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<br />III IIIIIIIIIIIIIIII <br />5731 State Highway 13 <br />Meeker, Colorado 81641 <br />(303) 824-4451 <br />COMPANY <br />November 3, 1992 <br />Mr. Mike Long, Director <br />Colorado Division of Minerals and Geology <br />215 Centennial Building <br />1313 Sherman Street <br />Denver, Colorado 80203 <br />Re: Permit C-81-019, Colowyo Coal Company <br />Notice of Violation C-92-30 <br />Request for Vacation <br />Dear Mr. Long, <br />a...:~ <br />NOV 9 1992 <br />f~INERN~~ ~ G~0! (~~: v <br />The following is factual information regarding the <br />circumstances associated with the referenced NOV issued by the <br />Division on September 30, 1992 as a result of OSMRE TDN number <br />X-92-020-244-2TV2. <br />Colowyo hereby requests that the NOV be vacated for the <br />reasons outlined below. We are confident that once all of the <br />pertinent facts have been reviewed, the Division will agree that <br />Colowyo has indeed complied with the requirements of the Act and <br />DMG Rules and an NOV is not warranted in this case. <br />The NOV was written for "Failure to retain a record of each <br />blast, a sketch of the blast pattern including number of holes, <br />burden, spacing and delay pattern" Rule 4.08.5(7). In particular, <br />the focus of the Division's concern was with the section of <br />Colowyo's blasting report that provides compliance specifically <br />with the "sketch of the blast pattern" portion of the noted Rule. <br />There are five issues that have a bearing on this request for <br />vacation of the NOV: 1) Colowyo daily blast records do in fact <br />provide a sketch of each blast pattern, 2) regulatory intent, 3) <br />blast records contain other symbols, 4) blast records have been <br />reviewed on many previous occasions and 5) abatement. <br />1j Colowvo Dailv Blast Records <br />Colowyo daily blast records have always provided a sketch <br />of the blast pattern. The information is located in the <br />"shooting pattern" section of the Blasting Report. <br />Symbols have been utilized as the sketch to describe both <br />the blast pattern and the method for tieing in the blast. <br />