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:~ BASIN RESOURCES, ~N~. a subsidiary of ENTECH, Inc. November 30, 1993 Mr. Steven G. Renner Coal Program Supervisor Division of Minerals and i;eoiogy 1313 Sherman Street, Room 215 Denver, Colorado 80203 iii iiiiiiiiiiii iii 14300 Hignway 12 Weston, Colorado 81091 (719)868-2761 FAX (719)868-2275 RF_CE'~~~D DEC 02 1993 RE: Response to Show Cause Order and Written Request for Review - New Elk Mine, Permit C-81-012 Dear Mr. Renner: Basin Resources, Inc. (Basin) hereby submits this Request for Review of Show Cause Order and Formal Public Hearing. This request is pursuant to the Order to Show Cause Why Permit Should Not ee Suspended or Revoked issued on October 29, 1993 and received by Certified Mail on November 2, 1993. Basin does not concur with the Division's findings that the sixteen Notices of Violations (NOVs) represent a broad overall lack of concern with regulatory compliance and that these violations were caused by the unwarranted failure to comply with the requirements of the Act, Rules, and permit conditions. This response presents the circumstances related to these NOVS and the reasons why the permit should not be suspended or revoked. The issues include the following: 1. Basin has abateo and terminated iourceer. of the sixteen referenced NOVS and is in the final phases of terminating the other two NOVs. 2. An analysis of the NOVS is presented with past compliance history. 3. An analysis of regulatory interpretation and enforcement by the Division is presented. 4. An analysis of Basin's regulatory compliance expenditures and staffing levels over the Mast three years and the proposed compliance activities are presented. 5. Preparation of a formalized plan for future regulatory cortipliarrce .is in the process of being implemented and is described.