1993-11-15_PERMIT FILE - C1981017 ‎(2)‎

• Permit No: C1981017
• IBM Index Class Name: Permit File
• Doc Date: 11/15/1993
• Doc Name: Request for federal Intervention ‎(Part 2 of 2)‎
• Media Type: D
• Archive: No

trust was replaced by the performance bond (also secured by a
deed of trust) filed in 1988.
4. Permits issued pursuant to CSCMRA are for a specified
term and must be renewed periodically if operations are to be
continued. § 34 -33- 109(5) & (7), C.R.S. (1984 & 1993 Supp.).
5. An application to renew the permit was filed on or
about December 1, 1987. The application was signed by Robert
Delaney. Item number 5 of the application identified both Mid -
Continent Resources, Inc. and Robert Delaney as the
"applicant /operator ". The application also identified Robert
Delaney as the resident agent, officer, and director of
Resources, and a principal shareholder of Minerals.
6. The 1987 application again identified John A. Reeves as
a director and president of Resources, and as a principal share-
holder of Minerals.
7. The 1987 application further identified defendant Diane
Delaney as the permitting contact for the permittee.
8. The renewed permit was issued on May 31, 1988, and was
signed by Robert Delaney.
9. In 1988, Resources executed a Coal Reclamation Bond For
Use With Deed of Trust - Realty in the amount of three million
dollars, secured by a deed of trust on a piece of industrial
property in Garfield County. The deed of trust had been previ-
ously recorded in 1984. Once again the performance bond was
personally obtained by John A. Reeves who executed the deed of
trust.
10. The amount of the performance bond, and the estimated
cost of performing reclamation as required by CSCMRA and the
permit, is three million dollars. The property described in the
deed of trust covered by the 1988 performance bond includes a
rock dust plant that produces limestone dust. The Coal Basin
Mine used limestone dust in its coal mining operation and was the
primary consumer of the limestone dust produced at the rock dust
plant. The current market value of the rock dust plant is sub-
stantially less than three million dollars.
11. During the course of 1989 and 1990, Division inspec-
tors observed several violations of permit requirements at the
Coal Basin Mine, which violations resulted in a series of Notices
of Violation. On or about July 17, 1990, the Division issued an
order to show cause why permit no. C -81 -017 should not be sus-
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