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Seriousness <br />P&N disagreed with the proposed civil penalty. Tn their opinion, <br />the seriousness was low. The NOV was directed only at the <br />missing flow data, which was merely a trickle, for June, 1994 <br />from site TR-b. Using the staff gauge would have provided <br />invalid data. They felt a more accurate analysis could be <br />obtained using a regression equation if necessary. One month of <br />missing flow data does not constitute a serious violation. <br />Based on the information presented in the conference, i propose <br />to reduce this component to $500.00. A file memo indicates the <br />proposed assessment for seriousness considered the past history <br />and questionable data collected from site TR-b. However, this <br />NOV was directed only at the missing flow measurement from <br />June,1994. The flow was a trickle which could not be recorded <br />using the permitted equipment at the time. To me, this <br />represents short duration, with moderate extent. The extent <br />considers that the loss of this data impacts not only the PHC for <br />the mine site but the cumulative hydrologic impact statement all <br />along Trout Creek. <br />Fault <br />I agree with the proposed penalty. <br />Good Faith <br />I am not recommending a good fait <br />data can never be retrieved. P&M <br />data and will start collecting the <br />location. <br />h reduction because the lost <br />did however, obtain the July <br />August data at the new <br />Settlement Agreement Penalty 51250.00 <br />