ENFORCE24512

• Permit No: C1981017
• IBM Index Class Name: Enforcement
• Doc Date: 11/30/1993
• Doc Name: Memo on Abatement Extension
• From: SGR
• To: MBL
• Violation No.: CV1993092
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman Sf-, Room 215
Denver, CO 80203
Phone: [phone]
FA%:(3031832-8106
November 30, 1993
MEMO
TO: Michael Long
FROM: Steve Renner
RE: Mid-Continent Resources NOV C-93-092
~~~~ c
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Roy Romer
Governor
Michael B. Long 1
Division Director
Mid-Continent Resources will be meeting with the Division on
December 1, 1993 to discuss their request for an extension of the
abatement of NOV C-93-D92.
The violation was issued on June 17, 1993 for failure to minimize
and control erosion to the extent possible at the road network
outslopes and cutslopes, and for failure to stabilize the system
of ditches, ditch outlets and culvert outlets adjacent to the
roads. Abatement of the violation required that a Technical
Revision be submitted by July 17, 1993 to address remedial
issues, and implement the program by September 15, 1993. Mid-
Continent submitted a Revision to the permit which was deemed to
be complete, but not approvable. The Division did not provide
adequacy comments. On November 5, 1993 the Division received a
FAX from Mid-Continent dated October 15, 1993 requesting an
indefinite extension of the abatement. The rationale provided
for the request was to allow their newly hired consultant the
opportunity to comment upon the permit and pending revision. The
Division issued a Failure to Abate Cessation Order to Mid-
Continent on November 29, 1993 due to its failure to abate the
violation.
I have a number of concerns regarding this request to extend the
abatement of the violation, which are explained below.
- Mid-Continent apparently requested the extension well after the
abatement deadline of September 15, 1993. Rule 5 allows for
extensions beyond 90 days, but clearly contemplates that such
requests would occur prior to the expiration of the abatement
date.
- Rule 5 provides a number of reasons to extend an abatement