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page 2 <br /> As a result of the discussion completed on December 19th, it was my <br /> preliminary opinion that Mid-Continent Resources had been performing in <br /> accordance with the approved "Interim Plan". I also realize that the road <br /> system continues to exhibit problems and that the final reclamation of these <br /> roads has yet to be completely resolved. The Division, citing the general <br /> performance standard for stabilization of road cut and embankment slopes has <br /> cited the operator. Assuming that the Division had not previously informed <br /> Mid-Continent that it had modified its stance, I believe that the Division <br /> improperly cited the operator. For this reason, I directed Dan Mathews to <br /> complete a review of the past three years of inspection reports and <br /> correspondence with the operator to determine whether the Division informed <br /> Mid-Continent of a change in our position regarding the Interim Plan. In <br /> order to accommodate this review, I continued the assessment conference until <br /> 1 :30 pm, Tuesday, January 7, 1992 in the Division' s office. <br /> On Thursday, January 2, 1992, Dan Mathews forwarded the attached memorandum to <br /> my attention. This memo presents the results of Dan' s investigation. Dan <br /> determined "that the approved interim reclamation plan allows for sloughing of <br /> both cut and fill slopes" . Further, Dan observes; "I have not found evidence <br /> that the Division indicated specific concerns to Mid-Continent regarding <br /> interim stabilization of cuts and fills prior to a midterm review letter of <br /> April 24, 1991 . . . . There are no specific comments, concerns, or <br /> recommendations regarding revegetation or other stabilization or sediment <br /> control measures for road cut or fill slopes in inspection reports between <br /> 1987 and July, 1991 . " <br /> Based upon the testimony presented during the assessment conference and Dan <br /> Mathews examination of the permit documents, it is my opinion that NOV <br /> C-91-018 was inappropriately issued. The operator, Mid-Continent Resources, <br /> Inc. , was acting in compliance with its approved permit. For this reason I <br /> have decided to recommend vacation of NOV C-91-018. <br /> attachment: <br /> Doc. No: 9240F <br />