2013-08-26_ENFORCEMENT - C1981012 (2)

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July 23, 2013 C- 1981- 012/New Elk Mine LDS COMPLIANCE. More revisions to the permit are anticipated as the mine moves towards production. This context continues to lend urgency to the need to ensure that the situation on the ground is in full compliance as soon as possible. In particular, the maps should reflect the physical reality, and vice - versa. AVAILABILITY OF RECORDS — Rule 5.02.4(1): Work on the digital record database, described in the inspection reports of October 16, 2012, and April 29, 2013, was on- going. In the meantime, NECC continues to maintain paper records. The records were in compliance in Mr Thompson's office (see attached checklist). EXCESS SPOIL and DEVELOPMENT WASTE — Rule 4.09 Placement; Drainage Control; Surface Stabilization: The reclaimed Development Waste Pile (DWDA 1) was stable and well vegetated. Some erosion was evident on the south side of the pile. The erosion should be repaired and reseeded. DWDA 1 is a potential candidate for a phase II bond release application, this would then allow pond 4 to be reclaimed, upon approval of a pond removal demonstration. The Development Waste Disposal Area (DWDA 2) appeared stable however the surface has not been reclaimed and is vulnerable to erosion. Sediment from the pile had washed off during the recent rain events and collected in the ditch surrounding the pile. The sediment level had built up to the point that the ditch was unable to convey the runoff. The ditch had breached in one place and almost breached in another (this is described in greater detail in the HYDROLOGIC BALANCE section). The third Development Waste Disposal Area (DWDA 3), which was approved by TR65, has not yet been bonded for and construction of it has not begun. In order to reduce potential liability, NECC could consider using the RDA to place future development waste, foregoing the need for DWDA 3. Furthermore, the waste currently stored in DWDA 2 could be moved onto the RDA (assuming that the RDA road is upgraded to a haul road, as approved by TR66), and the land currently occupied by DWDA 2 could be used for other purposes, or reclaimed. EXPLOSIVES — Rule 4.08 Distance Prohibitions 4.08.4; Warnings 4.08.4; Control of Adverse Effects 4.08.4: There were no explosives on site; NECC no longer holds an explosives permit. The area where explosives were stored previously was in good order. FISH and WILDLIFE — Rule 4.18: Several dead Ponderosa Pines were observed. Dead trees occurred on the mine site and on the neighboring hillsides. Their occurrence appeared to be slightly biased towards topographical ridges, suggesting that drought stress may be a factor. There was no reason to suspect that the dead trees were attributable to the disturbance of NECC. HYDROLOGIC BALANCE - Rule 4.05 Drainage Control 4.05.1, 4.05.2, 4.05.3; Siltation Structures 4.05.5, 4.05.6; Discharge Structures 4.05.7, 4.05.10; Diversions 4.05.4; Effluent Limits 4.05.2; Ground Water Monitoring 4.05.13; Surface Water Monitoring 4.05.13; Drainage — Acid and Toxic Materials 4.05.8; Impoundments 4.05.6, 4.05.9; Stream Buffer Zones 4.05.18: Number of Partial Inspection this Fiscal Year: 0 Number of Complete Inspections this Fiscal Year: 1 Page 3 of 29