GENERAL53205

• Permit No: C1981013
• IBM Index Class Name: General Documents
• Doc Date: 12/2/1993
• Doc Name: RESPONSE TO SHOW CAUSE ORDER & WRITTEN REQUEST FOR REVIEW GOLDEN EAGLE MIN EPN C-81-013
• From: BASIN RESOURCES INC
• To: DMG
• Media Type: D
• Archive: No

III IIIIIIIIIIIII III
999
14300 Highway 12
Weston, Colorado 81091
[phone]
FAX [phone]
BASIN
RESOURCES, ~N~.
a subsidiary of ENTECH, Inc.
November 30, 1993
Mr. Steven G. Renner
Coal Program Supervisor
Division of Minerals and Geology
1313 Sherman Street, Room 215
Denver, Colorado 80203
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RE: Response to Show Cause Order and Written Request for Review -
Golden Eagle Mine, Permit C-81-013
Dear Mr. Renner:
Basin Resources, Inc. hereby submits this Request for Review of Show
Cause Order and Formal Public Hearinq. This request is pursuant to the
Order to Show Cause Why Permit Should Not Be 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 ten
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 abated and terminated six of the ten referenced NOVs and
is in the final phases of terminating the other four 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 past three years and the proposed
compliance activities are presented.
5. Preparation of a formalized plan for future regulatory compliance is
in the process of being implemented and is described.