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Michael Long <br />October 27, 1993 <br />Page 3 <br />ground vibration is offered to support this fact, and indicate <br />Peabody Western conducted the subject blast in accordance with <br />the approved plan. <br />1. Vibra-Tech Engineers, Inc. has been processing and <br />evaluating seismographic data from the Seneca II-W Mine <br />since operations began. Vibra-Tech has provided Peabody <br />Western with references and related documentation that <br />affirms engineered structures such as wells and tanks can <br />withstand peak particle velocities of at least five inches <br />per second (ips). Seismograph monitoring records for the <br />area of concern indicate that ground vibration has never <br />been in excess of 4.0 ips at the oil well site. Thirty- <br />eight blast records have been analyzed with the majority of <br />peak particle velocities being under 1.0 ips. Two records <br />were in excess of 2.0 ips. The well site has not been <br />adversely affected by ground vibration caused by blasting <br />in the vicinity. <br />2. Peabody Western has not blasted within 500 feet of the oil <br />well in accordance with the approved blasting plan (Tab 14 <br />of the permit document) and State regulations. <br />3. The original permit issuance document (1985) contained <br />Stipulation No. 9 to prevent blasting within 500 feet of <br />oil wells unless a no effect demonstration could be made. <br />Stipulation No. 9 was satisfied on June 23, 1989, with a <br />commitment to not conduct blasting within 500 feet of such <br />facilities. <br />4. Concern about protection of the oil well was brought up in <br />an OSM oversight inspection on 9/26/90. The OSM inspectors <br />stated: "The reviei,' cf the blasting records initially <br />indicated that the operator was not complying with the <br />requirements to detonate certain amounts of explosive <br />within an eight millisecond period. Further review <br />indicated that the structure that was listed on the <br />blasting record (an oil well) is not one that is controlled <br />pursuant to the Colorado Rules at 4.08.4(101". (Emphasis <br />added). The oil well site is within the permit area. The <br />blasting operations were conducted in accordance with the <br />scaled distance formula as stated in Tab 14 and Rule <br />4.08.4(10(b)(i). A distance, in the scaled distance <br />formula, to the nearest dwelling outside the permit <br />boundary was utilized as specified in the approved plan and <br />as required by regulation. <br />The inspection report asserts the fly rock was not in compliance <br />with the intent of the Colorado Surface Mining Reclamation Act <br />(34-33-102). The State regulations implement the requirements <br />