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iii iiiiiiiiiiiii iii <br />999 <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman 51., Room 215 <br />Dem•er, Colorado 80203 <br />Phone: 1303) 866-3567 <br />FA%: 1303) 832-8106 <br />MEMO <br />To: Mike Long <br />From: Kent Gorham <br />Subject: Raton Creek Mine <br />Energy Fuels Mining Company <br />NOV CV-99-014, Request to Vacate <br />Date: December 21, 1999 <br />DIVISION OF <br />MINERALS <br />GEOLOGY <br />0. E C L A M A T I O N <br />MINING•SAFETY <br />Bil I Owens <br />Governor <br />Greg E. Walther <br />EtPCULec DvMlor <br />M¢hael B Long <br />Division Director <br />The Division has received a request from Energy Fuels Mining Company (EFMC) to <br />vacate NOV C-99-014, issued for implementing a revision prior to obtaining final <br />approval at the Raton Creek mine. Rather than provide all the details and events <br />leading up to the NOV, I have provided comments directly in response to the request <br />for vacation. EFMC comments are in italics followed by the staff response. <br />"The violation alleges implementing a minorrevision before obtaining hnal approval." <br />This is not an allegation, but a fact supported by on-the-ground inspection. EFMC even <br />admits later in the same correspondence that they did proceed with the work. <br />"EFMC did proceed with work proposed within the minor revision (MR-17) in good <br />faith..." EFMC made no effort to contact the DMG to request, discuss, or initiate an <br />accelerated approval due to the contractors time constraints or any other reason. No <br />phone calls, Faxes, emails, or other correspondence requesting expedited approval <br />were received by the DMG prior to EFMC conducting the work. It is common for the <br />DMG to assist operators by compressing permitting timeframes when circumstances <br />arise, particularly when it relates to operation and reclamation issues. <br />"...the work performed was discussed with the inspector at the mine on July 22, <br />1999..." This statement correct. However, EFMC fails to point out that what was <br />included in the revision and submitted in September was a small portion of what was <br />discussed with the inspector in July, thus leading to the first incomplete determination <br />by the DMG. <br />"...the contractor was ready to leave the site to do work elsewhere, EFMC felt <br />compelled to start the work proposed..." . EFMC not only started the work but <br />