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concurrent Technical Revision 48 (TR-48) and Minor Revision 194 (MR-194) applications. 15 Ju12005 issuance of Notice of Proposed Amount of Civil Penalty, Request for Conference. 20 Jul 2005 assessment conference held. 22 Ju12005 transmittal of the Settlement Agreement and the Settlement Agreement Justification by the Division to the Company. 29 Jul 2005 acceptance of the Settlement Agreement and the Settlement Agreement Justification by the Company 1 Aug 2005 the Division found the TR-50 application complete, subsequent to receipt of missing information. 2 Aug 2005 request by the Company to extend the time of abatement to October 7, 2005 (received at the Division on 3 Aug 2005). A summary of actions and schedule to complete abatement of Part (2)(b) is as follows: 08 Aug 2005 current due date for abatement 30 Sep 2005 due date for a proposed decision on TR-50. accomplishment of the abatement work. 07 Oct 2005 proposed extended abatement date requested by the Company. I have reviewed the Company's request to extend the time of abatement for Part (2)(b) and find it meets the requirements of Rule 5.03.2(2) for approval. A summary of this review follows: Rule 5.03.2(2)(c) provides for extension to abate within 90 days if the delay was not intentional or caused by a lack of diligence by the Company. There is no evidence that the Company intentionally delayed the remedial action. The Company timely abated Part (1) of the Notice of Violation, and has timely addressed the abatement of Part (2) in due process as allowed by the Rules. Rule 5.03.2(2)(c)(i) provides for extension to abate when the Company has diligently pursued necessary approval of designs or plans, but such permit or approval will not be issued within 90 days. Within 29 days the Company designed abatement work and submitted a technical revision application (TR-50) for approval. However, the Division found the application incomplete. The Company submitted missing items and the Division found the application complete. Within 41 days the Company exercised its right to request an assessment conference. The conference was held and findings issued in due process. The permittee has, as demonstrated above, diligently pursed approval of the abatement action. Extent of coordination and public review, schedules, and levels of approval authority vary between technical revisions and minor revisions. TR-50 changes pages of the Permit Application Package that were already in process, but not yet approved, under TR-48 and MR-194 applications. Within 70 days, the Company, in coordination with the Division, established a hierarchy and propriety of approvals for the three concurrent revisions that would allow TR-50 to proceed to proposed approval. The current due date for TR- 50 proposed approval is 53 days past the current abatement date. 4 August 2005, page2 of 3 pages, R. W. Cattany