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<br /> <br />NOV 82-69 Justification of Proposed Settlement Agreement <br />The Division proposed a civil penalty of $2,250.00. I am proposing a <br />reduction of $500.00 in the seriousness component due to facts which <br />have come to light since the Division proposal. The facts indicate a <br />lesser probability of environmental damage than initially thought. In <br />addition, due to the good faith effort by the company since the time the <br />NOV was written, I am proposing a reduction of an additional $500.00. <br />Thus, the total civil penalty is now proposed at $1,250.00. <br />