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sketches contained in the blasting reports are now <br />determined unacceptable after a decade of comprehensive <br />review by both OSMRE and the Division. <br />5) Abatement <br />Abatement of the violation, in part, calls for a key to <br />the symbols used on the blasting report to be included on <br />the report. we understand the importance of providing a <br />key to the blast pattern sketches if it will facilitate <br />understanding of the reports. Similarly, we endeavor to <br />provide a key to the symbols on all reports and permit <br />maps where appropriate. We do, however, question the <br />issuance of a violation for what amounts to lack of a key <br />to the blast pattern sketches. <br />The issuance of violations for a lack of keys to symbols <br />on reports, maps or any other Permit document, appears to <br />indicate an example of unreasonable and pointless <br />enforcement on the part of the Division and sets a <br />dangerous precedent. Colowyo is certainly pleased to <br />provide additional explanations on permit documents, but <br />to risk enforcement actions for such items would appear <br />to be excessive. <br />In closing, we have attempted to show that the premise for the <br />NOV is clearly not valid. Colowyo blasting reports are complete <br />and contain all the necessary items required by the regulations. <br />The substance of this violation is merely a desire for more <br />clarification on records rather than a violation of the <br />regulations. <br />We also recognize that the NOV is issued in response to OSM <br />activities, but in this case the NOV is clearly not valid. <br />Please contact me if you need additional information. <br />Sincerely, <br />~~ u <br />Ja es A. Kiger <br />. Environmental <br />JAK/gdf <br />attachment <br />,~ <br />Specialist <br />cc: R. G. Atkinson <br />Central Files <br />