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AMERICAN FUELS, INC. PRYOR STRIP C-31-81 Show Cause Order I. Issue - why we're here. An Order to Show Cause was issued to American Fuels, Inc. for the Pryor Strip Mine on May 3, 1985. Board must decide on basis of information presented at this hearing whether permit C-31-81 should be suspended or revoked. Order to Show Cause issued pursuant to Rule 5.03.3(1) after a finding by the Division of a Pattern of Violations in accordance with Rule 5.03.3(2). Pursuant to Rule 5.03.5(2)(c) the permittee was given 30 days written notice of the hearing, and notification of the hearing was published on 6/19/85 in the Chronicle-News (Trinidad). American Fuels, Inc. has been given the opportunity to request a hearing. No such request has been received by the Division. Company Rep in attendance? II. The Division has the option to find a pattern of violations on the basis of more than one violation of similar or different requirements of the act, rules or permit based on two or more inspections of the permit area within a 12 month period. The Division must determine that a pattern of violations exists if there were violations of the same or similar requirements based on three or more inspections during a 12 month period In this case, three patterns have been identified Susan Mowry, the lead specialist for the mine, will present the violations which constitute the pattern, and discuss the facts surrounding them. All of the violations have been through the administrative process with regard to civil penalty assessment and providing for an assessment conference, etc. Introduction, 5 years, lead specialist after permitted, most inspections almost all NOV's in PoV. III. Background A. New Pryor Strip permitted November 9, 1982 by Uiking Succession of Operators applied for by American Fuels August 10, 1983, approved September 22, 1983.