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• <br />STATE OF iii iiiiiiiiiiiii iii <br />COLORADO <br />DIVISION OF MINERALS AND GEOLOGY i <br />Dr•pdrlmcnl of NJlural Ketiuurres ~ <br />I f I 1 Shermon 51 . Kuum ? I S <br />Dcmcr, CulnmrL, HII_'U S <br />Nhnnc'. (4041146h~5567 <br />FA%: I3U II N f? R 1116 <br /> DEPARTMENT OF <br />October 14, 1997 NATURAL <br /> RESOURCES <br /> Rny Rnmcr <br /> Guvcrnnr <br />Allen S. Weaver lan,rs s. lnrnnrar~ <br /> E rennrvr DireUOr <br />Mine Engineer <br /> nb~hael B Long <br />Energy Fuels Mining Company Drvisinn Dvrt'Inr <br />P.O. Box 449 <br />Florence, CO 81226 <br />Mr. Weaver: <br />Enclosed please find Notice of Violation C-97-O18 for the Raton Creek Mine operated by Energy Fuels <br />Mining Co.(EFMC). This violation was taken for failure to submit a 1996 Annual Reclamation Report <br />and failure to conduct year 2 vegetation monitoring as required by the approved permit. <br />As you are aware, the Division tentatively agreed to allow Energy Fuels to re-seed the overburden material <br />directly in some areas of the reclamation based on the Topsoil Substitute Suitabiliry Report conducted by <br />Cedar Creek Associates, Inc. in September of 1994. The Division responded to receipt and review of this <br />report in a letter dated November I5, 1994. In this letter, the Division made it clear that "as per <br />recommendation #2 of your report, if the Division determines that the initial seeding has failed, the <br />Division may require Energy Fuels to procure additional topsoil material in sufficient quantities to satisfy <br />the permit requirement of topsoil replacement to a depth of 4.5 inches." The Division went on to indicate <br />that this approval of a topsoil substitute "is a variance from permit conditions, [and] a technical revision to <br />the permit" would be necessary. The letter also states, "The TR application should include a copy of the <br />Topsoil Substitute Suitabiliry Report with EFMC responses to the recommendations made in the report <br />and the fact that this approval is tentative, pending Division evaluation to occur following two years from <br />seeding." <br />The Division apparently did not receive a technical revision in response to this first request, as evidenced <br />by text in the subsequent mid-term review document. Question #3, on page 13 of the mid-term review <br />dated January 6, 1995, states "The Division has previously requested, in our letter dated November 15, <br />1994, a technical revision containing a copy of EFMC's Topsoil Substitute Suitability Report, with <br />responses by EFMC to the recommendations made within the report. The TR should also propose <br />conditional approval, pending evaluation of the revegetation success that will occur following two years <br />after seeding. The topsoil substitute TR is necessary to allow the Division's decision to become a permit <br />condition. Although this issue was addressed previously, it remains outstanding and as such is included <br />within this review." <br />Division review of technical revisions approved from January 1995 to the present indicate that, again, no <br />response from EFMC was received in the form ofa technical revision which addresses this issue. TR-l6 <br />dealt with the trailer and topsoil stockpile area and an SAE for CWD No. I. TR-17 approved a number of <br />structures to remain as permanent. TR-18 approved changes in some drainage and sediment control at [he <br />