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Memo to Jim Stevens Rimrock Geotechnical Adequacy page 3 2. 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 number of legalistic letters exchanged by the applicant and the owner of the natural gas line. The application also contains a brief and inadequate technical justification for permission to conduct limited blasting activities as close as 50 feet from the gas transmission line. This justification was apparently prepared by a consultant for the gas transmission line owner. The status of this entire representation is unclear. The applicant is applying for a 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, should they receive one. The Division has no desire or authority to become embroiled in civil disagreements between the applicant and other parties. The application will need to be amended to clarify exactly what blasting activities the applicant proposes to conduct. 3. 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 of 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. Protection of Underground Mining (Rule 4.19) 1. Intercepted underground workings could contain Methane, Coal Damp and other gases which might be dangerous to the miners, the general public and the environment. Exposure of underground workings to air could present a spontaneous combustion hazard. The applicant must obtain approval of MSHA and the Division, in order to comply with the specific requirements of Rule 4.19.