Actual cost data supplied by the violator are preferred; however, they are not always provided to EPA. When cost data is not supplied by the violator EPA should estimate the costs as best as possible and document the source data in the case file. For Superfund actions, this cost should be the estimated value of Responsible Party work to be performed as included in the Record of Decision (ROD) or other enforcement documents.
Estimating the cost of injunctive relief/complying actions if a respondent/defendant does not respond to EPA with the cost of compliance
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