1989-12-08_GENERAL DOCUMENTS - C1981017

• Permit No: C1981017
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 12/8/1989
• Doc Name: Bid Documents ‎(IMP)‎
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

Amended Findings of Fact (Exhibit A) , therefore, Mid-Continent
denies these allegations.
--�� 14 'Mid=Con"tinent - admits"the—all--egat-io ig'cont-ained�in
paragraph 14 of the Amended Findings of Fact (Exhibit A) .
15. Mid-Continent denies the allegations contained in
paragraph 15 of the Second Amended Findings of Fact .
MID-CONTINENT ANSWER
TO
NOTICE OF VIOLATION ALLEGATIONS
Mid-Continent hereby answers the allegations contained
in the Notice of Violation, as amended, as follows :
1 . Mid-Continent denies the allegations contained in
paragraph 1 of the Notice of Violation ( Exhibit A ) .
Specifically, Mid-Continent denies that the TSS concentrations
in the effluent from Outfall No. 016 "between January 17 'and
February 23 , 1989" , exceeded the daily maximum concentration
allowed by the permit of 70 mg/l. [Emphasis supplied. ]
2. Mid-Continent admits the allegations contained in
paragraph 2 of the Amended Notice of Violation (Exhibit B) .
3 . Mid-Continent denies the allegations contained in
paragraph 3 of the Amended Notice of Violation (Exhibit B) .
4. Mid-Continent denies the allegations contained in
paragraph 4 of the Amended Notice of Violation (Exhibit 3)_
5. +Mid-Continent denies the allegations contained in
naracraDh 5 of the Second Amended Notice of Violation.
MID-CONTINENT GENERAL AN'D A��'FIRMATIVE DEFENSES
The following general and affirmative defenses are
addressed to the Notice of Violation, dated February 22, 1989
(Exhibit-A) , the Amended Notice of- Violation, =-dated April-- I I , - --- -- -
1989 (Exhibit-B) , and the Second Amended Notice of Violation,
dated June 27 , 1989, each individually and collectively or as
incorporated_ successively into the -must recently filed notice-- -
of violation, and any violation alleged in the Cease and Desist
order or as the same may have been amended.
- Mid-Continent- states and alleges:
1 . The dates that actual samples were taken and shown by
competent analysis to have exceeded the Total Suspended Solids
( "TSS " ) effluent limitation are evidence only that on the
MCR Amended Answer to
2nd Amended NoV - 3 -