_GENERAL DOCUMENTS - C1981017 (142)

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MID-CONTINENT RESOURCES, INC. ANALYSIS OF CITATIONS AND ORDERS ALLEGEDLY CONSTITUTING PATTERNS OF VIOLATIONS Administrative Record and Proceedings As a preface to this presentation, it should be noted that enforcement actions were taken by the Mined Land Reclamation Division resulting from the inspections conducted March 30 , April 13, May 21-24 , June 28, August 23 and November 1 , 1984 . Additionally, extensive informal public assessment conferences or Board-directed investigations and conferences were conducted between representatives of Mid-Continent and the Division. The records of these proceedings are part of the Divi- sion' s public files . The results of the administrative pro- ceedings were reviewed and approved in subsequent public pro- ceedings by the Board. Memoranda of these administrative actions are contained in the Stipulation Agreement, approved by the Board on December 14, 1984, as amended by the Board on March 28 , 1985, and in the Settlement Agreement approved by the Board on March 28 , 1985 . The Settlement Agreement approved by the Board on March 28 , 1985 was supplemented, by Board authority, by my Supplementary Letter dated April 12 , 1985 . To aid your review of this request , references are made to the foregoing records and proceedings , verbal presentations, data described or presented in documents received in evidence, and evidence adduced at the public conferences . If you wish Mid-Continent to provide verification of these points or documents, please advise us and allow a reasonable lead-time to provide such verification for your consideration. I. DETERMINATION OF PATTERN OF VIOLATIONS (I) PERTAINING TO TOPSOIL HANDLING 1 . NoV No. C-84-013 . No such NoV was issued to Mid-con- tinent. We believe the correct reference is to NoV No. C-84-103 . This circumstance, we submit, represented an isolated cir- cumstance conducted under emergency circumstances for environ- mental protection purposes and, thus , was an isolated departure from otherwise lawful conduct and the normal operations of the Rock Tunnels Project. The violation cited was remedied and abated at the earliest opportunity.