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<br />PAGE 3 <br />culvert was complete prior to the abatement deadline. Seriousness <br />is extremely low due to the nature of the event that caused the <br />problems, short duration, and limited actual and potential damage <br />which may have occurred. <br />FAULT: The unavoidable nature of the storm event, combined <br />with the very quick response time to correct the identified areas <br />indicate a very low fault value. Response time was delayed because <br />of the extremely wet conditions and the labor dispute which did not <br />allow a continuation of cleanup. Cleanup of the drainage bybtem <br />was well underway at the time of inspection. It continued <br />throughout the inspection. The cleanup was progressing in a <br />priority fashion with these secondary structures awaiting their <br />turn. The failure to maintain was a direct result of the total <br />disruption of the drainage system caused by the storm. <br />In summary, the problems caused by the August 3 storm at the <br />New Elk Mine represented the effects of a greater than 10 year/24 <br />hour storm event that devastated the mine site. There was no <br />failure to design, construct, or maintain the structures that were <br />damaged by the storm; the design capacities of these structures <br />were simply exceeded. As a result of these exceedances, structures <br />failed. In all cases, cleanup and repairs were begun during the <br />storm or as quickly thereafter as possible, and were amply staffed <br />and funded by Basin. <br />Basin requests the Division review the facts of this NOV and <br />vacate the violation. Basin believes the items identified were <br />caused by events beyond our control and beyond design constraints. <br />We further believe fast action and continuing efforts resulted in <br />elimination of the identified problems quickly prior to departure <br />of the ir_specticr. team. mhe cne remaining issue at the times of <br />departure is minimal and should be viewed in light of the events <br />that occurred. <br />Please call if you have any questions. <br />Sincerely, <br />./ <br />Ralph ez, P.E. <br />Environmental Engineer <br />