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ENFORCE31443
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ENFORCE31443
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Entry Properties
Last modified
8/24/2016 7:43:02 PM
Creation date
11/21/2007 12:59:04 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
Enforcement
Doc Date
11/6/1992
Doc Name
MEMO REQUEST FOR VACATION OF NOV C-92-030
From
DMG
To
MIKE LONG
Violation No.
CV1992030
Media Type
D
Archive
No
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<br />2 <br />This is essentially the point at which Colowyo's and my <br />interpretations differ. If the regulations do not require the <br />blasting records to be adequate for a reviewer to interpret them, <br />then I agree the NOV should be vacated. If the regulations require <br />the blasting records to certain enough information that a reviewer <br />can reconstruct a blast, then the records are not in compliance <br />with the regulations. This is because definition of the symbols on <br />the records is essential to understanding and reconstructing a <br />blast. Without definition, the symbols have no meaning or <br />significance and thus, render the "sketch " uninterpretable. <br />3. Blast Records Contain Other Symbols <br />This section of the Colowyo letter reiterates the arguments <br />discussed in section 2 above. <br />4. Blastincr Record Inspections <br />As mentioned in Colowyo's letter, blasting records have been <br />reviewed at the mine for a number of years. I am not aware that <br />questions have been raised during inspections in the past about the <br />adequacy of sketches on the blasting records. The fact that an <br />inadequacy has been overlooked in the past does not however, <br />relieve the Division from its obligation to correct those <br />deficiencies when they are observed. <br />The Division did forward a question about the adequacy of Colowyo's <br />blasting records in a preliminary adequacy letter for PR-O1 on <br />October 4, 1991 and again on March 25, 1992. Colowyo indicated <br />that the records contained adequate information in conjunction with <br />"typical sketches" in the permit. The matter was not pursued any <br />further at that time. <br />5. Abatement <br />While the subject matter of this violation may be minor in relation <br />to other matters within the Division's jurisdiction, it is my <br />opinion that the blasting records are not in compliance with the <br />regulations. Consequently, we are obligated to issue an NOV. The <br />only available alternative would have been arguing a TDN for which <br />I do not feel there is a good argument. The Division cautioned <br />Colowyo about our concern with the adequacy of their blasting <br />records earlier this year. Colowyo chose not to make any changes <br />at that time. <br />
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