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<br />Mr. Michael <br />October 29, <br />Page 2 <br />B. Long, Director <br />1997 <br />2. Failure to complete Year 2 vegetation monitoring as required in <br />the permit. <br />The approved permit states: "Initial evaluation of the revegetation <br />success will be conducted in the 2nd, 4th, and 7th year following <br />germination. In the case of the Raton Creek Mine, the first required <br />evaluation of vegetation success will be completed in 1998, as <br />explained below. <br />EFMC planted the permanent seed mixture on the entire reclaimed mine <br />site just 2 years ago in November 1995. During 1996, following a <br />relatively dry winter and spring, germination of the seeded species <br />was very limited, at best. The lack of germination is documented in <br />the DMG~s inspection reports, and was similarly observed by EFMC <br />personnel during-routine site inspections. <br />The emergence of the seeded species throughout the reclaimed site <br />was evident in the spring of this year (1997). Typical of vegetation <br />growth in a semi-arid area, the significant germination of the <br />seeded species at Raton Creek occurred in the second year following <br />planting. The sprouting of perennial grasses and cicer milkvetch is <br />documented in the DMG inspection reports during the first and second <br />quarters of 1997. <br />Based on the vegetation conditions described above, EFMC planned to <br />conduct the first vegetation monitoring in 1998, in accordance with <br />the permit. EFMC believes that the Division has misinterpreted the <br />permit requirement to mean that vegetation monitoring will be done <br />in the 2nd year following seeding. Clearly, it would be premature to <br />conduct vegetation monitoring during the first year of vegetation <br />establishment at the Raton Creek Mine. <br />Issuance of this violation on the basis of administrative <br />circumstances for the report, and misinterpretation of permit <br />vegetation monitoring requirements, is not warranted. The above <br />information provides that EFMC was not negligent in complying with <br />the permit. In conclusion, EFMC requests that Notice of Violation C- <br />97-018 be vacated. <br />Sincerely, <br />Energy Fuels fining Company <br />Allen S. Weaver <br />Mine Engineer <br />cc: G. v. Patterson (EFMC) <br />Kent A. Gorham (DMG) <br />