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 to Cold Creek. Therefore, a score of 1 was assigned to this factor.
Susceptibility to Cleanup or Abatement. A score of 0 is assigned for this factor if 50 percent or more of the discharge is susceptible to cleanup or abatement. 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 by the discharger. For Violation No. 1, VVWRA recovered 8,602 gallons of the 8,832 gallons that initially spilled. Therefore, a factor of 0 is assigned. 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 4 was calculated. The total score is then used in Step 2, below.
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. (1)
(1) applies. For the January 14, 2017 SSO, the Discharger reported that 5,000 gallons of untreated sewage spilled from the collection system, of which 4,000 gallons discharged into Chorro Creek. None of the sewage in the creek was recovered. A score of (1) is assigned.
Susceptibility to Cleanup or Abatement. 0 Potential for Harm Final Score: 4
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. 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. The Discharger did not undertake any known cleanup activities to address the discharge of storm water runoff. Pollutants discharged into the riparian drainage at the south termini would have been difficult to cleanup. Therefore, a score of 1 is assigned because less than 50% of the discharge was susceptible to cleanup.
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. 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 asserts that the entire spill was cleaned up. While it is probable that a portion of the spill was recovered, Board staff contends that less than 50% of the discharge was susceptible to cleanup or abatement, as described below. Therefore, a score of 1 was assigned to this factor. Central Valley Water Board staff maintains that full recovery of an entire spill volume within the creek would be infeasible three days after the spill occurred given prevailing precipitation and flow conditions. To confirm conditions along Arcade Creek at the time of the spill, precipitation and discharge measurements were obtained from the California