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Page two 6. Basin has and will continue to promote environmental and regulatory compliance. This commitment is even stronger with the recent acquisition of a long term coal contract. Any actions against the permit may jeopardize this contract and the overall employment and economy of Las Animas County. 1. VIOLATION TERMINATION As of this date, Basin has abated and terminated six of the ten referenced NOVs. Technical Revisions to the permit have been submitted for the other two NOVs which are in the approval process. Upon approval, on-the-ground activities will be completed at which time the NOVs can be terminated. The number and complexity of the NOVs has required significant man power and expenditure for abatement activities which are discussed below. 2. ANALYSIS OF COMPLIANCE HISTORY For the period of March 1990 through March 1993 (previous three years), only one NOV was issued at the Golden Eagle Mine for the following: Violation No. C-92--010 was issued on June 22, 1992 for failure to submit at least semi annually to the Division results of the subsidence monitoring program. The violation was terminated on July 27, 1992 following submission of the required information. As noted, the Golden Eagle Mine compliance history is less than one NOV per operating year. During this same period of time, the Division conducted. regular monthly partial inspections and quarterly complete inspections. The regular inspection typically included one inspection day and the quarterly inspection one to three days. It was uncommon for an inspector to be accompanied by another inspector or his Senior except for the purpose of training. The total inspector days for the last three years were 21 in 1991, 20 in 1992, and 57 in 1993 (January through November). Throughout this period, Basin was in compliance with the regulatory program. This contentlon is also supported by the fact that the Golden Eagle Mine was presented the 1991 Large Underground Mine Award for compliance by the Division and the Colorado Mining Association. Since March of 1993, the Golden Eagle Mine has had 57 inspector days resulting in the ten referenced NOVs. Six of these NOVs are related to hydrology while the remaining four are for general performance standards. Basin's review of the NOVs has classified them .into two general categories including failure to maintain permitted facilities (9 NOVs) and permit deficiencies as a result of policy changes (1 NOV). Many of the NOVs are related to items which were permitted and/or maintained by the previous owner of the property (prior to 1991) and inspected by the Division.