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ti <br />Certain items were improperly cited in the NOV and will be excluded <br />by a pending modification. Environmental harm has apparently not <br />occurred as a result of the identified deficiencies and the <br />potential for damage appears to be minimal. I recommend a <br />reduction in the Seriousness component to $i5u.00. <br />Fault <br />I concur with the $250.00 assessment for fault representing a minor <br />degree of negligence. The deficiencies appear to be isolated <br />oversights of minimal environmental significance. <br />Good Faith <br />The NOV has not been fully abated and thus a reduction for good <br />faith cannot be considered. <br />Settlement Agreement Penalty Proposal........$500.00 <br />