A RCRA CEI was accomplished on 12/8/2003. An NOV was isssue to Circuit on 8/24/2004 for violations of the contingency plan requirements, training requirements, manifesting requirements, notification requirements, and tank requirements. A show cause meeting was conducted on 12/22/2004. Based on several documents submitted by Circuit to the US EPA throughout the enforcement process, the penalty was assessed at $8,321. A 10% reduction was given to Circuit based on their good faith efforts and cooperation to come into compliance prior to the issuance of this CAFO.The final assessed penalty was calculated at $7,489.