Based on information gathered through the request for information, EPA alleges that Eiki World, Inc. (EWI) made three exports of CRTs to Mong Cai City, Vietnam in November 2009, June 2010, and August 2010 and one export of CRTs to Jakarta Utara, Indonesia in February 2010 without notifying EPA. EWI shipped 1,807 units on or about November 28, 2009, shipped 881 units on or about February 11, 2010, shipped 1,016 units on or about June 4, 2010, and shipped 1,117 units on or about August 7, 2011. These shipments violated RCRA Section 3017, 42 U.S.C. § 6938 and the implementing regulation, 40 C.F.R. §§ 262.50 et seq. EPA brought a civil administrative penalty action against EWI to assess penalties for these two violations, under the authority of Section 3008(a)(1) of RCRA, 42 U.S.C. § 6928(a)(1).