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1 i <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 $250. 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 />