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Memo - American Fuels, Inc. -2- May 2, 1985 <br />CO C-85-023 - Issued March 21, 1985, failure to abate NOV C-84-176. <br />Penalty has not been assessed yet. <br />CO C-85-024 - Issued March 21, 1985, failure to abate NOY C-84-177. <br />Penalty has not been assessed yet. <br />Therefore, we have 4 NOV's (C-84-062, C-84-063, C-84-067, C-84-157) relating <br />to hydrologic balance, issued during 3 separate inspection. Two NOV's <br />relating to reclamation bonds, one for roads and one for non-contemporaneous <br />reclamation. We also have one Failure to Abate Cessation Order (FTACO). All <br />of the above have completed the administrative review process, none of which <br />penalties have been paid. Pending are two additional FTACO's. <br />Therefore, based on these facts and the track record of this operator, I <br />believe there is a pattern of violations. I also believe that a show cause <br />order for permit revocation should be issued. I do not feel a suspension <br />would serve any useful purpose. The operator has no assets to complete the <br />reclamation, in my opinion, so there is no sense in giving them any more <br />opportunities to do so. <br />/ph <br />Doc. No. 0038 <br />