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1 I • • <br />the point that no impacts are apparent; therefore the monitoring <br />(in hindsight of course) was not required. I am not sure how one <br />could come to this conclusion since the data to analyze was not <br />collected. I agree that the timing of the events make the <br />violation seem administrative and procedural. However, a conscious <br />decision to not conduct monitoring was made by COVCC without any <br />type of consent from the Division. Furthermore, this failure to <br />monitor continued after the operator was aware that the Division <br />could only reduce monitoring by a technical revision. Also, the <br />operator had a period of 16 months to act on the result of our 1992 <br />meeting but chose not to go through the proper procedure until 1993 <br />was essentially past. It would not be fair to the operators who are <br />religiously conducting their required monitoring to ignore the <br />seriousness of this violation. <br />If you have questions or need clarification, please let me know. <br />