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Proposed Civil Penalty Assessment <br />Trapper Mining, Inc. /Trapper Mine <br />NOV CV- 2014 -006 —Issued August 26, 2014 <br />September 25, 2014 <br />Materials reviewed: DRMS Inspection Report (8/22/14); DRMS NOV CV- 2014 -006 (8/26/14); Permit <br />Application Package (PAP) sections 3.1.1, 3.2.1, and 3.3.2.1. <br />History [Rule 5.04.5(3)(a)]: <br />No NOVs have been issued at this mine during the 12 months preceding the issuance of this NOV. <br />The History component is therefore proposed to be set at $0. <br />Seriousness [Rule 5.04.5(3)(b)]: <br />The Seriousness component of a proposed assessment may range from $0 to $1750. The amount <br />proposed depends upon whether the violation was one of performance requirements or of <br />administrative requirements. This NOV was written for a violation of performance requirements. <br />In the case of a violation of performance requirements, the amount to be assessed for Seriousness <br />depends upon (1) the probability of the occurrence of the event which a violated standard is <br />designed to prevent, and (2) the duration and extent of the potential or actual damage in terms of <br />area and impact on the public or environment. <br />(1) Events occurred which the standards are designed to prevent. Topsoil was not removed or <br />stored at development drill pads; 2014 -M7, 2014 -M2, 2014 -M1, 2014 -M11. Topsoil was <br />partially removed and stored at pad 2014 -MIO. A portion of the topsoil from the 2014 -MIO <br />pad area was stockpiled at the toe of the pad and it appeared a portion of the drill pad was <br />constructed out of topsoil. Topsoil markers were not posted at development drill pads; 2014 - <br />M6, 2014 -M3, 2014 -M8 and 2014 -M9. Small pits to contain water generated by the drilling <br />operations were not observed at pads 2014 -M7 and 2014 -M 10. A small rill from the drill hole <br />at pad 2014 -M7 ran from the drill hole down the pad embar lanent and into the undisturbed <br />brush adjacent to the pad. Similarly, water from the drilling operations at pad 2014 -MIOran <br />down the pad embankment and continued through a portion of grass/brush and down the light <br />use road used to access the pad area. <br />(2) Actual damage to the environment includes loss of topsoil resource, compaction of topsoil, <br />and discharge of mud/water to undisturbed adjacent areas at two drill pad sites. The total area <br />of impact to topsoil resources at five drill pad locations is estimated at 1.25 acres. The <br />undisturbed areas impacted by drilling fluids being discharged off of the drill pad site is also <br />small and estimated at less than 0.5 acres total for two drill pad locations. Creation of a <br />public safety or health hazard did not occur. Although the size of the areas impacted is <br />relatively small, loss of topsoil resource is considered significant. <br />The Seriousness component of this assessment is therefore proposed to be set at $1,000. <br />Fault [Rule 5.04.5(3)(c)]: <br />The fault component of a proposed civil penalty assessment may range from $0 to $1500. <br />Assessments of "unavoidable" violations may range from $0 to $250. Assessments for violations <br />that were the result of "negligence" may range from $250 to $750. Assessments for violations that <br />resulted from "intentional conduct" may range from $750 to $1500. <br />