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Mr. Randall P. Price April 23, 1993 Page Two 4) Revisions TR-07 and TR-08 were missing Status: Bo[h TR-07 and TR-08 were on file at the mine site at the time of the inspection. Because these revisions were not filed within the last two years, corresponding documen[ation had been backfiled as archive files and were found in separate file drawer from [he one provided for OMLR/OSMRE review. These files were not requested at the time of the inspection, otherwise they could have been provided. 5J The findings document with the proposed decision to renew. Status: Following your ini[ial indication that this document was missing, [he files were checked and the document was found, having been mis-filed in a MSHA compliance file. The document was presented during the second day of the inspection. As indicated above, the only items actually missing from the mine site files were Map 28A (copy ob[ained 4/14/93), the CDPS Renewal which was not copied to the mine (copy transmitted 4/21/93), and bonding correspondence which was not copied to the mine (copy requested from OMLR). We apologize for any inconvenience relating to our in-house filing system and are working with ACZ Inc. to more effectively organize and update our permitting and compliance files. Given, however, the shear volume and scope of information required to document permit commitments and ongoing compliance, we feel that it is unrealistic for the agencies to expect operators to be able to produce all relevant information with no advance notice. We also feel that issuance of records viola ions without providing the operator with reasonable oppor[unity to locate and provide requested information is both unreasonable and arbi[rary. Sincerely, Kerr Coal Company George V. Patterson Mine Manager JMN:cmc cc: D. Berry/OMLR H. Austin/OSMRE-AFO R. Munson/EFC Denver J. Nettleton/ACZ