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` `4 • • III III'111111111111 <br />999 <br />ASSESSMENT CONFER] <br />WEST ELK MINE <br />April 14, 1993 <br />I. Facts of the Violation <br />A. Issued NOV C-93-006 for failure to submit semi-annual <br />subsidence reports on a semi-annual basis <br />B. Division has not received a report for a year and a half <br />1. Last report received 9etaber 1990 until report received <br />January 1993 u0~e i~'~ {~/,~i~.rc tact (45-9 *YO Suv ~C YS <br />2. This data, and the reporting of this data, is important <br />because actual subsidence data is required when a PR is <br />submitted (any day now!) to mine into the Minnesota <br />Creek Drainage. <br />C. Not arguing that the reports were not completed <br />1. In fact, many inspectors including myself, acknowledged <br />during site inspections that these surveys were being <br />completed. This fact was brought up in MCC's request <br />for vacation. <br />2. But, the reports are required to be submitted so the <br />Division can review the surveys and the maps, in house. <br />The inspection is not the time or place to review and <br />make findings regarding the adequacy or status of final <br />reporting. This is the reason the Division requires <br />these reports to be submitted. Too complicated! ~~ %d[ ~~p,~ ~1pJ{' <br />~b~occasi~Ks ov~(y (2tesc~hs~~,(R ~d~~~o,-yav~ p9.L tNaS widrlce-~l-r(oCOvKr~c <br />SrS~ <br />D. --- issuing this violation rv2.vt~y Gov <br />1. In violation of Rule 2.05.6(6) (c) (i) (E); "Results of ~r4vc~cr~L <br />the monitoring program shall be submitted to the <br />Division at least semi-annually" <br />2. In violation of permit application, page 2.05.147; <br />"Subsidence monitoring reports are submitted on a semi <br />-annual basis in a format approved by the Division" <br />3. Division's opinion that it is the operator's <br />responsibility to submit reports that are both accurate <br />and timely. <br />4. Subsidence monitoring is a very important facet of <br />MCC's permit. <br />A. The subsidence control plan for the Minnesota Creek <br />Drainage will be based on actual subsidence data l <br />collected during the 2 previous permit terms(iaJE/~_/ <br />B. Subsidence prediction, monitoring and evaluation <br />have been a very significant concern for MCC since <br />its original permit issuance, including a three <br />year involvement for the Division at considerable <br />expense before the OSM Board and ALJ. <br />1. The Division is taking a pessimistic view <br />