worksheet,  CX 82A)  Size of business is Category 1, as in  FIFRA



 93-H-02,  which yields a base penalty of $5,000 according  to  the



 Civil Penalty Matrix (FIFRA ERP, p. 19, CX 83; Penalty Worksheet,



 CX 82A)   Gravity adjustment factors are the same as used  in  FIFRA



 93-H-02,  with one qualification.   The pesticide toxicity  for the



 unregistered pesticides has not been determined and so, is not



 available for use as an adjustment factor.  In its absence,



 Complainant has  used the same gravity adjustment factor as in



 FIFRA 93-H-02 given that the greatest risk is the risk of



 infection owing  to inefficacy and  given that the unregistered



 products  contain the same active ingredient as the registered



 product.



      4.    I.  F.  & R.  VIII-90-279C



      The  current FIFRA Enforcement Response Policy was issued on



 July 2, 1990,  superseding the prior EPA policy, the FIFRA Civil



 Penalty Assessment Guideline,  issued July 31, 1974.  The



 complaint in  I.  F.  &  R.  VIII-90-279C predates the 1990 FIFRA ERP



 and  reflects  penalty  calculations  under the 1974 penalty  policy.



 The  above discussion  of the penalty calculations in FIFRA 93-H-02



 and  FIFRA 95-H-04 are based on the 1990 FIFRA ERP and reflects



 the  Agency_s  current  interpretation and implementation of the



 statutory factors for these violations.  Complainant has  not



 sought to amend  the complaint in I. F. & R. VIII-90-279C  to  seek



 the  higher penalties  called for under current policy.



Accordingly,  rather than discuss in detail the mechanics  of  the






                                                           000188

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1974 penalty policy, Complainant merely notes that the current



FIFRA ERP calls for higher penalties  than proposed in the I. F.  &



R. VIII-90-279C complaint and refers  to the above discussion as



fully supportive of penalties at least as high as those sought in



I. F. & R. VIII-90-279C.
                                                           000189

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                                              ;''-"'             V
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                         ;-
                                                        *"   Sht3 2 11994
                           REGION VII
                      726 MINNESOTA AVENUE
                    KANSAS CITY, KANSAS 66101

                    BEFORE THE ADMINISTRATOR

IN THE MATTER OF              )   EPCRA Docket No.  VII-94-T-381-E
                              )
GEC Precision Corporation     )   COMPLAINT AND NOTICE OF
Wellington, Kansas            )   OPPORTUNITY FOR HEARING
                              )
                Respondent    )

                            COMPLAINT

                          Jurisdiction

l.  This is an administrative action for the assessment of civil
penalties instituted pursuant to Section 325 of the Emergency
Planning and Community Right-to-Know Act of 1986 (hereinafter
"EPCRA11), 42 U.S.C. § 11045."

2.  This Complaint serves as notice that the United States
Environmental Protection Agency (hereinafter "EPA") has reason
to believe that Respondent has violated EPCRA, 42 U.S.C. § 11001
et. seg. and the regulations promulgated thereunder and codified
at 40 C.F.R. Part 372, governing the submission of toxic chemical
release inventories by owners and operators of covered
facilities.

                             Parties

3.  The Complainant, by delegation from the Administrator
of the EPA, and the Regional Administrator, EPA, Region VII,
is the Director, Air and Toxics Division, EPA, Region VII.

4.  The Respondent is GEC Precision Corporation, an aircraft
parts and equipment company, incorporated and registered to
do business in the State of Kansas, located at 1515 Highway 81
North, Wellington, Kansas  67152.

              Statutory and Regulatory Requirements

5.  Section 313 of EPCRA and 40 C.F.R. §§ 372.22 and 372.30
require the owner or operator of a facility that:   (a)  has
10 or more full time employees;  (b) has a Standard Industrial
Classification  (SIC) code of 20 through 39; and  (c) that
manufactured, processed or otherwise used a toxic  chemical  listed
under Section 313 (c) of EPCRA and 40 C.F.R.  §-372.65,  in  excess
of the threshold quantity established under S~ection 313 (f)
of EPCRA and 40 C.F.R. § 372.25 during the calendar year,  to
                                           0001 91

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                                    GEC Precision Corporation
                                    EPCRA Docket No. VII-94-T-381-E
                                    Page 2 of 8

complete and submit a toxic chemical release inventory form
(hereinafter "Form R") to the Administrator of EPA and to the
State in which the subject facility is located by July 1 for
the preceding calendar year for each toxic chemical known by
the owner or operator to be manufactured, processed, or otherwise
used in quantities exceeding the established threshold quantity
during that preceding calendar year.

6.  As set forth at Section 313(f) of EPCRA and 40 C.F.R.
§ 372.25, the reporting threshold amount for calendar year
1987 for chemicals manufactured or processed at a facility
is 75,000 pounds, 50,000 pounds for calendar year 1988, and
25,000 pounds for calendar years subsequent to and including
1989.  The reporting threshold for a toxic chemical otherwise
used at a facility is 10,000 pounds for calendar years subsequent
to and including 1987.

                           VIOLATIONS

     The Complainant hereby "states and alleges that Respondent
has violated EPCRA and regulations thereunder as follows:

                             Count I

7.  On or about May 17, 1994, an authorized EPA representative
conducted an inspection pursuant to EPCRA § 313 at Respondent's
facility located at 1515 Highway 81 North, Wellington, Kansas
67152.

8.  Respondent has 10 or more full-time employees, as defined at
40 C.F.R. § 372.3, at said facility.

9.  Respondent's facility is in SIC Codes 20 through 39.

10.  Respondent is a person as defined at Section 329(7) of EPCRA
and is the owner or operator of a facility as defined at
Section 329(4) of EPCRA.

11.  The May 17, 1994, inspection of Respondent's facility
revealed that in calendar year 1992, Respondent otherwise used
1,1,1 Trichloroethane in excess of  10,000 pounds.

12.  1,1,1 Trichloroethane is a toxic chemical listed under
Section 313(c) of EPCRA and 40 C.F.R. § 372.65.

13.  Respondent failed to submit a  Form R for 1,1,1,
Trichloroethane to the Administrator of EPA and to  the  State  of
Kansas by July 1, 1993.                     '~    ;


                                                        000192
                                 3-33

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                                    GEC Precision Corporation
                                    EPCRA Docket No. VII-94-T-381-E
                                    Page 3 of 8

14.  Respondent's failure to submit a Form R for 1,1,1
Trichloroethane by July 1, 1993, is a violation of EPCRA § 313,
42 U.S.C. § 11023, and of the requirements of 40 C.F.R. Part 372.

15.  Pursuant to Section 325 of EPCRA, 42 U.S.C. § 11045, and
based upon the facts stated in paragraphs 7 through 14 above, it
is proposed that a civil penalty of $17,000 be assessed against
Respondent.

                             Count  II

16.  The facts stated in paragraphs 7 through 10, are herein
restated and incorporated.

17.  The May 17, 1994, inspection of Respondent's facility
revealed that in calendar year 1992, Respondent otherwise used
methyl ethyl ketone (MEK) in excess of 10,000 pounds.

18.  Methyl ethyl ketone  (MEK) is a toxic chemical listed under
Section 313(c) of EPCRA an_d "40 C.F.R. § 372.65.

19.  Respondent failed to submit a Form R for methyl ethyl ketone
(MEK) to the Administrator of EPA and to the State of Kansas by
July 1, 1993.

20-  Respondent's failure to submit a Form R for methyl ethyl
ketone (MEK) by July 1, 1993, is a violation of EPCRA  § 313,
42 U.S.C. § 11023, and of the requirements of 40 C.F.R. Part 372.

21.  Pursuant to Section 325 of EPCRA, 42 U.S.C. § 11045, and
based upon the facts stated in paragraphs 16 through 20 above, it
is proposed that a civil penalty of $17,000 be assessed against
Respondent.

                            Count III

22.  The facts stated in paragraphs 7 through 10, are  herein
restated and incorporated.

23.  The May 17, 1994, inspection of Respondent's facility
revealed that in calendar year  1991, Respondent  otherwise used
methyl ethyl ketone (MEK) in excess of 10,000 pounds.

24.  Methyl ethyl ketone  (MEK)  is a toxic chemical listed under
Section 313(c) of EPCRA and 40  C.F.R.  §  372.65.

25.  Respondent failed to submit a Form  R for methyl ethyl  ketone
(MEK) to the Administrator of EPA and  to -the' -State of Kansas by
July 1, 1992.                                -    i
                                                             000193

-------
                                    GEC Precision Corporation
                                    EPCRA Docket No. VII-94-T-381-E
                                    Page 4 of 8

26.  Respondent's failure to submit a Form R for methyl ethyl
ketone (MEK) by July 1,  1992,  is a violation of EPCRA § 313,
42 U.S.C. § 11023, and of the  requirements of 40 C.F.R. Part  372.

27.  Pursuant to Section 325 of EPCRA, 42 U.S.C. § 11045,  and
based upon the facts stated in paragraphs 22 through 26 above,  it
is proposed that a civil penalty of $17,000 be assessed against
Respondent.

                             Count IV

28.  The facts stated in paragraphs 7 through 10, are herein
restated and incorporated.

29.  The May 17, 1994, inspection of Respondent's facility
revealed that in calendar year 1990, Respondent otherwise  used
methyl ethyl ketone  (MEK) in excess of 10,000 pounds.

30.  Methyl ethyl ketone (MEK) is a toxic chemical listed  under
Section 313(c) of EPCRA  and 40 C.F.R. § 372.65.

31.  Respondent failed to submit a Form R for methyl ethyl ketone
(MEK) to the Administrator of  EPA and to the State of Kansas  by
July 1, 1991.

32.  Respondent's failure to submit a Form R for methyl ethyl
ketone (MEK) by July 1,  1991,  is a violation of EPCRA § 313,
42 U.S.C. § 11023, and of the  requirements of 40 C.F.R. Part  372.

33.  Pursuant to Section 325 of EPCRA, 42 U.S.C. § 11045,  and
based upon the facts stated in paragraphs 28 through 32 above,  it
is proposed that a civil penalty of $17,000 be assessed against
Respondent.

                             Relief

34.  Section 325 (c) of EPCRA,  authorizes a civil penalty of up
to $25,000 per day for each violation of the Act.  The penalties
proposed in paragraphs 15, 21, 27, and 33 above are based upon
the facts stated in this Complaint, arid on the nature,
circumstances, extent, and gravity of the above-cited violations,
as well as the Respondent's history of prior violations and
degree of culpability, in accordance with EPCRA and the
Enforcement Response Policy for Section 313 of EPCRA.

35.  A Summary of the Proposed Penalties is contained  in the
enclosed Penalty Calculation Summary attached hereto and
incorporated herein by reference.        •         '
                                                             000194

-------
                                    GEC Precision Corporation
                                    EPCRA Docket No. VII-94-T-381-E
                                    Page 5 of 8

36.  Payment of the total penalty - $68,000 - may be made by
certified or cashier's check payable to the Treasurer,  United
States of America, and remitted to:

               Mellon Bank
               EPA - Region VII
               Regional Hearing Clerk
               P.O. BOX 360748M
               Pittsburgh, Pennsylvania  15251

Note that payment of the proposed penalty alone does not satisfy
Respondent's legal obligation to file a complete and accurate
Form R as required by Section 313 of EPCRA and 40 C.F.R.
Part 372.  Failure or refusal to file Form R may subject
Respondent to additional civil penalties of up to $25,000 per day
of violation.

           NOTICE OF OPPORTUNITY TO REQUEST A HEARING

                 Answer and Request for Hearing

37.  In accordance with 5 U.S.C. Section 554, Respondent has the
right to request a hearing to contest any material fact contained
in this Complaint above or to contest the appropriateness of the
proposed penalty set forth herein.  Such a hearing will be held
and conducted in accordance with the Consolidated Rules of
Practice Governing the Administrative Assessment of Civil
Penalties and the Revocation or Suspension of Permits,  40 C.F.R.
Part 22, one copy of which is enclosed herein.

38.  To avoid being found in default, which constitutes an
admission of all facts alleged in this Complaint and a waiver
of the right to hearing, Respondent must file a written answer
and request for hearing within twenty  (20) days of service of
this Complaint and Notice of Opportunity for Hearing.  Said
answer shall clearly and directly admit, deny, or explain each
of the factual allegations contained in this Complaint with
respect to which Respondent has any knowledge, or shall clearly
state that Respondent has no knowledge as to particular factual
allegations in this Complaint.  The answer shall also state
(a) the circumstances or arguments which are alleged to
constitute the grounds of defense;  (b) the facts that Respondent
intends to place at issue; and  (c) whether a hearing is
requested.

39.  The denial of any material fact or the  raising of  any
affirmative defense shall be construed as a  request for hearing.
Failure to deny any of the factual allegations in  the Complaint
                                                          000195

-------
                                    GEC Precision Corporation
                                    EPCRA Docket No. VII-94-T-381-E
                                    Page 6 of 8

constitutes an admission of the undenied allegations.  Said
answer shall be filed with the following:

                 Regional Hearing Clerk
                 United States Environmental Protection Agency
                 Region VII
                 726 Minnesota Avenue
                 Kansas City, Kansas  66101

40.  If Respondent fails to file a written answer and request
for a hearing within twenty (20) days of service of this
Complaint and Notice of Opportunity for Hearing,  such failure
will constitute a binding admission of all allegations made in
this Complaint and a waiver of Respondent's right to a hearing
under EPCRA.  A Default Order may thereafter be issued by the
Regional Administrator and the civil penalties proposed herein
shall become due and payable without further proceedings.

                 Informal Settlement Conference

41.  Whether or not Respondent requests a hearing, an informal
conference may be requested in order to discuss the facts of this
case, the proposed penalty, and the possibility of settlement.
To request a settlement conference, please contact:

                    Anne E. Rauch
                    Attorney
                    United States Environmental Protection Agency
                    Region VII
                    726 Minnesota Avenue
                    Kansas City, Kansas  66101
                    Telephone  913/551-7010

42.  Please note that a request for an informal settlement
conference does not extend the twenty  (20) day period during
which a written answer and request for a hearing must be
submitted.

43.  EPA encourages all parties against whom a civil penalty
is proposed to pursue the possibilities of settlement as a result
of informal conference.  Any settlement which may be reached
as a result of such a conference shall be embodied in a written
Consent Agreement and Consent Order issued by the Regional
Judicial Officer, EPA Region VII.  The issuance of such a Consent
Agreement and Consent Order shall constitute a waiver of
Respondent's right to request a hearing on any matter stipulated
therein.
                                                              000196

-------
                                    GEC Precision Corporation
                                    EPCRA Docket No. VII-94-T-381-E
                                    Page 8  of  8
                     CERTIFICATE OF SERVICE

     I certify that on the date noted below I  hand delivered
the original and one true and correct copy of  this Complaint
and Notice of Opportunity .for Hearing to the Regional Hearing
Clerk, United States Environmental Protection  Agency,
726 Minnesota Avenue, Kansas City, Kansas  66101.

     I further certify that on the date noted  below I sent
by certified mail, return receipt requested, a true and correct
copy of the signed original Complaint and Notice of Opportunity
for Hearing; a copy of the Penalty Calculation Summary; a copy of
the Consolidated Rules of Practice Governing the Administrative
Assessment of Civil Penalties and the Revocation or Suspension of
Permits, 40 C.F.R. Part 22; and a copy of the  August 10, 1992,
Enforcement Response Policy for Section 313 of EPCRA to the
following registered agent for GEC Precision Corporation:

                    The Corporation Company, Inc.
                    515 South Kansas Avenue
                    Topeka, Kansas  66603
      .  3!  I
        Date                                 Bonnie Andrews
                              33*                          000198

-------
                                    GEC Precision Corporation
                                    EPCRA Docket No. VII-94-T-381-E
                                    Page 7 of 8


44.  If Respondent has neither achieved a settlement by informal
conference nor filed an answer within the twenty (20) day time
period allowed by this Notice, the penalties proposed above may
be assessed by the entry of a Default Order.
Date
                                   William A. Spratlin,  Director
                                   Air and Toxics Division
Anne E. Rauch
Attorney
Office of Regional  Counsel.

Enclosures:  Penalty  Calculation Summary
             Consolidated  Rules of Practice Governing the
               Administrative Assessment of Civil Penalties and
               the  Revocation or Suspension of Permits, 40 C.F.R.
               Part 22
             Enforcement Response Policy for Section 313 of EPCRA
                               33?
                                                            000197

-------
                  PENALTY CALCULATION FOR
                  GEC Precision Corporation
                     Wellington, Kansas
              EPCRA  Docket No.  VII-94-T-381-E
COUNT I

VIOLATION;
EXTENT;
CIRCUMSTANCE;
GRAVITY BASED
PENALTY:

PROPOSED
PENALTY;
Failure to report toxic chemical release
inventory emissions for 1,1,1 Trichloroethane
in a timely manner during reporting year
1992.

LEVEL B - Description:  Less than 10 times
reporting threshold; greater than $10 million
annual sales; greater than 50 employees

LEVEL 1 - Description:  Failure to submit
1992 Form R report for 1,1,1 Trichloroethane
by July l, 1993
$17,00& + Adjustments:  None
$17,000
COUNT II

VIOLATION:
EXTENT;
CIRCUMSTANCE:
GRAVITY BASED
PENALTY:

PROPOSED
PENALTY:
Failure to report toxic chemical release
inventory emissions for methyl ethyl ketone
(MEK) in a timely manner during reporting
year 1992.

LEVEL B - Description:  Less than 10 times
reporting threshold; greater than $10 million
annual sales; greater than 50 employees

LEVEL 1 - Description:  Failure to submit
1992 Form R report for methyl ethyl ketone
(MEK) by July 1, 1993
$17,000 + Adjustments:  None
$17,000
                                                         000199

-------
            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                               REGION VII
                         726 MINNESOTA AVENUE
                        KANSAS CITY, KANSAS 66101
                             KAY 2 4 1995
MEMORANDUM

SUBJECT:  Penalty  Calculation  for GEC Precision Corporation,
          Wellington,  Kansas,  EPCRA Docket No. VII-94-T-381-E

FROM:     Mark A.  Smith ^^MjlUi-—
          Environmental Scientist
          Toxic Substances  Control Section
                                A
TO:       Anne Rauch
          Office of Regional Counsel

     The following information supports the appropriateness of
the U.S. Environmental Protection Agency, Region VII's assessment
of civil penalties in  regard to the subject administrative
action.  The proposed  penalties were calculated pursuant to the
August 10, 1992, Enforcement Response Policy for Section 313  of
the Emergency Planning and  Community Right-To-Know Act (EPCRA).

     The purpose of the above-mentioned Enforcement Response
Policy (ERP) is to assure that enforcement actions for violations
of EPCRA Section 313 are arrived at in a fair, uniform, and
consistent manner.  Furthermore, the ERP aims to provide
appropriate enforcement responses for violations committed, as
well as, providing deterrent from the violation of Section 313.

     The ERP states that the determination of the gravity-based
penalty is made according to two factors, which are the
circumstance and the extent of the violation.  These two factors
are incorporated into  a matrix which allows the determination of
an appropriate base penalty amount.  After the base penalty has
been determined, upward or  downward adjustments may be made to
the base penalty in consideration of the following factors:
voluntary disclosure;  history  of prior violations; delisted
chemicals; attitude; other  such matters as justice may require;
supplemental environmental  projects; and, ability to pay.
According to the ERP,  the first three of the above adjustment
factors may be made prior to issuing the civil complaint.  The
total proposed penalty is determined by calculating the penalty
for each violation on  a per chemical, per facility basis, and
then applying any  appropriate  penalty adjustment factors.


                                                          000201

-------
Facility Information

     GEC Precision Corporation is listed in the Dun & Bradstreet
Database (D&B) with a Standard Industrial Classification (SIC)
code of 3728 - principally involved in the manufacture of
aircraft parts and equipment.  GEC Precision Corporation
otherwise used chemicals listed under EPCRA Section 313 above
thresholds required for reporting during calendar years 1990,
1991, and 1992.  According to D&B, annual sales at GEC Precision
were greater than $10 Million, and GEC Precision employed more
than 50 employees.

Summary of Alleged Violations

     GEC Precision Corporation failed to report the otherwise use
of methyl ethyl ketone (MEK) , a listed chemical under EPCRA
Section 313, for calendar years 1990, 1991, and 1992.  GEC
Precision Corporation also failed to report the otherwise use of
1, 1, 1-Trichloroethane (TCA) , a listed chemical under EPCRA
Section 313, for calendar year 1992.

Penalty Calculations

     Circumstance Level:  According to the ERP, the circumstance
of the violation is determined by the seriousness of the
violation as it relates to the availability and accuracy of the
information to the community, to states, and to the government.
The ERP states that failure to report in a timely manner
(Category I - failure to submit report one year or more after the
July 1 due date) the otherwise use of a listed EPCRA Section 313
chemical is a "Level 1" circumstance.

     Extent Level:  The extent factor for a violation is based on
the quantity of EPCRA Section 313 chemical otherwise used by the
facility in violation, and the size of the total corporate entity
in violation.  The size of the total corporate entity is defined
by the amount of sales or number of employees of all sites taken
together owned or controlled by the domestic or foreign parent
company.  According to the ERP, a facility with total corporate
entity sales of $10 million or more and 50 employees or more,
which uses a Section 313 chemical less than 10 times the
threshold level is a "Level B" extent.

Summary of Proposed Penalties

  COUNT I

  VIOLATION:        Failure to report toxic chemical  release
                    inventory emissions for 1^1,1 Trichloroethane
                    in a timely manner during- reporting  year
                    1992.
                                                          000202

-------
EXTENT:
CIRCUMSTANCE:
GRAVITY BASED
PENALTY:

PROPOSED
PENALTY:
LEVEL B - Description:   Less than 10 times
reporting threshold;  $10 million or more
annual sales; 50 employees or more

LEVEL 1 - Description:   Failure to submit-
1992 Form R report for 1,1,1 Trichloroethane
by July 1, 1993
$17,000 + Adjustments:   None
$17,000
COUNT II

VIOLATION;
EXTENT:
CIRCUMSTANCE;
GRAVITY BASED
PENALTY:

PROPOSED
PENALTY:
Failure to report toxic chemical release
inventory emissions for methyl ethyl ketone
(MEK) in- a timely manner during reporting
year 1992.

LEVEL B - Description:   Less than 10 times
reporting threshold; $10 million or more
annual sales; 50 employees or more

LEVEL 1 - Description:   Failure to submit
1992 Form R report for MEK by July 1, 1993
$17,000 + Adjustments:   None
$17,000
COUNT III

VIOLATION:
EXTENT:
CIRCUMSTANCE:
Failure to report toxic chemical release
inventory emissions for methyl ethyl ketone
(MEK) in a timely manner during reporting
year 1991.

LEVEL B - Description:  Less than 10 times
reporting threshold; $10 million or more
annual sales; 50 employees or more

LEVEL 1 - Description:  Failure to submit
1991 Form R report for MEK by truly 1, 1992
                                                     ,  000203

-------
GRAVITY BASED
PENALTY:

PROPOSED
PENALTY;
$17,000 + Adjustments:   None


$17,000
COUNT IV

VIOLATION;
EXTENT:
CIRCUMSTANCE:
GRAVITY BASED
PENALTY:

PROPOSED
PENALTY;
Failure to report toxic chemical release
inventory emissions for methyl ethyl ketone
(MEK) in a timely manner during reporting
year 1990.

LEVEL B - Description:  Less than 10 times
reporting threshold; $10 million or more
annual sales; 50 employees or more

LEVEL 1 - Description:  Failure to submit
1990 Form R report for MEK by July 1, 1991
$17,000 + Adjustments:  None
$17,000
TOTAL PROPOSED PENALTY:  $68,000

-------
               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                  REGION VII
                            726 MINNESOTA AVENUE
                           KANSAS CITY, KANSAS 66101

                                  ] 6 l§§5
MEMORANDUM

SUBJECT:  Addendum to the Penalty Calculation for GEC Precision
          Corporation, Wellington, Kansas, EPCRA Docket No.
          VTI-94-T-381-E

FROM:     Mark A. Smith ^AJL__
          Environmental ScismBTstT
          Toxic Substances Control Section

TO:       Anne Rauch
          Office of Regional Counsel

     In response to Administrative Law Judge Vanderhayden's
request, the following information represents the views of the
U.S. Environmental Protection Agency, Region VII, concerning the
gravity of the alleged violations, including the actual or
potential harm to man and the environment resulting from
Respondent's illegal conduct.  The following includes
Respondent's history, if any, of compliance with the Emergency
Planning and Community Right-to-Know Act  (EPCRA).

     Under Section 313 of EPCRA, facilities that meet certain
criteria are required to report their releases, transfers, and
other activities as required under the Pollution Prevention Act
of 1990 for toxic chemicals.  The report in which this
information is submitted is known as the Form R.  The information
on the Form R is required to be submitted to the U.S. EPA and the
designated State agency in which the facility is located.
Reports are due by July 1 of each year for activities that
occurred at the facility during the previous calendar year.  A
facility must submit a separate Form R for each chemical that
meets the reporting requirements.  Respondent met the pertinent
reporting criteria under Section 313 of EPCRA, but failed to
submit Form R's to the EPA and to the State of Kansas.

     By not submitting Form R information to the State and to
EPA, Respondent's releases, transfers, and pollution prevention
activities were not included in the Toxics Release Inventory
(TRI) database.  The TRI database gives the public direct access
to information about environmental releases of toxic chemicals
for more than 23,000 industrial facilities located in communities
around the nation.  TRI data have been used by industry, public
interest groups, state and local governments, the U.S. Congress
and EPA to assess major opportunities for reducing risks to
public health and the environment.  TRI data have helped industry
identify and analyze areas where source substitution may be


                                                      0002045

-------
possible and wastes minimized.  Finally, TRI data have aided in
the identification of pollution prevention activities and
projects.  Lacking this information, the public is deprived of
its "Right-To-Know" the magnitude of potential harm associated
with living in the community near facilities which release toxic
chemicals.

     In this instance, the Respondent has since reported releases
of methyl ethyl ketone (MEK) and 1,1,1-Trichloroethane, which is
an ozone depleter, into the environment.  Because of the basic
nature of toxic chemicals, i.e. health effects are often not
apparent until several years after exposure, actual harm to
humans is not immediately identifiable.  That fact, however,
underpins the importance of the community having the opportunity
to know its potential harm and make long-term plans to minimize
its exposure.  The local community in Respondent's facility area
has not had the necessary information provided to it via Form R
reporting thereby frustrating any desire that may have been
prompted to perform such planning.

     Regarding other information that may have been available
from the company, many companies report data on chemical
emissions to . EPA and to the' States under other environmental
laws, such as the Clean Air Act, the Resource Conservation and
Recovery Act,  and the Clean Water Act.  Specifically, some of the
information reported under the CAA is reported as a class or
compound of chemicals to one medium, such as volatile organic
compounds (VOC's) emissions to the air.  The scope of TRI
reporting is much broader.  The EPCRA Section 313 TRI data
provide information regarding releases of specific toxic
chemicals to the air, water, and to the land; source reduction,
recycling, treatment, and pollution prevention activities are
reported; and, the public has direct access to the information.

     Enforcement of EPCRA Section 313 ensures that the public has
access to timely and accurate chemical release information.
Respondent's violations of EPCRA Section 313 were identified as
the result of an on-site inspection conducted by EPA.
Respondent's violations were not identified as the result of
Respondent seeking compliance assistance.  In fact, Respondent
was on the mailing list of companies sent an invitation to  EPA,
Region VII 's regularly scheduled compliance assistance workshops
in Respondent's area.  Furthermore, a compliance history of
Respondent with EPCRA does not exist since Respondent had not
submitted a Form R until after the time of the inspection by EPA.

     In summary/ by not reporting under EPCRA Section  313,
Respondent's toxic chemical emissions were not included  in  the
TRI database.   Respondent's violations prevented the public,
industry,  state and local governments from having  a basic tool
for understanding the management and control of to^ic  chemicals
in their community.
                                                              000205

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                                              49




mandatory  road  map  rather than a guideline.  It



again goes back to  the purpose of the document



which is to ensure  that EPA has broken it out



into ten different  regions and all ten regions as



well as the headquarters office are complying in



assessing  penalties in the same manner.



           THE COURT:   Ms.  Rauch, do you have any



     follow-up  in light of my few questions to



     the witness?



           MS. RAUCH:   No.



           THE COURT:   Ms.  Hoffman?



           MS. HOFFMAN:  No.
                *
              v

           THE COURT:   Mr.  Smith, thank you.



           MS. RAUCH:   We have one more witness.



     If there's no  objection, Ms. Fain will do



     the direct questioning of this witness.



           THE COURT:   Good morning, Ms. Fain.



           MS. FAIN:  Good morning.  On behalf of



     EPA this morning, Your Honor, I would like



     to call Mr.  James Hirtz, please.
               C,ou.rt  Keporting
                 MIDCITY PLACE
                  115 EAST DOUGLAS
                   WICHITA, KANSAS 67202
                       PHONE (31 6) 267-1 201
000233

-------
                                                   50
                    JAMES F.  HIRTZ,

           having been first  duly sworn, was

           examined and testified as follows:
                   DIRECT EXAMINATION

BY MS.  FAIN:

Q     Mr.  Hirtz,  will you please state your full name

      for  the  reporter,  please.

A     My name  is  James Francis  Hirtz.

Q     Would  you please state your place of employment

      and  the  address.

A     I'm  employed with United  States Environmental
                   ^f
      Protection  Agency,  Region VII,  at 726 Minnesota

      Avenue,  Kansas  City, Kansas, 66101.

Q     Mr.  Hirtz,  what is  your position at the

      Environmental Protection  Agency?

A     I'm  an Environmental Engineer.

Q     How  long have you been in that  position?

A     I've been employed  with the Agency for nine years

      in that  position.

Q     Do you have any formal education?

A     I received  a Bachelor of  Sciences Degree  from the

      University  of Missouri-Rolla with a degree in

      Chemical Engineering.

      Do you have any training  beyond your degree  in
                     C,ouri  r^eportina
                      MIDCITY PLACE
                       115 EAST DOUGLAS
                        WICHITA, KANSAS 67202
                         TELEPHONE (316) 267-1201
000234

-------
                                                   51
     relation  to what  you do at the Environmental

     Protection agency?

A    Yes, I have.

Q    Can you tell  us what that is,  sir?

A    I received training at the Federal Law

     Enforcement Training Center in Lithgow,  Georgia,

     as well as training in estimating techniques as

     well as training  in negotiation skills.

 >    Can you tell  us what your duties and

     responsibilities  are as an environmental engineer

     at the EPA?

 L    I'm the TRI Coordinator,  Toxic Release Inventory
                   V
     Coordinator for Region VII as  well as the TSCA 5

     and 8 Coordinator in the Toxic Substances Control

     Act.  I also  perform inspections and case review.

     for both  Acts.

 }    Are there any other duties and responsibilities

     that you  have?

 \.    I'm also  a member of several national work

     groups.

 J    Sir, can  you  tell us some things about national

     work groups as they apply to your duties at the

     Environmental Protection Agency?

 L    I'm a member  of the National EPCRA 313

     Enforcement Response Policy work group as well' as
   t
                      ou.r
MIDCITY PLACE
  115 EAST DOUGLAS
   WICHITA, KANSAS 67202
   TELEPHONE (316) 267-1201
                                                000235

-------
                                                   52
     the  313  Interpretive  Guidance  work  group.

 }    What was  your  role  -- you mentioned that you

     participated in  the work group pertaining to the

     Enforcement Response  Policy  for EPCRA 313.   What

     was  your  role  in that work group, sir?

 i    As a regional  representative we were asked to

     help develop an  Enforcement  Response Policy or

     make amendments  to  the existing Enforcement

     Response  Policy  that  was in  place.   As part of

     the  requirements of going through it,  we looked

     at existing Enforcement Response Policies under

     the  statutes as  well  as the  new requirements that
                   •V*
     were required  under EPCRA for  purposes of 313

     reporting to make modifications to  the

     present-day Enforcement Response Policy.

Q    How  long  did the work group  exist?

A    The work  shop  — excuse me,  the work group

     started in April of 1991 and we concluded with

     our final  product around July  of '92.

     Now, when  the  work  group formulated the

     Enforcement Response  Policy, were there statutory

     factors such as  the ones that  Mr. Smith just

     discussed  and  the ones that  are found in the

     statute?   Were those  taken into account?

     Yes, they  were.
                    L^ourt IKeportina
                     MIDCITY PLACE
                       115 EAST DOUGLAS
                        WICHITA, KANSAS 67202
                         TELEPHONE (316) 267-1201
000236

-------
                                              53
Can you tell us why you would take  those  factors

into account?

The first responsibility as  far  as  the

Enforcement Response Policy  is actually to

determine if a violation exists.  It's basically

broken down into three considerations whether  or

not the company is in compliance with the

existing Act, whether or not the violations

warrants a notice of non-compliance for minor

deviations of the rule, and  the  third one is a

policy to establish an administrative action in

which the heart of the Enforcement  Response
              v«*
Policy is about.

Now, Mr. Hirtz, I would like to  go  through the

statutory factors and just would like for you  to

explain how was the nature of the violation

considered when the work group assessed the

penalty?

The nature was basically setting up that  an

administrative action or civil penalty is

warranted, and then we developed the use  of the

circumstance levels and the  extent  levels to

develop the gravity penalty  matrix  for the  final

establishment of determining a penalty for  the

appropriate violations of the Act.
               C,ourt
MIDCITY PLACE
 115 EAST DOUGLAS
   WICHITA, KANSAS 67202
   TELEPHONE (316) 267-1201
                                            ______
                                            000237

-------
                                              54
How was circumstances  of the violation

considered?

          THE WITNESS:  Do you mind  if  I  stand?

          THE COURT:   Please.

For the circumstances  we basically broke  it down

into six different  levels, and these were the

levels that we were looking at.  As  far as

Level 1 is a failure to report in a  timely manner

which is a Category 1.  It's principally  that

companies fail to submit a TRI report or  a Form  R

as required under EPCRA.  And the reason  that

this is the most significant of  the  violations is
              V
that this is a chemical specific reporting

requirement if they meet the conditions of the

law.

          This information is used by both EPA in

the local communities  for purposes of emergency

planning and right-to-know.  And emergency

planning at least on the federal side we  use it

for initiatives like the environmental  justice,

we use it for purposes of pollution  prevention

planning, and the community has  the  opportunity

to gather chemical  specific information on the

chemicals themselves as well  as  the  emissions for

their community so  they themselves  can  take an
                      \\.eporting
                 eruice
MIDCITY PLACE
  115 EAST DOUGLAS
   WICHITA, KANSAS 67202
   TELEPHONE (316) 267-1201
                                               000238

-------
                                              55
active role in exercising change  or  identifying a

dialogue with industry  itself  to  make  hopefully

useful changes that  are occurring in the

community.

          Level  2  is  failure to supply

notification.  And this is the primary avenue

that we use to help  the manufacturers  who  use

toxic chemicals  in a  process to know that  they're

required to report under EPCRA 313.

          It requires that if  you receive  a

product from a manufacturer as far as  a raw

material that you're  using in  your process that
              ••*
identifies that  chemical that's within that

product as subject to reporting under  the

EPCRA 313 provisions.   So we have requirements  in

which we can enforce  the manufacturers to  notify

their customers  that  these chemicals are indeed

regulated by law.

          Level  3  deals with data quality

violations.  It  is the  responsibility  of EPA as

well as for the  industry to submit a Form  R  and

take a look at making sure that the  emission

estimates are performed correctly.  If emission

estimates are done incorrectly, basically  you're

making a faulty  data  base with information that
               (_ourt  Keporting
                MIDCITY PLACE
                  115 EAST DOUGLAS
                   WICHITA, KANSAS 67202
                    TELEPHONE (316) 267-1201
              353
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                                              56
may be  skewed.  So we also  perform  data quality

inspections  at  sites to ensure  that the

information  submitted by  industries are correct.

           And the last one  is a Level  4,  failure

to report  in a  timely manner, and this is a

Category 2.  Category 2 is  basically when the

information, which is the Form  R, is submitted

within  the course of a year to  EPA.  It is still

late  after the  deadline reporting date of

July  1st.

           The relevance for a Level 4  versus a

Level 1, if  the information is  submitted after a

year, EPA  is not able to  put this information

into  the toxic  release inventory which is the

computer system.  This computer system is used to

help  organize and identify  information associated

with  the submissions from industry.  Now, this

organization is used to help develop national

reports as well as state  diskettes  which the

communities  as well as the  general  community use

to help identify the emissions  in their

geographical location.

           Now if the information is submitted

within the year, EPA has  the ability to help

speed along  getting this  information into the
                     l^enortina
ervice
                MIDCITY PLACE
                  115 EAST DOUGLAS
                   WICHITA, KANSAS 67202
                    TELEPHONE (316) 267-1201
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                                              57
national report, so the harm  is much  less  if we

receive it shortly after the  deadline reporting

date, but as the days extend  getting  closer to a

year it impedes the EPA by trying  to  get that

information into the system.   So that's why

that's set up as a Level 4.

          Level 5 and Level 6  are  pretty much

voluntary disclosure violations in which EPA has

been notified by the facilities that  they  should

have submitted Form R's and they are  making the

step forward by giving the information to  the

EPA.
              V*
Okay.  Thank you.  Hr. Hirtz,  can  you also

explain to us how the extent  of the violation was

taken into consideration by the work  group?

For the extent, we're looking  at three primary

issues as far as the amount of chemicals that are

otherwise used or processed at the facility for

setting up thresholds.  For otherwise used

there's a 10,000-pound threshold and  for

manufacturing and processing  it's  a 25,000-pound

threshold.  So we're looking  at whether or not

ten times or more of that threshold of that 313

chemical substance was handled by  the facility.

          This was set up in  order to help
               C^ourt Keporting
                MIDCITY PLACE
                  115 EAST DOUGLAS
                   WICHITA, KANSAS 67202
                    TELEPHONE (316) 267-1201
                355
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                                                   58
      identify what  the potential for exposure could be

      at  the  plant due to material handling operations.

      If  it increases  by greater than ten times the

      amount,  the potential for exposure to the general

      employees is much more.   Also,  it helps identify

      that they were significantly over the threshold

      requirements as  required by the rule.  We also

      look at 50 employees or  more to help identify

      that quite a few employees had  the potential to

      be  exposed to  this chemical substance during th.e

      handling practices.

                The  other requirement that we deal with
                   ••*
      is  the  identification of $10 million in corporate

      sales.   This is  the opportunity to help identify

      large corporations from  small corporations

      because  we did not want  to have economic

      considerations used against small businesses.  We

      wanted  to identify larger businesses from small

      businesses.  And those were the three conditions

      that we  looked at.

Q     What about the gravity of the violation?

A     The gravity of the violation is used to take a

      look at  the circumstance levels as well as the

      extent  levels  to develop a matrix to help

      determine the  appropriate penalty for those  two.
                     \_ourt  importing Service

                      MIDCITY PLACE
                       115 EAST DOUGLAS
                        WICHITA, KANSAS 67202
                         TELEPHONE (316) 267-1201
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                                              59

Now, you heard  the testimony provided by
Mr. Smith  concerning other factors that is part
of the statute.   Did the work group consider
those other  factors, adjustment factors?
Yes, they  did.   Those factors were put into place
to help the  EPA look at the conditions associated
with those factors to aid the EPA in settling
cases.
Do you mind  just going through each one of the
factors we're talking about, culpability, ability
to pay.
Factors that we looked at were primarily the
attitude.  As far as other adjustments, we also
looked at  the culpability, whether or not the
chemical involved was a de-listed chemical.
Also, the  other adjustment factors included SEPs
as far as  supplemental and environmental
projects.
           MS. FAIN:  Your Honor,  I have no other
     questions.
           THE COURT:  Ms. Hoffman?
           MS. HOFFMAN:  I have two questions,
     Mr. Hirtz.
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                                                   60


                   CROSS  EXAMINATION

BY MS. HOFFMAN:

Q    First  of  all,  I  wanted to  ask you,  are you

     familiar  with the National Emission Data System

     maintained  by the USEPA?

A    As  required under the  Clean Air Act?  Is that the

     one you're  referring to?

Q    I'm referring to the data  system referred to in

     correspondence from the State of Kansas received

     by  the respondent.

A    I have a  general familiarity with that data base.

Q    Assuming  that the chemical reported to the State

     of  Kansas were in fact the same chemicals

     subsequently reported  on Form R, is the

     information available  — or the information in

     both systems that's available to the community,

     is  it  fair  to say that that information is

     identical?

A    No.

Q    Is  it  fair  to say that the information is

     summarized  in such  a way so that the community in

     which  the business  is  located has an indication

     of  the chemicals that  are  being used by the

     facility?

     No.
                                      eri/ice
MIDCITY PLACE
 115 EAST DOUG LAS
   WICHITA, KANSAS 67202
   TELEPHONE (316) 267-1201
                                                  000244

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    UNITED  STATES ENVIRONMENTAL PROTECTION AGENCY
                       REGION VII
                  726  MINNESOTA AVENUE
               KANSAS  CITY,  KANSAS 66101

                BEFORE THE ADMINISTRATOR
In the Matter of:
GEC PRECISION CORPORATION     )  EPCRA Docket No
WELLINGTON,  KANSAS            )  VII-94-T-381-E
                   Respondent.  )
                   February 29,  1996

                       9:30 a.m.

                    Wichita,  Kansas

                 APPEARANCES
                   •»••
           Appearing as Administrative Law Judge,

Carl C.  Charneski, United States Environmental

Protection Agency, 401 M Street, S.W., Washington,

D.C., 20460.

           Appearing on behalf of the United States

Environmental Protection Agency, Anne E. Rauch,

Assistant  Regional Counsel,  and I. Pearl Fain,

726 Minnesota Avenue, Kansas City, Kansas 66101.

           Appearing on behalf of GEC Precision

Corporation,  Patricia A. Hoffman, A. B. Dick Company,

5700 West  Touhy Avenue, Niles,  Illinois 60714-4890.
                     C,ourt
                      MIDCITY PUCE
                       115 EAST DOUGLAS
                        WICHITA, KANSAS 67202
                         TELEPHONE (316) 267-1201
000245

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                                                               353
  1           A    Yes,  I was.
  2           Q    And also of  the amending  complaints that are
  3      before the Court today,  is that correct?
  4           A    Yes,  that's  correct.
  5           Q    In the course  of preparing  those  complaints,  did
  6      you have an occasion to  calculate a penalty for  both
  7      Respondent Group Eight and Respondent Wausau?
  8           A    Yes,  I did.
  9           Q   . And did you  consult any guidance  or the
 10      assistance of any internal  EPA  document with regard to
 11      calculating that penalty?
 12           A    Yes,  I  used  the  Polychlorinated Biphenyls
 13      Penalty  Policy  of April  9,  1990.
 14                MR. WAGNER:  Your Honor,  I  would  tender  to the
 15      Court Complainant's  Trial  Exhibit #20.  Provide  a  copy to
 16      the court  reporter,  to each Counsel.  I would identify
 17      this  document as  Polychlorinated Biphenyl Penalty  Policy
 18      of the United States Environmental  Protection Agency dated
 19      April  9,  1990.
20                JUDGE  LOTIS:   The document  will be so
21      identified.
22                              (Whereupon,  Complainant's Exhibit
23                              #20 was marked for
24                              identification.)
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  1      BY MR.  WAGNER:
  2           Q     Mr.  Bonace,  could you tell us what the
  3      Polychlorinated Biphenyl PCB Penalty Policy of U.S.  EPA
  4      is, this Exhibit 20?
  5           A     Pardon me?
  6           Q     What is Complainant's Trial  Exhibit 20?
  7           A     That is the  Polychlorinated  Biphenyl  Penalty
  8      Policy.
  9           Q     What is the  significance  of  this  document to  the
10      work  you've  been doing in  the  PCB unit?-
11           A     This is the  document I would use  for  developing
12      penalties  for  PCB complaints.
13           Q     Could you  give us  a  brief  description of the
14      breakdown  of the PCB Penalty Policy?
15           A     The  Penalty  Policy has two basic  sections; the
16      Gravity  Based  Penalty  and  adjustment factors  to the
17      Gravity  Based  Penalty.
18          Q     What -is the  standard  procedure in the PCB unit
19      of using that  Penalty  Policy to calculate penalties of
20      enforcement actions?
21          A     The  procedure  is the  review  the inspection
22      reports  involved in  the  case and to  apply the Penalty
23      Policy to  problems described in the  inspection  reports.
24          Q     Did  you have an  occasion  to  determine, with
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                                                               355
  1      regard  to  the  complaint  you  were  preparing  against
  2      Respondent Wausau, what  violation to allege  in the
  3      complaint?
  4          A     Yes,  I did.
  5          Q     What violation did you determine to allege in
  6      the complaint?
  7          A     Improper disposal.
  8          Q     Is that the only violation in your preparation
  9      of the  complaint against Respondent Wausau?
 10          A     Yes,  it is.
 11          Q     Did  you have an occasion to assess a penalty for
 12      that complaint  or that violation also?
 13          A     Yes,  I did.
 14          Q     And  could you tell us how you did that using the
 15      Penalty Policy?
 16          A     Okay.  The first thing to do is to develop the
 17      Gravity Based  Penalty using the penalty matrix and extent
 18      and circumstances.   The circumstances which are found on
 19      Page 10 and 11  describe major disposal as a Level 1
20     violation.   Extent,  which involves the amount of material
21      in a particular violation for disposal violations is found
22     on Page 6  and 7.  Since the situation with Wausau involved
23     greater than 25 gallons, quite, a bit more than 25 gallons
24     of PCB fluid, that violation is of major extent.  When you
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 1      refer  to the matrix on Page 9 you see that major extent,
 2      level  1  is a $25,000 penalty.
 3                JUDGE LOTIS:  What about the one you previously
 4      referred to,  this major disposal  is that also in the
 5      matrix?
 6                THE WITNESS:  In the matrix it says level 1,  if
 7    '  you  look there on Page 10.  Level  1  lists a number of
 8      types  of -violations.
 9                JUDGE LOTIS:  Level 1  relates  to — I  see.  You
10      viewed this as a major disposal.
11                THE WITNESS:  Yes.
12                JUDGE LOTIS:  That  was  because  why?
13                THE WITNESS:  All  PCS violations  are considered
14      to be  the most serious violations  at 'level  V and there  is
15      really no alternative  .for  disposal.  There  is a minor
16      disposal  in which a PCB article has a  small  leak on the
17      surface.
18                JUDGE LOTIS:  This  was  a level  1  for what
19      reason?
20                THE WITNESS:  Because PCB oil was taken out of a
21       transformer and shipped for  disposal  to  a facility that
22      was not  designed to handle PCB disposal.
23                JUDGE LOTIS:  It would  be  level  2 if what had
24      happened?
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  1                THE WITNESS:  Okay, there  would  be  no  instance

  2      of  disposal  that  would fall  in  level  2,  but there are

  3      examples  of  level  2 violations  involving failure to

  4      register  a PCB transformer with the  local  department and

  5      such.

  6                JUDGE LOTIS:  I see.  Please proceed.  Thank

  7      you.

  8      BY  MR. WAGNER:

  9          Q     Mr.  Bonace, with regard to the nature of the

 10      violation, what would be the nature of the violation?

 11          A     All  PCB violations are considered chemical

 12      control in nature.

 13          Q     Did  you have an occasion to review the

 14      adjustment factors set forth in the Penalty Policy?

 15          A     Yes, I did.

 16          Q     On what page are those found?

 17          A    Adjustment factors begin on Page 14, the bottom

 18     of Page 14.

 19          Q    What is the first adjustment factor?

20          A    Culpability.

21          Q    And where is that found?

22          A    On Page 15.

23          Q    What were your considerations with regard to

24     culpability as an adjustment factor?
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  1           A     Culpability did not change  the  Gravity  Base
  2      Penalty  of $25,000.
  3           Q     Did you consider any —
  4                JUDGE LOTIS:   (interrupting)  Excuse me, what
                                                •
  5      does  that  mean?  What you just said I just don't
  6      understand.
  7                THE WITNESS:   When  you calculate the $25,000
  8      penalty, then you look  at these other factors to see if it
  9      should be  increased or  decreased.
10                JUDGE LOTIS:   Or stay the same.
11                THE WITNESS:   Or stay the same.
12                JUDGE LOTIS:   And what did you say as to
13      culpability?
14                THE WITNESS:   It did not change the penalty.
15                JUDGE LOTIS:   What does that mean in terms of
16      their culpability?
17                THE WITNESS:   Well,  okay,  I  can  explain  that.
18      If you look on  Page 14 there are three levels of
19     culpability.   Level 1 is a willful  violation and level  2
20      is the violator had knowledge or control and that's where
21     the penalty stays the same.  Level  3 is, lack knowledge,
22      lack control  and  still the violator was reasonably prudent
23     and responsible.  Then there's an opportunity for  lowering
24     the penalty as  much as 25*.
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  1                JUDGE LOTIS:  Alright,  please  proceed.

  2      BY MR.  WAGNER:

  3           Q     Now,  $25,000  is the  maximum  penalty  permitted on

  4      the TSCA 4 violation, is that  correct?

  5           A     That's correct.

  6           Q     So it was  impossible for  you to consider

  7      increasing this penalty.

  8           A     That's correct.

  9           Q     Why did you decide not  to decrease the penalty

 10      because  of the  culpability factor?

 11           A     Because it appeared  that the violator had

 12      knowledge  that  PCB's were on site.

 13           Q     What  did you base that  determination on?

 14           A     I  had  received a letter from Wausau  responding

 15      to my letter to  Mr. Schrott in which I informed him of the

 16      PCB transformer  on his property.

 17          Q     Would  those be the two  letters you just earlier

 18      identified in your testimony?

 19          A     Yes.

20          Q     That would be Complainant's Trial Exhibit #14

21     and Complainant's Trial  Exhibit #19?

22          A     I  see  14 on the letter  to Mr. Schrott.  I don't

23     see a number on  the Wausau letter.

24          Q     The Wausau letter of —
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                                                               360
  1           A    (interrupting)  Of April 10, 1989.
  2           Q.    With regard to the next adjustment factor,  can
  3      you identify that for us under the Penalty Policy?
  4           A    That is history of prior violations.
  5           Q    How are you to consider the history of prior
  6      violations in regard to penalty?
  7           A    This considers whether the  company had a history
  8      of a prior TSCA or particularly a PCS violation.
  9           Q    What happens if they did have a prior violation?
 10           A    In certain circumstances, the penalty would go
 11      up 25,  50 or 100%.
 12           Q    What if they did not have a history of  a prior
 13      violation?
 14           A    The penalty would remain unchanged.
 15           Q    Did you have knowledge of any prior violation of
.16      Wausau?
 17           A    No, I did  not.
 18           Q •   With regard to the next adjustment factor, would
 19      you  identify that for us,  please?
 20           A    That's ability to continue  in business.
 21           Q    What page  is that on?
 22           A    That's on  the bottom of Page 16.
 23           Q    Did you consider that adjustment factor in
 24      Wausau's penalty?
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  1           A    Yes, I did.

  2           Q    What was your determination there?

  3           A    This section refers to whether the payment

  4      penalty would cause a  business to have to close.   I  saw no

  5      evidence that Wausau could not afford to pay this penalty.

  6           Q    When did you calculate this penalty,

  7      approximately?

  8           A    I  don't recall  the  date.   I imagine it  was in

  9      late '89 or  early '90.

 10           Q    It would be  shortly before the filing of the

 11      initial  complaint,  is  that correct?

 12           A    Yes,  that's  correct.

 13           Q    Subsequent to the time  that you initially

 14      determined this penalty and particularly this adjustment

 15      factor,  had  you come into  any information through pre-

 13      hearing  exchanges  or any other exchange  of information

 17      during the course  of these cases  that would  cause you to

 18      change your  determination  as  to this adjustment factor,

 19      the ability  to  pay?

 20          A    No,  I did not.

 21          Q    Mr. Bonace,  are  there any  other adjustment

 22      factors  that you considered?

23          A    No other adjustment factors appeared

24      appropriate.
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 1          Q    With  regard  to  your  penalty  calculations —
 2               JUDGE LOTIS:   (interrupting)   Excuse me.  On
 3     that last question  and  answer,  on  Page  17 of the policy
 4     statement,  it has the  heading,  other factors.  Are you
 5     saying you  considered  them and  found no  adjustment was
 6     appropriate  based on these factors?
 7            -   THE WITNESS:  Yes, that's correct.
 8               JUDGE LOTIS:  Alright.
 9     BY MR.  WAGNER:
10          Q    Mr. Bonace,  let me ask you to  just be a little
11     bit more specific,  there are some  specific factors set
12     forth here with regard  to attitude at the bottom of Page
13     17.
14          A    Yes.
15          Q    Did you consider that specifically with regard
16     to the Wausau penalty?
17          A    Yes,  I did.
13          Q    why did you determine not to make any reduction
19     for attitude?
20          A    Because it did not appear that the violator was
21     making good  faith efforts to comply with the PCB
22 '    regulations.
23          Q    With  regard to voluntary disclosure at the top
24     of Page 18.
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  1           A    Wausau, as I recall, did not voluntarily
  2      disclose the problems that occurred.
  3           Q    With regard to the cost of  the violations to. the
  4      government.
  5           A    This refers to cost expended in an
  6      administrative proceeding under Section 16 of TSCA and I-
  7      knew of no such cost.
  8           Q    With regard to economic benefit of non
  9      compliance.
 10           A    I knew of — I did not know  of any economic
 11      benefit of non compliance.
 12           Q    With regard to Group Eight,  the complaint
 13      against Group Eight,  did you have an occasion to develop
 14      that complaint also and determine the  violations to  be
 15      alleged in that complaint?
 16           A    Yes,  I  did.
 17           Q    How many  violations did you  include in Group
 18      Eight's complaint?
 19           A    Six,  I  believe.
 20           Q    And were  any of those six violations the same
 21      violation  as  was  alleged in  Wausau's complaint?
 22           A    Yes,  Count  6 was the same, improper disposal.
 23           Q    With regard to the Gravity Base of- the penalty
24      for  that particular violation.   For the record,  I  would
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  1      just  that would be Count 6 of the complaint,  violation  for
  2      unlawful  disposal.   With regard to that  violation, was
  3      your  calculation of the Gravity Base component  of the
  4      penalty  the  same as you testified to in  Wausau?
  5           A     Yes,  it is.
  6                MR. WAGNER:   Your Honor,  I would ask  the Court
  7      and Mr.  Christensen if  they would want him to restate that
  8      Gravity  Base component?
  9                JUDGE LOTIS:   No.
10   "   BY MR. WAGNER:
11           Q     Mr. Bonace, with  regard  to the other five
12      violations that were alleged  in the Group.Eight complaint,
13      Count 1,2,  3,  4, and 5, could  you  indicate how you
14      calculated the  penalty  pursuant to the Penalty Policy with
15      regard to  those violations?
16           A     Yes,  I  will.   Count 1, was there a Count 1?
17           Q     Yes.   Count 1  was the failure to dispose of one
18      PCB transformer and two PCS contaminated transformers
19      within one year of  placement  in storage.  Violation of 40
20      CFR 761.65-A.
21           A     The transformers  on the  Group Eight property
22      were  in storage at  least since  the  fire  in 1987 and from
23      that  date  to the date of our  first inspection exceeds one
24      year, the  maximum time  allowed  for storage for  disposal of
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  1      a PCS article.   That type  of  violation,  the  circumstance

  2      for that type of violation is found  on  Page  12.   It's a

  3      level 4- violation.   It's the  first number  3  you  come to on

  4      Page 12 —  excuse me, the  first number  2,'  storage.

  5           Q   Toward the top of the page?.

  6           A   That's right.  Storage of  PCB  in excess of one

  7      year is the level 4  violation.

  8           Q   The circumstances of that  violation?

  9           A   That  is the circumstance.  Level 4, the extent.

 10           Q   The extent, yeah.

 11           A   Okay.  -The extent for the  storage violation was

 12      significant because, as you see on Page  4 of the Penalty

 13      Policy,  the gallonage of PCB fluid in the transformers

 14      exceeded 220  gallons but was  less than 1100 gallons.

 15      From  that,  looking at the matrix for a level 4 significant

 16      extent  violation you have a $6000 penalty.

 17           Q    With  regard to Count 2 of  the  complaint against

 18      Group  Eight,  it  alleges that Group Eight stored one PCB

 19      transformer and  two PCB contaminated transformers in a

 20      facility lacking a roof, walls, and  an impervious floor

21     with  6  inch continuous curbing in violation of 40 CFR

22      761.65.B-1.    Can you indicate how you calculated the

23     gravity base  of  that violation?

24          A    Certainly.  Storing PCB articles in a  storage
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  1      area that lacks a roof, walls, and 6 inch curbing of

  2      impervious floors is a level 2 violation.  These

  3      transformers were stored out of doors without any roof,

  4      walls or curbing..

  5           Q    Where on the policy do you find it's a level  2?

  6           A    On Page 11, the first number 5 you come to it

  7      says, major storage.

  8           Q    And further components?

  9           A    The extent is the same as the previous

 10      violation,  the same equipment was involved.   Greater than

 11      220 gallons, less than 1100.   If you look on the matrix

 12      then you see that a level  2 significant extent violations

 13      has a $13,000 penalty.

 14           Q    With regard to Count 3 of the complaint which

 15      alleged that Group Eight did not mark its PCB transformer

 16      or  PCB contaminated transfo-mers with the date they  were

 17      placed in storage for disposal  in violation  of 40 CFR

 18      Section 761.65 C-8.   Can you indicate to the Court how you

 19      calculated  the gravity component of that?

.20           A    Yes.  Like  Count 1,  this is considered a minor

 21     -storage,  as you see on Page 12,  #2, minor storage and the

 22      extent is the same as the previous two violations;

 23      significant because the same equipment is involved and  you

 24      have a $6000 penalty  for a level 4 significant extent.
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                                                               367
          \
  1           Q    With  regard  to  Count  4  of  the  complaint against

  2      Group Eight  it  alleged that  Group Eight  failed  to marked

  3      its  PCB  transformer  with  a PCB  label,  a  violation of 40

  4      CFR  Section  761.48 2.   Could you  indicate'how you

  5      calculated that penalty?

  6           A    Yes,  I can.   The transformers  on the  Group Eight

  7      property had no PCB  labels, no  official  PCB  label  or any

  8      PCB  label  of any kind.  That is considered major  marking

  9      where  someone unfamiliar with the equipment might  not be

 10      aware  there were PCB's.  That's found on Page 11,  the

 11      first  number 4, major  marking.  It's a level 2  violation.

 12          Q     The extent?

 13          A     The extent is significant because the PCB

 14      transformer contained  236 gallons and the range for

 15      significant extent is  220 to 1100 and therefore,  you have

 16      a level 2  sicnificant extent.  $13,000 penalty  for that

 17     violation.

 18          Q    With regard to Count 5 of the complaint  against

 19     Group Eight which alleged that Group Eight did  not mark

20     the PCB storage area with the PCB label in violation of 40

21     CFR .Section 761.4810.  Would you indicate to His  Honor how

22     you calculated that gravity component?

23          A    Yes,  I can.  That also is considered  major

24     marking like the previous violation, level 2, and that's
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                                                               368
  1      found on Page 11.  The extent is the same as the previous
  2      several  violations because the same gallonage for the
  3      transformers involved is of significant extent and in the
  4      matrix you see level  2 significant extent'has a $13,000
  5      penalty.
  6                JUDGE LOTIS:  Counsel,  are these all  involved
  7      with  the  same equipment,  the same 3?  Are all  counts
  8      directed  toward the same 3 transformers?
  9                MR.  WAGNER:   Yes,  Your  Honor.
10                THE WITNESS:  If I may?
11                JUDGE LOTIS:  Please explain, yes.
12                THE WITNESS:  The  one count  for the failure to
13      mark  the  PCB transformer  involves the  one transformer.
14                JUDGE LOTIS: Which count  was that?
15                THE WITNESS: Count 4,  I believe.  Because
16      transformers that contain  less than  500 parts per million
17      do not require that label.
18                JUDGE LOTIS:  Thank you very much.
19      BY MR. WAGNER:
20          Q     Mr.  Bonace,  in connection  with  your work with
21      the PCB unit you  have  worked with PCB  rule on numerous
22      occasions  I  take  it,  is that correct?
23          A     Yes,  that's  correct.
24          Q     Are  there are  any  presumptions  that  are  provided
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                                                               369

  1      for under the PCB rule?

  2           A    Yes,  there is a — one of the presumptions

  3      involving transformers?

  4           Q    Yes.

  5           A    A mineral  oil  transformer that has not  been

  6      tested for PCB's is  assumed  to  be PCB  contaminated  and

  7      contain a level  of PCB  concentration ranging between 50

  8      and 500 parts per million.

  9           Q    With  regard to  nameplated PCB transformers such

 10      as  Askarel,  are  there any  presumptions  there?

 11           A    Yes, a nameplated  transformer is always

 12      considered  to be greater than 500,  usually quite a  bit

 13      greater  than  500 parts per million  and  therefore a  PCB

 14      transformer  by definition.

 15          Q    Did you  utilize any of  these  presumptions  with

 16      regard to  any of the 7 transformers on  the Great Eight

 17      property as with regard to any of these penalties?

 18          A     I did  utilize those presumptions in addition to

 19      some other  information.

20          Q    And what was the other  information you had?

21          A    There  were some tests,  some PCB samples that

22     were run at the  expense of CIW Company  of the equipment on

23     Group  Eight property.

24          Q    How did  you come to have  those results?
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                                                               370
 i           A    Those results came to us through an inspection
 2     at CIW Company.
 3           Q    Do you know who conducted the  inspection?
 4           A    I  believe  that was Patricia Spitzley.
 5           Q    Do you recall  who did the analysis  that was
 6     provided  in  those inspection reports?
 7           A    The company was called,  I believe,  Dihydro — I
 8     can't remember the second part.
 9           Q    In any event,  the results were part of the
10     inspection report you prepared.
11           A    Yes,  they  were.
12           Q    And that you reviewed.
13           A    Yes.
14           Q    I'd now 1 ike to move,  Mr.  Bonace, to the
15     adjustment factors with  regard  to  the penalty calculated
16     for Group  Eight.   When you considered adjustment factors
17     for Group  Eight  did  you  consider adjustment factors in the
18     same  fashion,  taking  all  six  counts in the complaint into
19     consideration?
20           A    Yes.   They  all  were considered to have the same
21      adjustment factor.
22           Q    Could  you  run  us through your consideration of
23     the adjustments  factors?
24           A    As you see in  the complaint, the gravity base
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                                                                371

  1      penalties did remain in the complaint so no adjustment

  2      factors were applied.  Culpability,  the penalty was not

  3      lowered because I felt the violator  had knowledge or

  4      control.  I had spoken to the owner  myself and written him

  5      a letter about the PCS equipment on  his site.

  6           Q    With regard to history of  prior violations.
  7           A    I knew of no history of prior violations by

  8      Group Eight.

  9           Q    So no adjustment was made.

 10           A    So no adjustment was made  for history.

 11           Q    With regard to ability to  continue  in  business.

 12           A    I was never given any information that  Group

 13      Eight could not continue in business after paying the

 14      penalty.

 15           Q    Subsequent  to the preparation of the complaint

 16      against  Group  Eight and the filing of the complaint

 17      against  Group  Eight,  have you  ever been provided  any other

 18      information or has  U.S.  EPA been provided any  other

 19      information, to your  knowledge,  concerning Group  Eight's

20      financial  status that would cause you to change  your

21      determination  with  regard to this factor?

22           A     No.   To my  knowledge,  U.S.  EPA has  received  no

23      other  information to  change the ability to pay.

24           Q     Are  you familiar with the  documents provided in
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                                                               372
 1     Group  Eight's pre-hearing exchange?
 2          A    Yes,  I  am.
 3          Q    So  your statement  includes  those  documents.
 4          A    Yes.
 5          Q    With  regard to other factors as justice may
 6     require  did you consider those with regard  to Group Eight?
 7          A    Yes,  I  did.
 8          Q    Specifically with  regard to attitude at the
 9     bottom of  Page  17?
10          A    The penalty was not changed for attitude.
11          Q    And why  is that?
12          A    It  did  not seem appropriate to lower the penalty
13     for good faith  efforts to comply with the appropriate
14     regulations.  As  to raising them, I did not choose to do
15     that.
16          Q    And with regard to voluntary disclosure?
17          A    To  my recollection, Group Eight did not disclose
18     these  violations  to the EPA.
19          Q    With  regard to cost of violation to the
20     government?
21          A     This  does not appear to apply to Group Eight.
22          Q    And with regard to economic benefit of non
23     compliance?
24          A     Once  again it does not appear to  apply.
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                                                               373

  1           Q    Were there any other considerations you made

  2      with regard to Group Eight's penalty?

  3           A    Not that I recall.

  4.           Q    With regard to the penalty against Wausau

  5      Insurance Company,  you prepared the  amended complaint or

  6      were involved in  the preparation of  the  amended  complaint?

  7           A    Yes,  I  was.

  8           Q    Is the  penalty proposed in that  complaint the

  9      same as  in the  original  complaint?

 10           A    Yes,  I  believe so.

 11           Q    $25,000?

 12           A    Yes,  to my recollection, yes.

 13           Q    And with  regard to the  various penalties  for the

 14      six  counts  in Group  Eights' amended  complaint, did  those

 15      proposed  penalties  remain the same as in the  original

 16      complaint?

 17          A     I  believe  they  remained the same.

 18               MR. WAGNER:  May I just have on  brief  moment,

 19      Your Honor.

20               Your Honor,  I  have no further questions of  this

21      witness.

22               JUDGE LOTIS:   Before cross examination, let's

23      take a recess.  My.watch  says  it's about 5 after 10:00,

24      let's come back at  20  after  10:00-
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         \         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
% -V\i7^ j            •           WASHINGTON, D.C. 20460
 %* ^^^^^^^^^^^^^ j«!*                      '
                                     MAY'2 8 1
                                                                          .  OFFICE OF
                                                                         ENFORCEMENT AND
                                                                       COMPUANCE ASSURANCE.
  MEMORANDUM
  SUBJECT:   Interim Guidance on Administrative and Civil Judicial Enforcement Following
               Recent Amendments to the Equal Access to Justice Act  '     •  •  •.
  FROM:
               OflBce of Regulatory Enforcement   .    .        •              .  .

  TO:          Regional Counsels, Regions I - X -             '
               Director, Office of Environmental Stewardship, Region I
             - Director,' Division of Enforcement and Compliance Assurance, Region
               Director, CompUance Assurance & Enforcement Division, Region VI
               Director, Office of Enforcement, Compliance & Environmental Justice,
               Region VH!                 .                   .       .
               Regional Enforcement Coordinators, Regions I-X
  A.    INTRODUCTIOI!

        On March 29, 1996, President Clinton signed into law H.R. 3136, the Small Business
  Regulatory Enforcement Fairness Act ("SBREFA"), P.L. 104-121, which had been added as an
  amendment to legislation raising the federal debt limit.  ORE has been working closely with
  representatives of other OECA offices, a number of EPA regional offices, as well as the .
  Department of Justice on implementation of this new law. SBREF A contains numerous
 . provisions which will affect the manner in which the Federal government conducts enforcement
  against small businesses and small communities, and requires the Federal Government to
  implement, a number of programs within one year of enactment. However, some provisions are
  effective immediately.  In particular, sections 331 and 332 of the law amend the Equal Access to
  Justice Act1 <"EAJA") to allow the awarding of attorneys fees to non-prevailing parties in an   .
  administrative or civil judicial enforcement action.
        1      28 U.S.C. § 2412; 5 U.S.C. § 504.  See also 40 C.F.R. § 17 (Implementation of the
 Equal Access to Justice Act in EPA Administrative Proceedings).   -•
                                  .                              • ^                          " -
                         N   ' "•                       '                . ' *

 ;        .   -•     .'..:•    ;  •'••   3«     '•"  •'..''       .'•''.':    :     '  000276
             R»cycl«d/R»cycUW» . Printed with Vegetable OH Based InKs on 100% Recycled Paper (40% PosJconsumer)  .

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        This memorandum is intended to provide interim guidance to reduce the Agency's risk of
 creating a cause of action in an administrative or judicial penalty action under SBRJEFA's
 amendments to the EAJA. This guidance does not address whether EAJA claims may apply to
 corrective action orders or cost recovery actions.  These issues will be dealt with in a subsequent
 guidance being developed by the Office of Site Remediation Enforcement (OSRE).

        Attached to this memorandum is-a summary of some of the other provisions of SBREFA
 that are significant for enforcement purposes (see Attachment 3).  As we work through these
 additional provisions, in conjunction with OECA's Office of Planning and Policy Analysis, we
 will provide further guidance and information as appropriate.     .  .

 B.     BACKGROUND ON CHANGES TO EQUAL ACCESS TO JUSTICE ACT

        The revisions to EAJA made by SBREFA are a- significant departure from the current
 state of EAJA law, which in general allows only a "prevailing party" to recover attorney's
 fees where  the position of the government is riot substantially justified.  Sections 331 and 332
 of SBREFA amend the EAJA to allow the award^of attorney's fees to a non-prevailing party2 in
 an administrative or civil enforcement action where "the demand by the agency is substantially
 in excess of the decision of the adjudicative officer3 and is unreasonable when compared with
 such decision, under the facts and circumstances of the case." "Demand" is defined in both
 sections as "the express demand" of the United States or Agency "which led to the adversary
 adjudication," but excludes "a recitation of the maximum statutory penalty" in the administrative.
 or civil complaint "or elsewhere when accompanied by an express demand for a lesser amount."
 Because section 504 of EAJA defines an adversary adjudication as "an adjudication under
 section 554 of this titlei "* this provision may apply to any administrative enforcement action
       2      For purposes of these subsections only, a "non-prevailing parry" must be a "small
entity" as defined by § 601 of Title 5.  "Small entity" includes, but is not limited to, small non-profit
organizations not dominant hi their fields, small governmental jurisdictions up to 50,000 in          - .   '
population, and small businesses ranging up to 1,500 employees and up to S25 million in annual  '
receipts.  Under the applicable Small Business Administration regulations, different criteria apply to
different SIC categories. See. Small Business Size Regulations, 61 Fed. Reg. 3,286 (January 31, 1996)
(to be codified at 13 C.F.R. § 121).

       3       Or, in the case of a civil judicial action subject to § 332, "the demand by the United
States is substantially in excess of the judgment finally obtained by the United States-." The
"legislative history" generated after passage of the legislation of SBREFA suggests that "demand"
includes the value of any injunctive relief.  See 142 Cong. Rec. S3242 (daily ed. March 29,
1996)(statement of Sen. Bond);  142 Cong. Rec. E571-573 (daily ed. April 19, 1996)(statement of
Rep. Hyde). Please consult with ORE prior to relying on this.
                 '.             *              •                 ••**,"•
       *       gee 5 U.S.C. § 504(b)(l)(C).          ;                "    ,         '


                   :  "  -      "    -                             '•.    Q0277

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         .     •   .             •                     .     '    •
         to be .brought using procedures subject to § 554 of the Administrative Procedure Act.
 (APA), as well as to any civil judicial complaint filed on or after March 29,  1996.
 1          . •     .        .

   '    SBREF A may allow a party which has been adjudged fully liable for violations of an  •
 environmental law to recover attorney's fees for its defense against the action if the court or
 adjudicating officer finds that the Agency's penalty demand was unreasonable and excessive,
 based on 'the record and the facts and circumstances of the case. , As a result, in order to
 minimize the risk of a finding that the agency's penalty proposal is both unreasonable and
 excessive, agency practitioners should continue to make reasonable and appropriate proposals
 for specific penalties based upon the best evaluation of the facts at hand, the statutory penalty
 factors, and the applicable penalty policies. However, this new law creates additional exposure
 to EAJA awards as a result of Agency litigation, and concerns about possible awards may affect
 litigation decisions. With this in mind, Agency practitioners should consider the following
 options in preparing for litigation, drafting a complaint, and responding to EAJA claims


 C.     ADMINISTRATIVE  ENFORCEMENT
                                *   * •        -^              .
        '.                                        .             .'           -"'
 1-      Maintain Consistency With Current Procedures    "

        Implementation of SBREF A, and the changes to EAJA, are not incompatible with strong,
 fair and effective enforcement.  As noted above, we are confident that our current practice of
-proposing specific penalties in administrative complaints, consistent with applicable EPA
 pleading penalty policies, will not result in significantly increased exposure to possible EAJA
 awards under SBREF A. In this regard, we urge the Agency's litigation teams and managers to
 craft complaints and develop litigation strategies with an awareness of the changes, but do not
 hesitate to initiate an action or to seek penalties for clear violations. Please continue to develop
 proposals for civil penalties that are reasonable and appropriate to the facts and circumstances of
 the case. In addition,-it is highly advisable to include as standard language in any consent
 agreement a statement that each party agrees to bear its own costs and fees.

 2.   .   Options Where Ability to Pay and Other Factors Are Uncertain

        As a general practice, we recommend that the litigation team identify and assess all
 information relevant to liability and the proper amount of a penalty prior to issuance of a
 complaint.  If your preparations do not produce enough reliable information to develop a
 defensible, specific proposed penalty amount, you should consider one of the following three
 options:         '                         .
   • '   . '* ••    5 U.S.C. § 55 1 et. seq.  Thus, formal administrative enforcement actions brought
using the Consolidated Rules of Practice at 40 C.F.R. Part 22 may be subject to an EAJA claim.
                                                                                  000278

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  a.      Issue a Pre-filing "Show Cause'"or Settlement Letter Seeking Additional
         Information on Penalty Issues.          .   •    .

       •  Prior to filing a complaint, issue a pre-filing "show cause" .or settlement letter in
  which  the respondent is asked for any relevant information (including inability to pay)
  EPA should consider in determining an appropriate penalty.  We advise practitioners to
 . be cautious about including specific penalty proposals in these pre-filing letters.  If, after
  such information is received, settlement does not occur, this information will assist in
  developing a more accurate, appropriate, and defensible penalty proposal for the
.  complaint.  Some Headquarters and Regional offices have adopted this practice, and it
•  appears to work well, -A model letter is attached for your consideration at Attachment 1.

  b.      Reference A bility to Pay, Affirmative Defenses in Letter Accompanying the
         Complaint or in the Complaint Itself...         '  ...

         In a cover letter accompanying a complaint, or in the complaint itself, state
  clearly that the penalty proposed may be adjusted if the respondent establishes bonafide
  issues of ability to pay, or other defenses  relevant to the appropriate amount of the
  proposed penalty. Consider indicating in the complaint that the proposed penalty was
  developed  based upon the best information available to the Agency at the time, and in
  consideration of the statutory factors, etc.' Such indications may be relevant to the "facts
  and circumstances" language of SBREFA referenced above, and may work to mitigate
 .the amount of any EAJA fee award. Model complaint language is attached as  .
  Attachment 2.    •                  •     .     -
                                '             *  .  »
  c.      Use "Notice Pleading" for the Penalty    '           •            .     .      .

        In cases where information relevant to proposing an appropriate penalty  cannot be
' obtained before issuing the complaint  and there are nonetheless reasons to proceed with •
 the action,  the litigation team should consider "notice" pleading — that is, pleading "up to
 the statutory maximum amount"  for each violation alleged. This notice pleading
 approach would not eliminate the need to make a definite penalty proposal, but would
 postpone it until full information about the case, including all violations and respondent's
 defenses, are known, so that the Agency can produce better informed penalty proposals.
 Note, that if a respondent defaults by failure to answer, it will be necessary to develop a
 specific penalty proposal in the motion for default judgment, in order to comport with the
 current default procedures in 40 C.F.R. § 22.17(a), which assume a proposed penalty in
the complaint. In any event, a specific penalty  proposal and argument.will still have to
be developed for the purposes of a hearing. Sample language for notice pleading in    ;
administrative complaints is included in attachment 2.
                                                                               000279

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 3.  •   Adjust the Penalty Proposal as Necessary    ...       -          ..      '    '

   .  •   In the event of an EAJA claim, the Agency may be able to successfully argue that the
 assessed penalty should be compared to the Agency's best offer before an adjudication, rather "
 than the penalty initially proposed in the complaint or in any pre-filing proposal. In all cases,
 attorneys should ensure that the respondent receives a written proposal containing a specific
 penalty amount based on the most current assessment of all the facts in the case before each
 adjudication occurs. 'This proposal should be made as far in advance of the adjudication as
 possible. Of course, whenever the Agency's understanding of the facts and legal issues in a case
 changes in such a way as to significantly impact the appropriate settlement penalty, the Agency
 should present the respondent with a written revised settlement offer.    .        .  r

 D.     CIVIL JUDICIAL ENFORCEMENT

        When referring a civil judicial action to the Department of Justice (DOJ), any proposal
 made by EPA in a pre-filing negotiation must be disclosed to DOJ, including any proposal'    ;
 related to injunctive relief.6. Informing DOJ of any Agency proposal made prior to referral is
 essential to allow the Department to assess the potential for EAJA concerns in each case. In
 addition, where the SIC code for the defendant is known, or an analysis of the defendant's
 classification as a "small entity" has been made, please include that information in the litigation
 report forwarded to DOJ so that the Department will be on notice that the defendant may be
 eligible under EAJA for a possible fee award.                 .                          :

 E.  '   NEXT STEPS.       .    "     •                  •

        Additional guidances and updates will follow as we move to implement SBREFA's
 provisions.  In the meantime, if you have questions regarding SBREFA's impact on
 administrative or judicial enforcement, contact Robert Kinney (202-564-3712), Scott Garrison
 (202-564-4047) or David Hindin (202- 564-6004). If you have questions about other aspects of
 SBREFA implementation, please contact Kate Perry, who is in OECA's  Office of Planning and
 Policy Analysis (202-564-4059), or the appropriate ORE division.      .             [

 Attachments (3)

 cc:     OECA Office Directors
        ORE Division Directors
        ORE Branch Chiefs          '
        Deputy Assistant Attorneys General/Environment and Natural Resources Division, DOJ
        Section Chiefs, Environmental Enforcement and Environmental Defense Sections, DOJ
'        6      See m. 3, supra.; regarding the relationship between "demand" under SBREFA and
 injunctive relief sought.         '„•'.••

:'•••*'•'''    .'   ••       '             :"  •'••-;      .'         .     000280

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                                    .   Attachment 1

                              EXAMPLE PRE-FHJNG LETTERS

 Example 1                        -.-.'..           '

 Dear_ _ :       .   ,                  •'"'••                •       ''        :
      ~~~~~~~~         •            .     •        •     .      .                     i

       .This is to notify you that the U.S. Environmental Protection Agency is prepared to bring a
 civil administrative or judicial enforcement proceeding against [name] for violations of the [statute].
 The complaint will allege that [name] has violated [section] of the [statute], and [regulation section],
 in that [name][ describe violation]. The complaint will seek civil penalties for these violations.

        Before filing the complaint,' however, we are extending to you the opportunity to advise the
 Agency of any factors you believe that the Agency should consider before issuing the civil
 complaint  Relevant factors might include any evidence of reliance on compliance assistance
 provided by EPA or State agencies exercising delegated authority, misidentification of the proper
 party, or financial factors bearing on your ability'to pay a civil penalty. Even if you are unaware of
 any mitigating or exculpatory factors, we are extending to you the opportunity to commence     •
 settlement discussions concerning the above-described violations.

        It is our intention to file the civil administrative complaint two weeks from today, unless you
 first advise us of substantial reasons not to proceed as planned. Please direct your response to [name,
 address, phone number]. Thank you for your prompt attention to this matter.
    The Environmental Protection Agency ("the Agency") has reason to believe that [name] may be in •
- violation of the Federal Insecticide, Fungicide and Rodenticide Act ("FIFRA" or "the Act") for
 selling and distributing a pesticide in violation of FIFRA § 12(a)(l)(Q-.

    Under § 12(aXl)(Q of FIFRA, it is unlawful for any person to distribute or sell any registered
 pesticide the composition of which differs at the time of its distribution or sale from its composition
 as described in the statement required in connection with its registration under section 3 of the Act.
 FIFRA § 2(gg) defines "To Distribute or Sell" as "to distribute, sell, offer for sale, hold for •
 distribution, hold for sale, hold for shipment; ship, deliver for shipment, release for shipment, or    .
 receive and (having so received) deliver or offer to deliver..:.".      .        .
       .          •                       '                             /
    The Agency has learned that [name], a registrant as defined hi FIFRA §2(y), may be selling and/or
 distributing a registered pesticide, the composition of which differs from the composition as   .
 described in .the confidential statement of formula submitted in connection with the product's
                                                                            ;   000281

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 «.* wAuwi.w&iueui. owuv/ii. rtii  ciuurwcmeiu action mciuaes an audit, on-site inspection,- compliance,; :>i:.
 assistance effort, or other enforcement related communication...." This does riot appe'ar'jto be limited'^
 to past and/or completed actions, but applies at any-point in the enforcement proce^^uiciuding'^>;B
.while the case is in active litigation, There is also a provision made for a: business •wfech'is curently.^
 being enforced against to-make a'confidential referral to the T~ —L J-J-'X--   -'• " -: ^ - r- - - -  -•    -  .*&
 legislative history likens this'to a "customer satisfaction" index. .The-boards must be esteblished 1
 the'SBA within 180 days after enactment. ...i.  '.-.' ,•" 'J\ ;./'.'•' ( ;•.:.- '.'-  T=;^--."^^>?S^i^^^.;^^^r

 3. .  •-"• Rights'of Small Entities iff Enforcement Actions    / •    ;   . ,.•  .'-••':  ' '•^'.•:^'.?:'^]l^J: "••. />.'"
  '   •'  ; OECA's June 1995 Interim Policy on Compliance Incentives for Small Businesses, is  '-.-'* .,
 essentially codified, by Section 323 of the Act (the legislative history indicates that the policy satisfies  •
 the section's requirements).  Accordingly, while this section directs that each covered Federal ; y. . '.'•
 agency to establish a program within one year to implement this section, EPA has already done this,."
 although a final version of the Interim Policy will be issued shortly. In addition, the Policy on ..s  . :  .
 Incentives for Self-Policing (the Audit Policy) also appears to satisfy the criteria in this section of the  .
 hewjaw/-;' i  .-..,' ' .•  ' ..'-M-- •' -..'  .••-'.-'  "   :'.  "_  '"'.:•••'   .'':;. 7;".v-> *'.'y-z£/---;.~ -.•'''.' "•"•".;
 4.  •    Other Enforcement Impacts  .     .. •       •  ''     .'  .-  '  '   .  ^-..-..      .

       • Because the Act is still being analyzed* the full extent of its impact remains to be determined.;;
 However, the provisions of more immediate concern are, hopefully, noted above. There are other
 provisions which raise enforcement concerns - such as the termination under Section 342 of ongoing
 and future enforcement actions brought under a rule for which a court has found that Regulatory ;
 Flexibility Act adherence was not sufficient.  Many of the Act's other provisions affecting     f
 enforcement seem to -be focused on changes to the rulemaking process, provisions for legislative veto
 of new rules, etc.   •"     .,••'.     '   '•          ,  .'    '•.--••'• ••}'' •">•.   '    ';  ..-.
                                      Attachment 3.-Page 2

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registration. Specifically, it has come to the Agency's attention that [product name] may have been  "
formulated with [chemical] as an active ingredient, which was not registered with the Agency. ?

   Therefore, the Environmental Protection Agency requests that your company submit to this office
within fifteen (15) business days of receipt of this letter the following information regarding the
above named products. Provide all records and documents relating to:          . •  '    •     . -

       1.    .the dates of sale and/or distribution of the product,             •  '    .      .

       2.     the quantity (pounds or gallons) of products sold and/or distributed,  '  ..      •-.   •••
  . •                                    •                                      '','''
       3.     the locations of all sale and/or distribution sites,'   •               •-'    ,.-..'•    •
                                     '             *.           •        •       "           %*'.

       4.   •  all shipping records,    .   '         '     ' .          -            '   .     .

       5.     a copy of the full product labeling associated with the product,         '  • .  •      '

       6.     any product packaging inserts or flyers used in "the marketing aspects;of the product,

       7.     any information that would indicate the source of the [chemical] as an active    .  .
              ingredient used in the production of the [pesticide product],                 •

       8.     product chemistry and physical characteristic data supporting [pesticide product] as.
              being similar or identical in composition or labeling to EPA Registration [number],

       9.     the  process used to produce [chemical] as an active ingredient, and

       10.    your legal relationship to [affiliated corporation]    ;               .  •

   Following receipt of the requested information, the Agency may wish to meet with representatives
of [name] to further discuss this matter and allow [name] additional opportunity to show cause why
the Agency should not proceed with enforcement action.   :

       Please direct your response to [name, address, phone number]. Thank you for your prompt
attention to this matter.
                                     Attachment 1 - Page 2
                                                        .         -.   '        00028.2;

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                               ;       Attachment 2

                        EXAMPLE'NOTICE PLEADING LANGUAGE
Exairrale 1:  •
     .  ;  -.- ...        ;            .    . CIVIL PENALTY .  '..  •       ..'.".'•'  I,  r-  '  .   •
   .'   Section 14(a)(I) of FIFRA, 7 U.S£. Section 1361(a)(l), authorizes the assessment of a civil
penalty of not more than $5,000 for each violation of FIFRA. The penalty assessed must reflect the
size of the business of the person charged, the effect on the person's ability to continue in business,  '
and the gravity of the violation. ./^  •  •'••. ' .'.      .  •    ...   '. •    '       '; 5.-.  '-.

Example 2:    •           i •'    ••   .       ..."   •       .    .. • '  '•  ••  •

   •'.  ..        '     '•            '   CIVIL PENALTY   ;     •  •-.   " ..
.  •  • .  Section 16 of TSCA, 15 U.S.C. Section 2615, provides that any person who violates TSCA
shall be liable for a civil penalty in an amount not to exceed $25,000 for each violation, and that each
day a violation continues shall constitute a separate violation of TSCA. The penalty assessed must
reflect the nature, circumstances, extent and gravity of the violations, and, with respect to
•Respondent, ability to pay, effect on ability to continue to do business, any history of prior such  «
violations, the degree of culpability and such other matters as justice may require.

Example 3: '        .      -. •     .     •         "                 .  •
                                     .  Civil Penalty          . .  •  .
       Pursuant to Section 309(g)(2)(B) of the Clean Water Act, 33 U.S.C. § i319(g)(2)(B), any
person who has violated [insert appropriate statutory requirement of the Act] may be assessed a civil
penalty by the Administrator that may not exceed $10,000 per day "for each day during which the
violation continues,.as long as the total amount of such a penalty dpes not exceed $ 125,00.0.
Therefore, Complainant requests that the Administrator, after consideration of the statutory
assessment factors set forth at Section 309(g)(3) of the CWA, 33 U.S.C. § 1319(gK3), assess a civil
penalty against Respondent of up to $ 10,000 per day for each day during which a yiolation(s) cited in
this complaint continues.  '          .                                      ..        -•
                                                                           . 000283

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                    — Potential Evident!
                                       Attachments                      ;

                              OTHER PROVISIONS OF SBREFA            V          -
                             ' "     '                * . ;         •         ••...'   '•..".•.."•'••   !• - - • '"
        SBREFA has a very broad reach, and will likely apply to a sizable percentage of the regulated
 community. It applies to all "small entities," as that term is defined in 5 TJ.S.C. §. 601,15 U.S.C. § , -
 632, and in SBA regulations codified at 13 C.F.R, Part 121. The universe'of "small entities" is larger ' ;
 than the definition used in Section 507 of the Clean. Air Act and OECA's "Policy on ComplianceV •;':::
 Incentives for Small Businesses," both of which use a 100-employee limit. .The SBA regulations  '-• '-^-l
. define "small" by reference to either a company's number of employees .(e.g., up to ,1500, oir greater) '"••*••
 or a. company's annual receipts (up to $25,000,000),.depending on me company's SIC code,! "The; ; • ''> " •"
 Act's definition of "small entities" also includes "small governmental jurisdictions" (smaikr'than ?'..V • '
 50,000 persons), and "small organizations" (eig., non-profits), further expanding the reach of this :::' =- -";
 Act SBREFA requires the Agency to establish within a year of enactment a number, of programs to'""'-!;'.
-benefit this segment of the community, some of which are summarized below!'

 1.

        Section 313 of SBREFA requires each department and agency of the Federal government to
 establish a program to "answer inquiries" or give "advice" on "interpreting and applying the law &
 specific sets of facts" provided by a small entity. The legislative history indicates that this provision
 contemplated a range of mechanisms, many of which are already commonly used by .the Agency to -
 provide this kind of information, including the use of hotlines. However, the effect of this land of    .
 guidance hi an enforcement action may have been given greater weight by a provision specifying mat
 "pjn any civil or administrative action against a small entity, guidance given by an agency applying   .
 the law to facts provided by the small entity may be considered evidence of the reasonableness... of
 any... fines, penalties or damages...."  Given the informal nature of some forms of advice   .    '
 provided by different parts of the Agency (both Regional- and Headquarters-based), this has the
 potential to affect an enforcement case involving a violator who was provided with an inconsistent or
 erroneous interpretation of law as applied to the facts at issue. Whether this provision in feet imbues  •
 such advice with any greater evidentiary weight than already afforded under current law is an open
 question.       .                    .                              .'_'"..'•

       Nevertheless, this provision tends to highlight the issues which might arise in an action
 involving a party who had relied hi good faith on erroneous advice or guidance provided by the
 Agency.  However, because the Agency has in place a number of Headquarters and Regional-based
 mechanisms to provide advice and guidance to both large and small entities, this provision raises the
 potential for forum-shopping by a business. As such it will place a premium on the Agency's ability
 to ensure a reasonable consistency in interpretations when a business" is provided with guidance that
 qualifies under this section. The "program" to be established under this section for responding to.
 inquiries must be established within 1 year.      '            '.   ; ,;  .  '      '"...'.          • .;

 2.     Oversight of EPA Enforcement Personnel bv the SBA  -'	   .       ;    . :.     •'.   •
                            *  . "*                  *    ' '      "•' •• v  "    •     •'      *      • *
       Section 322, on "Oversight of Regulatory Enforcement" by the Small Business '   :.     •
 Administration, establishes regional boards chaired/run by the Small Business Administration, and  .
tA

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