Penalty Calculations For Non-Hazardous Waste AEOs . Lisa Brown, Cal/EPA February 2007. What is there when there isn’t a matrix?. The law Your judgment Examples from other programs and/or your neighbors The AEO TAG Some UPAs have their own matrixes for non haz waste programs.
Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author.While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server.
Lisa Brown, Cal/EPA
Example 10 drums w/o lids
Example: 10 drums w/o lids for 2 weeks
in the same facility?
in a different facility (same owner)?
A single initial penalty may be assessed when:
- The facility has violated the same requirement in different location (e.g., units) within the facility.
- The facility has violated the same requirement on different days, unless the facility has been notified of the violation and has had sufficient time to correct the violation.
- Violations that are not independent or are not substantially distinguishable.
Economic Benefit does not include
Probability of violation being detected
If detected, probability of enforcement
If enforcement action taken, probability of penalty
Discount rate (interest)
Time between date of violation
and payment of penalty