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2011-05-12_ENFORCEMENT - C1981008 (3)
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2011-05-12_ENFORCEMENT - C1981008 (3)
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Last modified
8/24/2016 4:33:28 PM
Creation date
5/13/2011 7:57:27 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
ENFORCEMENT
Doc Date
5/12/2011
Doc Name
Response to 2/14/11 JoEllen Request for Informal Review
From
OSM
To
JoEllen Turner
Violation No.
TDNX11140182001
Email Name
SB1
DAB
MLT
Media Type
D
Archive
No
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activities that had occurred from December 1, 2010, up to the inspection date. The report <br />concludes by stating that no enforcement actions were issued as a result of the inspection, <br />and none are pending. <br />4. WFC responded to DRMS' request in a letter dated January 17, 2011, wherein it provided a <br />tabulation of temperature and precipitation data from December 1, 2010, through January 13, <br />2011, as well as records that showed approximate volumes of prime farmland topsoil that <br />had been removed from the Frank Morgan field during that same period. The letter also <br />stated that "the entire volume of Prime Farmland Lift "A" & "B" was hauled directly to their <br />respective topsoil stock piles during December 2010 and the first 13 days of January 2011." <br />Lastly, the letter documented that WFC's representative accompanied the DRMS inspector <br />to the field to visually verify.the haulage and included digital photographs dated December <br />28, 2010, of a shovel loading trucks with "A" zone topsoil. Based on this climatic data and <br />the topsoil salvaging photos provided by WFC, DRMS responded to the DFD's TDN on <br />January 20, 2011, finding there is no evidence of saturated soil conditions and that the <br />alleged violations do not exist. As a result, DRMS determined that WFC is in compliance <br />with Rules 4.06.2 and 4.06.3 and their permit. <br />5. You submitted numerous photographs to the DFD on January 26-27 and February 1-2, 2011, <br />via Federal Express depicting wet and snowy conditions. On February 16, 2011, the DFD <br />Chief responded to you with an e-mail message letting you know that he had received one <br />fax from you on February 14th and two on February 15t , as well as receiving four FedEx <br />packages between January 26th and February 3rd. The DFD Chief continued that while he <br />recognized your efforts to keep him informed about the concerns you have with the mining <br />operations on the Morgan property, "the photos you sent have little meaning without a date <br />stamp or a point of reference. It is most helpful to all parties to have specific and accurate <br />information and documentation of potential violations in order to successfully address any <br />problems." <br />You responded to the DFD Chief in an e-mail message dated February 16, 2011, that the <br />pictures were taken immediately when you made the calls and that some of the photos do <br />have a time and dates, but your sister-in-law took the pictures. You further stated that all of <br />the pictures were taken on the 23rd [of December], the 2" d, 3rd [of January], and so forth and <br />all you have to prove those dates are the receipts showing the dates they were developed. <br />You go on to explain that these types of cameras don't put the dates and you can't mark <br />them until they are developed. You also stated that you told the DFD Chief the dates on <br />which you took the pictures and they were developed within a week of that time. Next, you <br />noted that all of the rainy ones [photographs] were from December the 23rd and all of the <br />others were when the snow was there from the 3rd of January on, and continue that you <br />marked the pictures of the 28th of December when the State Inspector was at the mine to <br />show the same fields five days later and document an accurate comparison to when they <br />were here and what happens in a few days. You explained that you made sure to make that <br />analysis so that the DFD Chief could see what the fields looked like on the 28th of December <br />and on the 3rd of January of the tremendous amount of snow that was received. You added <br />that you can send copies of the development dates with the numbers on the back of the <br />photos so the DFD Chief can see when they were, and note that without having a camera that <br />prints the dates on the fronts of the pictures as did the other that is the best that you can do.
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