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August 18, 2014 C- 1981 - 010 /Trapper Mine JLE <br />ENFORCEMENT ACTIONS /COMPLIANCE <br />The following development drill pads were observed on August 20, 2014 during the inspection; 2014 -M6, <br />2014-M7,2014-M-31, 2014-M2,2014-MI, 2014 -Ml 1, 2014-M8,2014-M9 and 2014 -M10. Enclosed is a <br />map that depicts the location of these development drill pads. The following pads had been drilled at the <br />time of the inspection; 2014 -M6, 2014 -M7 and 2014 -M9. Pad 2014 -M10 was actively being drilled at <br />the time of the inspection. Topsoil was not removed or stored at development drill pads; 2014 -M7, 2014 - <br />M2, 2014 -M1, 2014 -Ml 1. Topsoil was partially removed and stored at pad 2014 -M10. A portion of the <br />topsoil from the 2014 -M 10 pad area was stockpiled at the toe of the pad and it appeared a portion of the <br />drill pad was constructed out of topsoil. Section 3.3.2.1 of Trapper's permit states, "Topsoil will be <br />removed from the drill sites prior to drilling ". Section 3.2.1 of Trapper's permit states, "Before an area is <br />disturbed by drilling, blasting, mining or other surface disturbance, the topsoil is removed as appropriate ". <br />Failure to remove and store topsoil is a violation of Rule 4.06.2 and 4.06.3. <br />Topsoil was removed and stored at development drill pads; 2014 -M6, 2014 -M3, 2014 -M8 and 2014 -M9. <br />However, topsoil markers were not posted on the topsoil stockpiles in accordance with Rule 4.02.7. <br />Section 3.3.2.1 of Trapper's permit states, "Any water generated by the drilling operations, i.e. when <br />drilling with water, will be contained in small pits and covered with at least two feet of material or <br />allowed to evaporate ". Small pits to contain water generated by the drilling operations were not observed <br />at pads 2014 -M7 and 2014 -M10. A small rill from the drill hole at pad 2014 -M7 ran from the drill hole <br />down the pad embankment and into the undisturbed brush adjacent to the pad. Similarly, water from the <br />drilling operations at pad 2014 -M10 ran down the pad embankment and continued through a portion of <br />grass/brush and down the light use road used to access the pad area. Failure to implement sediment <br />control measures is a violation of Rule 4.05.5(2). <br />As a result of the items discussed above, the following violation was issued <br />Infraction Number: CV2014006 <br />Inspection Date: August 18, 2014 <br />Date Issued: August 22, 2014 <br />Primary Topic: Topsoil <br />Secondary Topic: Sediment Control <br />Tertiary Topic: <br />Description: Failure to remove topsoil, store topsoil and post topsoil markers at development drill <br />pads and failure to implement sediment control measures at development drill pads. <br />Abatement 4: 1 <br />Abatement Due Date: 9/22/2014 <br />Abatement Due Extended Date: <br />Abatement Description: Remove and store any salvageable topsoil from development drill pads <br />where topsoil had not been removed during pad construction and has not been drilled. Store the <br />salvageable topsoil in a stockpile in compliance with Rule 4.06.3. <br />Abatement 4: 2 <br />Abatement Due Date: 9/22/2014 <br />Abatement Due Extended Date: <br />Abatement Description: Post topsoil markers on stored topsoil at the development drill pad sites <br />Number of Partial Inspection this Fiscal Year: 1 <br />Number of Complete Inspections this Fiscal Year: 1 <br />Page 6 of 24 <br />