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controlled Catawba Industries, which received the violations. Even though Mr. <br />Holway held positions with Ziegler Coal Holding Company from 9/18/92 to <br />11/04/96, well after the violations occurred in 1986 and 1987, AVS assumes that <br />the violations could have been remedied while Mr Holway worked for Ziegler <br />Coal Holding Company, but were not. Therefore, Mr. Holway and Seneca Coal <br />Company have been linked to the violations. <br />In the case of the new West Virginia violation, there are many individuals who are <br />associated with Seneca and who have been linked to the violator company, <br />Martinka Coal Company. <br />3. Whatever remedy is sought by Seneca, the information in AVS can only be <br />changed by the States of Kentucky and West Virginia, since they are the ones who <br />input the pertinent violation data to begin with. In this case, Colorado can only <br />check AVS, not change it. <br />I ran a system check of Seneca Coal Company. The system recommendation is <br />"CONDITIONAL ISSUE", which means that a stipulation needs to be attached to the <br />Seneca permit application. The OSM recommendation is "OTHER", which means that <br />there is a link through certain individuals between Seneca and at least one violator <br />company. I have attached several AVS data sheets to this memo, which you can give to <br />Seneca if you would like. One is the system recommendation and another is the OSM <br />recommendation. Ihave also attached the violator organizational tree information for the <br />Kentucky and the West Virginia violator companies. The asterisks in column two of each <br />data sheet show the names that are the links between the violator companies and Seneca. <br />If you need any additional information, please let me know. <br />Attachments <br />c:\wp61\avs\yostmem 1 <br />