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<br />History <br />There was no discussion on this component. <br />Seriousness <br />Based on the information presented in the conference, I believe <br />the penalty should be reduced to $0.00. There was no damage or <br />potential for damage resulting from these ponds. The entire area <br />drains into Pond A, or other sediment control structure. There <br />was no evidence of structural problems related to the ponds. i <br />consider it an administrative violation, in that the Division's <br />policy has changed regarding these structures. <br />ault <br />All operators were notified last November that all impoundments <br />must comply with the certification requirements and the quarterly <br />inspection requirements. The operator had five months to certify <br />ponds, although for most of that time, if not all, the ponds were <br />covered by snow or inaccessible due to the wet conditions. I <br />believe the proposed penalty is appropriate. it represents a low <br />level of negligence. <br />Good Faith <br />At the time of the assessment conference, the NOV had not been <br />abated. A good faith reduction is not recommended. <br />Settlement Agreement Penalty Proposed $250.00 <br /> <br />