MEMORANDUM OPINION
EMMET G. SULLIVAN, District Judge.
Plaintiff Howmet Corporation ("Howmet") appeals a final decision by Defendant United States Environmental Protection Agency ("EPA") penalizing Howmet $309,091 for violations of the Resource Conservation and Recovery Act and the Hazardous and Solid Waste Amendments of 1984, 42 U.S.C. §§ 6901 et seq. (collectively "RCRA"). Howmet claims the penalty is arbitrary and capricious under...
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