RESPONDENT VIOLATED AOS ISSUED BY EPA IN DEC. 1999 AND JAN. 2000 FOR FAILURE TO address MCL violations. EPA proposed initial civil penalty in the amount of $25,000 but at the request of the VIDOE, reduced the penalty to $2,000 when VIDOE made an inability to pay argument and supported that argument with cost documentation in excess of $50,000. Because VIDOE's actions undertaken to adddress violations and to prevent future violations went beyond the requirements of the AO, EPA agreed to settle the matter with a civil penalty in the amount of $2,000.00.