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i~ <br />data in the field, these tools have not been proven at Colowyo in our <br />existing operating conditions. Colowyo will continue to explore high tech <br />pathways to improve reporting, design, data collection, and blasting <br />software to meet not only the effectiveness of the blast, but meet the <br />requirement of the law in a more efficient manner. <br />Therefore Colowyo firmly believes that the intent of the law is being met <br />through the aforementioned methodology. At this time, the amount of <br />effort and time necessary to generate an exact actual number of <br />maximum pounds of explosive detonated is not reasonable or necessary <br />to meet the intent of the law. This is not to say that Colowyo would not <br />explore future software applications or field communication tools that <br />allow for consistent and accurate information to efficiently detail the <br />information requested. Mr. Hernandez and myself did discuss possible <br />software that may allow us fo accomplish Phis Task, once the field data is <br />entered into the software. <br />Proposal: Colowyo will continue to calculate the maximum allowable pounds of <br />explosives detonated within any 8-millisecond time period using the scale <br />distance formula referenced above. <br />Colowyo will use the assistance of electronic software to determine the <br />timing sequence and calculate the maximum number of holes detonating <br />in any one 8-millisecond time period to determine the maximum amount <br />of explosives to would detonate during any one 8-millliseconds. This wil <br />then be compared to the result of the scale distance formula, to ensure <br />that the blast design is under the criterion. <br />Colowyo will continue to work with CDMG to improve blasting and record <br />keeping practices. Until a method of calculating the actual number of <br />pounds of explosives is reasonable in time consumption and can be done <br />efficiently and accurately (repeatedly), Colowyo will continue to use the <br />conservative calculated value (noted above) to determine maximum <br />pounds of explosives detonated in any 8-millisecond period. <br />Comment 2: Part 2: Failure to record in blast records the depth of some of the holes, <br />and thus, in turn, failure to record the total weight of explosives in those <br />holes. Repeated deficiencies in part for blasts of 11/2/02, 2/2/03, 2/3/03, <br />2/6/03, 2/12/03, 2/13/03, and 3/19/03. <br />Part 2, Blasting, blast record keeping -The depth of some holes <br />detonated in the 4:04 PM, February 16, 2003, blast (east side of the East <br />Pit), and thus, in turn, the total weight of explosives in those holes were <br />not included in the blast record. Repeated deficiencies in part for blasts <br />of 11/2/02, 2/2/03, 2/3/03, 2/6/03, 2/12/03, 2/13/03, and 3/19/03. <br />Response: Colowyo has identified the depth of the drill holes through the use of <br />actual drill logs. Problems that surround this method of reporting are <br />Notice o4 Vic(atinn Cu-2t~03-C;1,°, <br />C;ommant & i~tes~ansea <br />N'.C%~_HSEGiGENT1iA~ Plt_E SY`l'Et~11A.rJ ,C7itiG`fi 2 Perntit\4.2.7 GG^h~G ~ GSM Inspection <br />Reports_Pd~1Jst4.2.1 2 NC;V's13~.CV_~V_20Q~._G';3:Gornm~nt & Respcrse.doc <br />