Susceptibility to Cleanup or Abatement. A score of 0 is assigned for this factor if 50% or more of the discharge is susceptible to cleanup or abatement. A score of 1 is assigned if less than 50% of the discharge is susceptible to cleanup or abatement. This factor is evaluated regardless of whether the discharge was actually cleaned up or abated by the discharger. In this case, less than 50% of the discharge was susceptible to cleanup or abatement as the wastewater entered Xxxxx Drain. Therefore, a factor of 1 is assigned.
Susceptibility to Cleanup or Abatement. The Enforcement Policy specifies that if 50 percent or more of the discharge is susceptible to cleanup or abatement, then a score of 0 is assigned. A score of 1 is assigned if less than 50 percent of the discharge is susceptible to cleanup or abatement. This factor is evaluated regardless of whether the discharge was actually cleaned up or abated. For Violations 1 through 8, the discharges were not susceptible to cleanup or abatement and are assigned a score of 1. In each instance, the discharged material flowed into and commingled with ambient receiving waters. There was no opportunity for abating the effects.
Susceptibility to Cleanup or Abatement. A score of 0 is assigned for this factor if 50% or more of the discharge is susceptible to cleanup or abatement. A score of 1 is assigned if less than 50% of the discharge is susceptible to cleanup or abatement. This factor is evaluated regardless of whether the discharge was actually cleaned up or abated by the discharger. In this case, less than 50% of the discharge was susceptible to cleanup or abatement as the wastewater entered Xxxxx Drain. Therefore, a factor of 1 is assigned. Final Score – “Potential for Harm” The scores of the three factors are added to provide a Potential for Harm score for each violation or group of violations. In this case, a final score of 6 was calculated. The total score is then used in Step 2, below.
Susceptibility to Cleanup or Abatement. A score of 0 is assigned for this factor if 50% or more of the discharge is susceptible to cleanup or abatement. A score of 1 is assigned if less than 50% of the discharge is susceptible to cleanup or abatement. This factor is evaluated regardless of whether the discharge was actually cleaned up or abated by the discharger. In this case, the Discharger did not clean or xxxxx any of the sewage discharged from either discharge point. The Discharger did use chlorine to sanitize areas where the spill occurred but was not able to recover any of the actual discharged sewage, therefore, a score of 1 was assigned to this factor.
Susceptibility to Cleanup or Abatement. For Violation No. 2, the discharge persisted for more than six days before it was discovered, and the material was directly discharged into a wetland tributary to the Mojave River. Due to the volume discharged, the chlorinated effluent flowed directly into the Mojave River and is not susceptible to cleanup or abatement. A factor of 1 is assigned.
Susceptibility to Cleanup or Abatement. For Violation No. 3, VVWRA recovered 184,078 gallons of the 405,957 gallons that overflowed from manhole No. 73. Therefore, a factor of 1 is assigned.
Susceptibility to Cleanup or Abatement. For Violation No. 4, all of the discharge flowed into adjacent storm drain inlets and into an actively flowing wash. The amount of water flowing in the wash during this period was significant to such a degree that it posed a danger to VVWRA personnel. The discharge was unrecoverable, and therefore a factor of 1 is assigned.
Susceptibility to Cleanup or Abatement. For Violation No. 5, all of the raw sewage discharge flowed directly into the Mojave River. The discharge was unrecoverable, and therefore a factor of 1 is assigned. Lahontan Water Board staff acknowledges that VVWRA had offered to install a hypochlorite station adjacent to the spill site. However, Lahontan Water Board staff advised against installing such a system (January 4, 2011 electronic mail).
Susceptibility to Cleanup or Abatement. The Susceptibility to Cleanup or Abatement factor is assessed as either 0 or 1. A score of 0 is assigned if the discharger cleans up 50 percent or more of the discharge within a reasonable amount of time, whereas a score of 1 is appropriate where less than 50% of the discharge is susceptible to cleanup or abatement, or if 50% or more of the discharge is susceptible to cleanup or abatement but the Discharger failed to cleanup up 50 percent or more of the discharge within a reasonable
d. Final Score – “Potential for Harm” The scores of the factors are added to provide a Potential for Harm score for the violation. Here, the Potential for Harm score is 6.
Susceptibility to Cleanup or Abatement. The Enforcement Policy specifies that if 50 percent or more of the discharge is susceptible to cleanup or abatement, then a score of 0 is assigned. A score of 1 is assigned if less than 50 percent of the discharge is susceptible to cleanup or abatement. This factor is evaluated regardless of whether the discharge was actually cleaned up or abated. The discharge was not susceptible to cleanup or abatement and is assigned a score of 1. The discharged material flowed into and commingled with ambient receiving waters. There was no opportunity for abating the effects of the discharge of 406,000 gallons of polluted stormwater to the Bay.
