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Trapper’s PAP clearly states that “Topsoil will be removed from the drill sites prior to drilling”… <br />and “Before an area is disturbed by drilling, blasting, mining or other surface disturbance, the <br />topsoil is removed as appropriate”. Failure to remove and store topsoil is a violation of Rule <br />4.06.2 and 4.06.3. Trapper Mining, Inc. was negligent in their failure to salvage and protect the <br />topsoil resources at several locations and in their failure to properly contain drilling fluids at two <br />drill pad locations. <br /> <br />The Fault component is therefore proposed to be set at $750. <br /> <br />Good Faith in Achieving Compliance <br />[Rule 5.04.5(3)(d)]: <br /> <br />Three abatement steps are defined in NOV CV-2014-006, and all three have an Abatement Due <br />Date of September 22, 2014. The Division inspected the site on the morning of September 23, <br />2014 and required abatement steps have been satisfactorily completed. The NOV was abated in a <br />timely manner and good faith credit is proposed for rapid compliance. The NOV was terminated <br />on September 25, 2014. <br /> <br />Good faith credit is proposed to be set at $250. <br /> <br />The Total Proposed Civil Penalty Assessment for this NOV is therefore set at $1,500. <br />