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Please note the examples submitted in the attached <br />correspondence to the Division dated October 22, 1992 <br />(attached for your information). The regulations are not <br />specific as to the definition of a "sketch" but, <br />nevertheless, our particular method of using symbols as <br />the blast pattern sketch has been used effectively for <br />over a decade. <br />3) <br />Regulatorv Intent <br />The intent of the regulation in question is to provide <br />that there is specific information available to the <br />regulatory authority to essentially recreate every blast <br />should some unforeseen controversy arise. As we noted in <br />the October 22, 1992 letter, Colowyo's blasting reports <br />do provide all of the information necessary to recreate <br />the blast. Since the blasting reports are inspected only <br />at the minesite, there are always opportunities for <br />inspectors to question Colowyo operations personnel about <br />a particular blast. We believe we demonstrated this <br />quite well at the time of the oversite inspection. <br />Blast Records Contain other Symbols <br />Colowyo blasting records contain other symbols as well. <br />For example, to provide the Division with the location of <br />each shot "Cut Number" and "Station to Station", numbers <br />are used. These symbols represent information unique to <br />Colowyo and would be meaningless to an inspector unless <br />Colowyo operations personnel are questioned as to their <br />interpretation. Similarly, symbols used for the blast <br />pattern sketches may also be meaningless to an inspector, <br />but nevertheless, the required information is contained <br />on the blasting report. <br />We do not believe that the lack of definition of symbol <br />meaning for blast pattern sketches constitutes a <br />violation, just as using other unique symbols for blast <br />location would not constitute a violation. Symbols are <br />merely an efficient means of summarizing information on <br />the blasting report in an effort to cut down on needless <br />paperwork. <br />4) Blasting Record Inspections <br />Colowyo's blasting reports have received close scrutiny <br />in the past by both OSMRE and the Division. Similar <br />blast pattern sketches contained on the previous reports <br />were discussed during past inspections and no problems <br />with this procedure had ever been noted. As we noted in <br />our October 22, 1992 letter to the Division, we find it <br />incomprehensible why the Colowyo blasting pattern <br />