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COMMENTS AND RESPONSES <br />COLOWYO COAL LLC <br />NOTICE OF VIOLATION CV-2003-013 <br />Dated: November 21, 2003 <br />Comment 1: Part 1: Failure to limit the maximum pounds of explosives detonated <br />within any 8-millisecond time period to the amount allowable. Failure to <br />record the actual maximum weight of explosives detonated within 8- <br />millisecond time period. <br />Part 7, Blasting -The calculated allowable weight of explosives <br />detonated within an 8-millisecond time period for the 4:04 PM, February <br />16, 2003 blast, at the east side of the East Pit, was 3, 303 pounds. The <br />maximum weight of explosives detonated within an 8-millisecond time <br />period recorded on the blast record was 2, 970 pounds. The <br />reconstructed maximum weight detonated (reconstructed) was 9,135 <br />pounds. <br />Response : Failure to limit fhe maximum pounds of explosives detonated within <br />any 8-millisecond fime period to the amount allowable. <br />Colowyo uses the "scale distance formula" [Rule: 4.08.4 (10)(c)(i)] to <br />determine the maximum allowable amount of explosives to be detonated <br />within any 8-millisecond time period. Colowyo personnel calculated the <br />maximum allowable amount of explosives correctly. However, the timing <br />sequence of detonation was in error, thereby resulting in exceeding the <br />requirement. <br />After a comprehensive investigation of this incident, the root cause was <br />determined to be a mis-calculation on the timing sequence of the blast <br />hole initiation. Traditionally, the timing calculation for a blast was <br />conducted using long hand or manual calculations. This method of <br />calculation has more opportunity for error when figuring the blast timing. <br />In February, Colowyo was manually calculating the blasts for initiation <br />timing. <br />Shortly after this event, Colowyo modified their timing sequence <br />calculations by the use of a model that was developed in-house. This <br />model was developed through the use of a Excel spreadsheet that <br />includes all the necessary burn times for initiation cords, surface delays <br />and in-hole delays. All that is necessary is to enter the hole spacing, <br />initiation sequence, and the number of holes and rows to calculate the <br />maximum number of holes that will ignite in a 8-millisecond time period <br />during the blast event. If the maximum amount of powder is exceeded, <br />based on the estimated amount of explosive for the deepest hole, times <br />the number of holes ignited in that 8-millisecond time period, then the <br />blaster can modify the placement, number, and type of delays necessary <br />Natic~: of Violation GV-20Q3-0i3 <br />Gomm2nt & Responses <br />R ;GCG HSEC~;CENTRAL PILE ~Y576Frit~.(J G6rviG?4.~ Ferrn)t1~2.i CC(~~G & GS#v~ hnsoecYion <br />ReParfs NC3Vs'W.2.12 NOV's1(~C~V_ CV__2063„_G13`:Gamment & Respcrss^..coc <br />