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Mid-Continent states and alleges that in December , 1988 the daily <br /> readings -- for high temperature were below freezing 12 days in a <br /> row (December 19-30, 1989) , - and in that period low temperatures <br /> - were below 0�-`Fahrenheit" on=three = days. <br /> ""From—Jan ary-6i 9"- nd'-'�"" <br /> 11-17 , 1989 temperature highs were below freezing, and during <br /> these periods the only high temperature above freezing was 350 <br /> Fahrenheit on January 10, 1989. For nine of the 14 days from <br /> January 6-19, 1989 , low temperatures were below 0' Fahrenheit and <br /> the low average temperature was -10 Fahrenheit . These <br /> occurrences and their cumulative effect were upset conditions and <br /> Acts of God beyond the control of Mid-Continent which affect the <br /> discharge or volume of discharge at Outfall No. 016 and/or caused <br /> the standard of compliance to be measured by other than TSS. <br /> DEMAND FOR HEARING <br /> Pursuant to 11 Colo. Rev . Stat . 5 25-6-603 ( 1982 Repl . <br /> Vol . ) , Mid-Continent requests that the Division conduct a hearing <br /> to determine the validity of the Notice of Violation, the Amended <br /> Notice of Violation, and the Second Amended Notice of Violation, <br /> including all Findings of Fact. <br /> DATED this 25th day of July, 1989. <br /> Respectfully submitted, <br /> DET _ BALCOMB, P.C. <br /> AtZmv",,_ <br /> at Law <br /> By -i'-. <br /> P,d war d "lulna=l, jr. IQ <br /> Regiszra�icn No. <br /> P. 0. Drawer 790 <br /> 818 Colorado .Avenue <br /> Glenwood Snrin_as, CO 81602 <br /> 3 0 3/9 4-5-6 54 6 <br /> Attorneys for Pe-r-mittee , <br /> Mid-Continent Resources, Inc. <br /> MCR Amended Answer to <br /> 2nd Amended NoV - 7 - <br />