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/t i energy fuels coal, inc. eouthfiel0 mine • poet oHlcs box M8 • Iloronte, coloredo 87226 • (71B) 7618766 February 16, 1993 Ms. Catherine Begej Office of Land Mined Reclamation 1313 Sherman St., Room 215 Denver, CO 80203 RE: Notice of Violation No. C-93-003 Written Information about the Violation Your File No. C-81-014 Dear Ms. Begej: ,~o_ .J. --~. ~' /Y~ III IIIIIIIIIIIII III 999 With this letter and its attachments, Energy Fuels Coal, Inc. (EFCI) is submitting documentation of extraordinary effort to fully abate Notice of Violation No. C-93-003 as provided by Rule 5.04.3(1). This violation was written es a result of operator failure to sample replaced topsoil prior to seeding the 1992 refuse pile reclamation area. The NOV was issued January 27, 1993 and received by EFCI on February 1, 1993. EFCI planned soil sampling procedures and excavated test pits on January 28, 1993 in accordance with the permit application. Incremental soil samples were collected, composited and bagged on the same day, and arrangements for analysis parameters were made with We soils laboratory. In addition, sample increments in each test pit were documented on field core logs (copies attached) and the sample sites wire photographed. Finally, the sample locations were plotted on attached Figure 1, Refuse Disposal Site 1992 Reclamation Map thus completing abatement steps nos. 1-a and 1-b. Results of the soil analysis were received by EFCI on February 12, 1993, and are attached for reference. Soil suitability was evaluated based on the suitability criteria found in the 1984 Wyoming Topsoil and Overburden Guideline (Wyoming DEQ 1984) given the OMLR's past reliance on these guidelines. Specifically, the suitability rankings found in Table I-2, Ctteria to Establish Suitability of Topsoil (or Topsoil Substitutes), and Table I-4, Criteria to Establish Overburden Suitability were used. Evaluation of the sample data indicates that the soil materials appear suitable with respect to all parameters shown in the above referenced guidelines. Abatement step 2 is thus shown to be unnecessary on the basis of this evaluation. ~~ ' ed i ti - 'd~ ~~ ., ~~~ 2 `~ 199= U.:... y11NEF?.~L~ . :•.....