Further Improvements Needed in the Administration of RCRA Civil Penalties
TABLE OF CONTENTS
CHAPTERS
Background
Scope and Methodology Prior Audit Coverage
2.RECOVERING ECONOMIC BENEFITS OF NONCOMPLIANCE IS ESSENTIAL
Improvements Needed In Recovering Economic Benefits of Noncompliance
Table: Review of Economic Benefit Calculations
Penalty Amounts and Compliance Not Found Related
More Guidance and Training Needed for Assessing Economic Benefits Recommendations
3.STATES NEED MORE CONSISTENT RCRA PENALTIES AND BETTER DOCUMENTATION
State Penalty Policies Vary
Gravity-Based Penalties Vary Among States
EPA Penalties Have Been Significantly Higher
Table: Average Final Penalty Amounts
Conclusions
Recommendations
EPA Effectively Documenting Penalties, While Some States Need Improvement
State Documentation Efforts Varied Depending on Penalty Policies
Table: State Documentation of Penalty Calculations and Adjustments
Conclusions
Recommendation
APPENDIX I - Scope and Methodology
APPENDIX II - Prior Audit Coverage
APPENDIX III - Analysis of Penalties and Compliance
APPENDIX IV - Report Distribution
Created April 14, 1997