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<br />COMMENTS AND RESPONSES <br />COLOWYO COAL LLC <br />TO ABATE VIOLATION <br />NOTICE OF VIOLATION CV-2003-013 <br />Dated: November 21, 2003 <br />Comment 1: Part 1: Implement a procedure, by submission of revised pages to the <br />Permit Application Package, that provides for accurate records with <br />regard to the maximum weight of explosives detonated with any 8- <br />millisecond time period. <br />Response: The new blasting procedure that has been in place for nine months is as <br />follows: <br />1) Utilize the timing model to determine the maximum number <br /> of blast holes that will ignite in any 8-millisecond period , <br /> this will determine the size of the blast pattern and the <br /> maximum amount of explosive to ignite at any 8 ms time <br /> period. <br />2) Compare this poundage of explosives to the "scale <br /> distance formula" result. If the blast design exceeds the <br /> criterion of the "scale distance formula," then we will revise <br /> the design until compliance is met. <br />3) Blast pattern design will then be sent to the field for <br /> implementation by the blasters. <br />4) Blast reports will then be recorded to meet the criteria <br /> noted in Rule 4.08.5 (1) thru (18) for surface coal mining <br /> operations. <br />Reference: See Volume I, Section 2.05, pages 28-28a <br />Comment 2: Part 2: Implement a procedure, by submission of revised pages to the <br />Permit Application Package, that includes the depths of hole and total <br />weight of explosives used per hole in a blast record. <br />Response: Colowyo has implemented a procedure in the field where each drill hole is <br />measured for depth and recorded on a Chargeweight Sheet to be <br />included in the blast record. <br />Reference: See Volume I, Section 2.05, Figure 3, pages 34b <br />CF 4.2.1.2 Remedial Action.doc <br />