_ENFORCEMENT - C1981017 ‎(8)‎

• Permit No: C1981017
• IBM Index Class Name: Enforcement
• Doc Name: Bid Documents ‎(IMP)‎ CV-90-050
• Violation No.: C-90-050
• Media Type: D
• Archive: No

JUSTIFICATION OF SETTLEMENT AGREEMENT FOR
NOV C-90-050
NOV C-90-050 was written for "failure to maintain light-use roads and
discharge structures associated with those roads in order to minimize erosion
and disturbance to hydrologic balance." Mr Routten cited seven separate areas
in the NOV. Slides were shown.
Mid-Continent Resources did not contest the NOV. Ms. Delaney explained that
these were old haul roads that were recently downgraded to light-use roads.
Mid-Continent will be evaluating the roads in the near future to determine how
to more effectively control the run-off.
The proposed civil penalty was:
H i story $ 250.00
Seriousness 250.00
Fault 500.00
Good Faith 0.00
TOTAL 19000.00
History
Five NOV's have been issued during the past twelve months.
Seriousness
Ms. Delaney was concerned that safety of the roads was considered as part of
the penalty since MSHA has jurisdiction on safety issues. This is true but
MLRD is concerned with safety to the extent a situation would damage public or
private property. I considered the potential to be low.
I agree with the proposed penalty of $250.00.
Faul t
I agree with the proposed penalty .
Good Faith
The NOV has not been abated. Therefire, a good faith reduction is not
appropriate.
Final Civil Penalty
History $ 250.00
Seriousness 250.00
Fault 500.00
Good Faith 0.00
TOTAL 1000.00
2704F/ddh