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09-24-2018 Council Packet
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09-24-2018 Council Packet
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39. Respondent did not immediately notify the NRC as soon as Respondent had <br />knowledge of the release. <br />40. Respondent's failure to immediately notify the NRC of the release is a violation <br />of section 103(a) of CERCLA, 42 U.S.C. § 9603(a). <br />41. Respondent provided written follow-up emergency notice of the release to the <br />SERC on June 22, 2018. <br />42. Respondent did not provide the SERC written follow-up emergency notice of the <br />release as soon as practicable after the release occurred. <br />43. Respondent's failure to provide written follow-up emergency notice to the SERC <br />as soon as practicable after the release occurred is a violation section 304(c) of EPCRA, <br />42 U.S.C. § 11004(c). <br />Civil Penaltv <br />44. Complainant has determined that an appropriate civil penalty to settle this action <br />is $4,690 for the CERCLA violation. In determining the penalty amount, Complainant <br />considered Respondent's willingness to perform a supplemental environmental project, as well <br />as the nature, circumstances, extent and gravity of the violation, and with respect to Respondent, <br />its ability to pay, prior history of violations, economic benefit or savings resulting from the <br />violation and any other matters as justice may require. Complainant also considered U.S. EPA's <br />Enforcement Response Policy for Sections 304, 311 and 312 of the Emergency Planning and <br />Community Right -to -Know Act and Section 103 of the Comprehensive Environmental Response <br />Compensation and Liability Act, dated September 30, 1999 (EPCRA/CERCLA Enforcement <br />Response Policy). <br />45. Within 30 days after the effective date of this CAFO. Respondent must pay a <br />
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