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rlr. Dada c. sheitt~ <br />rtined Land Reclamation Division <br />February 2d, ].982 <br />Page 2 <br />the formation of erosional rills. 'this will ho]d the duration oC any damage <br />that would result Crnm erosion or sedimentation to a medium or short period. <br />Thr: extent of damage in any case is small since the amount of material in <br />the area involved is small both in terms of the tot.rl disturbed area at the <br />mine and in the Hubbard Creek watershed area. <br />In summary, if the term damage refers to the hazardous effects of erosion <br />and sedimentation, which we believe should be the definition of the term, a <br />value of. 2 should be assigned in each of the three areas. Anv damage due to <br />erosion will be contained within the sediment control system. The effects of <br />erosion will he limited Co a short duration by rcvcgctation of the disturbed <br />areas. The extent of the additionally disturbed areas is very smaL1. <br />In the fault category, we can make no argwnent other than the violations <br />were the result of poor supervision of the contractor doing the work by the <br />mine superintendent and his assistants. Phis was a negligent act and was not <br />intentional. It does, however, point up a need we expect to correct. In the <br />future, we plan to properly instruct all contractors working at the mine in the <br />proper procedures to he used in accordance with the terms of our permit applica- <br />tion. <br />By combining the two notices of violation and fallowing the argument that <br />the definition of damage is the cFfccts of erosion and sedimentation off the <br />permit area, the following summary of the assessment. calculations should be <br />used: <br />History of Prcv.i.ous Violations - $150.00 <br />Seriousne:;s - $218.75 <br />Fault - $750.00 <br />TOTAL - $618.75 <br />I believe that this level of assessment would be fair considering the <br />size of the operation and [he level of damage and/or potential damage. T feel <br />that a.ithough there was some negligence in the work of making the ventilation <br />change at the mine, it is significant [hat proper communications regarding the <br />event of installing a new fan and scaling Chc opening at the old mine were made <br />with rFhR. Also the abatement plan of December 18, 1981, which I believe repairs <br />any long term damage, has been attached for consideration. <br />Si9cerely yo~, <br />i~ <br />James K. Greenlee <br />JKG/ct Vice-President of Engineering <br />and Technical Services <br />enclosure <br />