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Memo to Berhaa Keffelew CC~VG LVSCS ALR Response page 3 the original application, and "above 2 percent exceedence" in Mr. Hardaway's June 13, 1995 letter were unchanged and state: "Advise the DMG and reduce the LVSCS flowrate through the following measures; • reduce head on liner; • plot rate of LVSCS flowrate versus solution elevation; • note when LVSCS flowrate falls within acceptable envelope; and • maintain solution levels within acceptable limits during all periods of operation." Based upon the data submitted by Mr. Hardaway in his response letter to Mr. Keffelew dated April 16, 1997, I conclude that CC&VG is complying with the first two of its four specified response actions. In performing the observations relating to reduction of saturated head versus the rate of LVSCS inflow within the Pregnant Storage Area (PSA), CC&VG has collected the data necessary to show that it cannot plausibly reduce the inflow rate below that specified as the "2$ exceedence" ALR. Finally, CC&VG could not reduce its Phase 2 LVSCS to a level below that ALR without effectively dewatering the entire Phase 2. I cannot concur, therefore, with Mr. Hardaway's statement; "These systems are being operated in compliance with the design specifications and the permit commitments, and the systems are achieving their objective of fluid removal." CC&VG is achieving the objective of fluid removal from the LVSCSs. There has been no evidence of loss of containment or of pressure heads on the lowermost composite liner exceeding the specified 2.0 foot magnitude. However, I cannot conclude that CC&VG has completely satisfied its permit commitments, in that it is not in compliance with all the Response Actions specified for the "2$ exceedence" ALR. A Proposal for Resolution CC&VG now emphasizes its contemporary belief, as expressed by Mr. Hardaway; "The estimates of rates that solutions could be anticipated to occur were not, in themselves, a limit. Rather, they were design criteria." Frankly, I see nothing to be gained by continuing this semantics discussion. Rather I suggest that CC&VG and the Division resolve this situation as follows. (1) The Division has always agreed, and continues to agree, with