Region 5 filed a Consent Agreement and Final Order (CAFO) with A. Finkl & Sons (Finkl), concluding the proceeding against the Respondent for RCRA violations. Finkl manufactures forging die steels, plastic mold steels, die casting tool steels, and custom open-die forgings. EPAÂs allegations were based on information and documents provided by Finkl during two inspections that occurred on May 31, 2007 and on April 13, 2010, in response to pre-filing settlement discussions, to Notices of Violation, to a Request for Information, and to a Pre-Filing, Notice and Opportunity to Confer Letter (Pre-Filing Letter). In summary, Finkl stored hazardous waste without a permit or interim status. In the Pre-Filing Letter, EPA had proposed an administrative civil penalty of $157,205, which was calculated pursuant to the RCRA Penalty Policy. For the purposes of settlement, a penalty of $104,159 was agreed upon. The penalty reduction is based in part on a re-evaluation of the potential for harm factor for the counts related to the training violations and related to the contingency plan violations.