_GENERAL DOCUMENTS - C1981017 (142)

Home Browse Search

David C. Shelton, Director , August 26, 1985 Colo. Mined Land Reclamation Division Page 6 before the Board requesting suspension or revoca- tion when there are no further actions that could be taken by the company with regard to these vio- lations or prevention of future violations of the same type. [Emphasis supplied. ] It would appear from these previous considerations of show cause orders that you have chosen to exercise your authority un- der Rule 5 . 03.3 ( 2) ( c) for the following reasons: (1) All previous enforcement actions had been successfully abated which reduced the probability of future problems (presumably within control of the permittee) . ( 2) No further or additional actions could be taken by the permittee to correct past violations or to prevent future violations of the same type. MID-CONTINENT CONCLUSIONS Mid-Continent submits that not only has it completely abated all the citations issued, but Mid-Continent has gone to exceptional lengths to, and we believe successfully, prevent any reoccurrence of these circumstances even in exceptional condi- tions . Attached to this letter we have enclosed a summary of en- vironmental expenditures for the period April , 1984 to and in- cluding July, 1985. During this period of time, Mid-Continent has spent in excess of $1 ,000,000 abating violations , reengi- neering and reconstructing existing facilities and constructing new facilities to address environmental concerns . All concomit- tant with better and increased in-house environmental monitoring and maintenance, as well as the established environmental train- ing programs described above. Long-range plans and additional capital expenditures are on-going to centralize operations and to eliminate, wherever possible, surface activities . Where it is not possible to eli- minate a surface facility, then Mid-Continent seeks to mitigate it substantially. These capital expenditures will exceed $40,000,000 .