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N <br />A <br />III Illllllllllllill ~ <br />STATE Or ~; ~i ~~~:~ ~~ <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1 31 3 Sherman St., Room 215 <br />Denver, CO 80203 <br />Phone: (303) 866.3567 <br />FA%:(3031832-8106 <br />DATE: November 6, 1992 <br />TO: Mike Long <br />FROM: Larry Routten ~2 <br />RE: Request for Vacation of NOV C-92-030 <br />o' iota <br />~~ <br />ns <br />~ Iq'(5 ~ <br />Ruv Ramer <br />G ove;mar <br />Alit hael B. Lnnt <br />Dia¢mn D~reCOr <br />This memo is in response to Colowyo's November 3, 1992 request for <br />vacation of NOV C-92-030. As mentioned in Colowyo's letter, the <br />NOV was issued for failure to include blasting sketches on the <br />mine's blasting records. In regard to the points made in the <br />Colowyo letter: <br />1. Colowyo Daily Blast Records <br />I agree that the regulations do not specifically define a "sketch". <br />Consequently, the abatement written in the NOV does not require a <br />drawn sketch. We agreed that the blasting pattern symbols on the <br />records adequately describe the blasts, assuming that the meaning <br />of the symbols is clear. <br />2. Recxulatorv Intent <br />I do not know where Colowyo derived their understanding of <br />"regulatory intent" of Rule 4.08.5. Rule 4.05.8(7) states that, <br />"The record shall contain...sketches of the blast pattern" and that <br />the records shall be available for inspection by the Division and <br />the public. Colowyo contends that the records need not be self- <br />explanatory since personnel are available somewhere on the mine <br />site who can explain what the symbols on the records mean. I <br />believe that a reasonable interpretation of the regulations is that <br />the records should contain adequate information so that the person <br />reviewing them can reconstruct the blast with the information in <br />the records. <br />