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.^: <br /> <br />Assessment Conference Page 2 <br />April 14, 1993 <br />regarding the upcoming PR, and assuming the <br />same thing that happened at permit issuance <br />will happen again with this PR and we want to <br />be prepared with the knowledge that everything <br />will happen as MCC says it will. <br />II. Justification of Abatement ~ S~~u~r~d. {~d~~F~VtilOr~~ ~~~~ ~Ui~ ~"e' <br />1. (To mitigate any perceived communication problems) ~Gf(oi,UivlL~ <br />~(~,(Clarify record-No chance for questions in the future) p~ (~'dWtGSi lMy~ <br />,1` 3, (Hole in the record-Only one good submittal) Vv~,nE (~ rn~l~{-y~~s. <br />A. Determine due date for semi-annual submittals by April 19 <br />1. The record is not clear regarding when these reports <br />are due <br />a. In the Division's database due dates as January 30 <br />and July 30 of each year <br />b. I do not believe MCC is aware of this <br />2. I proposed November 30 and July 31 of each year <br />a. It appears that most of the surveys are completed <br />in June and October <br />b. The due dates are negotiable- <br />B. Develop report format for mid-year and yearly submittals <br />by April 19 <br />1. The record is not clear as to the format approved by <br />the Division <br />a. In the reports the Division has received each <br />format is different ~'OfM Vl~or ~ ~ vLpor~ <br />2. y Reviewed many subsidence reports for other mines and <br />it appeared that the mid-year submittal is different <br />than the yearly submittal <br />C. Submit additional information in order for Division to <br />review report submitted 1-19-93 <br />1. Report inadequate considering the Division has not <br />received a report for a year and a half <br />2. Letter dated 2-19-93 details the information required <br />III. Civil Penalty,/~)OVri%~d-~/CG9 ~9/S~fvr~Q~~urr~b <br />A. Indeed a administrative violationnand minimum of $250 was <br />assessed <br />B. Fault- i do not think the violation was intentional, they <br />just forgot, although I reminded them several times <br />C. But a violation still occurred and I believe it should be <br />upheld <br />