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Mr. William T. Davis - 6 - April 25, 1989 In general, insufficient narrative requirements of state the maximum number explicit presentation of hole loading. information is provided to satisfy the general Rule 2.05.3(5)(a). The applicant doesn't clearly of holes to be fired simultaneously. There is no drilling patterns, delay configurations, and separate The applicant requests permission to blast closer than 500 feet from a natural gas transmission line, which is prohibited by Rule 4.08.4(7) unless specific permission is granted by the Division. The application contains a technical justification for permission to conduct limited blasting activities as close as 50 feet from the gas transmission line. This justification was prepared by a consultant for the gas transmission line owner. The status of this entire representation is unclear. The applicant is applying fora permit to mine ' coal. The application includes blasting activities. The applicant must be responsible for conducting those activities in accordance with the regulations and the permit. The application will need to be amended to clarify exac tly what blasting activities the applicant proposes to conduct. In general, the brief blasting justification presented by Lewicki and Associates mentions many of the necessary elements of an appropriate application for variance under Rule 4.08.4(7). However, significant elaboration will be necessary to obtain approval to blast up to 50 feet from the natural gas transmission line. Topics such as seismographic monitoring will need more detail to describe how the monitoring will be performed, what sort of equipment will be used, how the results would be interpreted, and how and when the results would be applied to control future blasting. Significant additional information will be necessary to justify the choice of 8 inches/second peak particle velocity as the acceptable tolerance limit for the specific pipe comprising the transmission line under consideration. A discussion of the possible consequences of a rupture and an emergency response plan would need to be developed. Rule 2.05.3(7) Reference to Exhibit Q would make the narrative under this section more complete. The location of this facility within the permit area should be specified and indicated on an appropriate map. Rule 2.05.3(8) The location of the designated area for non-coal waste should be specified and indicated on an appropriate map. The design of the non-coal waste disposal area should be discussed, i.e, bank or pit, location and nature, water barriers, etc. The discussion should address the requirements of Rule 2.05.3(8)(a).