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~~ III IIIIIIIIIIIIIIII <br />•~ 999 <br />energy fuels mining company ~~ <br />one labor center • swte 2500 1303) 6238317 <br />1200 seventeenth street • denver, coiorado 80202 iwx 910931-2561 <br />December 13, 1999 ~ECE~~E~ <br />Mr. Michael B. Long, Director DEC 16 'g99 <br />D313sSherman Streets Room 215ogy Dt~slono~Mlne~bBGeolo9Y <br />Denver, Colorado 80203 <br />Re: Notice of Violation No. CV-99-014 rec~ved_by Energy Fuels <br />Mining Company on November 30, 1999; Permit No. C-82-055 <br />information About the Violation (Rule 5.04.3(1)), and <br />Request to Vacate the Violation <br />Dear Mr. Long: <br />Energy Fuels Mining Company (EFMC) hereby requests vacating NOV No. <br />CV-99-014. The violation alleges implementing a minor revision <br />before obtaining final approval. The facts supporting EFMC's request <br />to vacate the violation are explained below in detail. <br />EFMC did proceed with work proposed within the minor revision (MR- <br />17) in good faith that information submitted to the Divis~~ion on <br />October 28, 1999 was sufficient to make the revision both' complete <br />and acceptable for approval. The response from the Division stating <br />the revision was incomplete for the second time, dated Nolvember 12, <br />1999, does not address any significant unanswered issuesiother than <br />providing a map of where the work will be conducted. Impl'lementing <br />-- the relatively uncomplicated work proposed by the revision would <br />not, in our previous experience, elicit a violation from it he <br />Division. In addition, the work performed was discussed wiith the <br />inspector at the mine on July 22, 1999, as is noted in the Division's <br />responses. <br />When EFMC implemented the work subject to this violation,'a <br />contractor was on the site completing work to abate previ',ous <br />violation No. CV-99-011. The previous violation was issued even <br />though the Division was aware that the contractor was preparing to <br />mobilize to the site to complete the work. For nearly two years prior <br />to getting the current contractor, S & 5 Services, on site, EFMC had <br />tried to arrange work with three other contractors that later proved <br /> <br />