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Richard D. Lamm Governor DEPARTMENT OF NATURAL RESOURCES DaviO H. Getches, Executive Director MINED LAND RECLAMATION DI\ DAVID C. SHELTO N, Director DATE: October 15, 1985 T0: Steve Renner FROM: Jim Pendleton RE: Peabody Coal mpa s Response to Seneca II-W Draft Stipulation No. 12 (Permit N C- 57) In response to your request I have reviewed the submittal made by Peabody Coal Company in response to Stipulation No. 12, included in your proposed Findings for Seneca II-W application. I forward the following comments for your consideration. Stipulation No. 12 required that Peabody Coal Company "demonstrate that blasting operations within 500 feet of the oil well will not damage the integrity of the well casing and detail the safety precautions which will be utilized to insure that vented gas is not ignited". The company proposes in its response to "contact the owner of the well to see what limits of vibration casing will withstand". Until that demonstration has been completed, it is impossible to determine whether compliance with the standard loading limitations of the scaled distance equation W=(D/60) will suffice. Therefore, the operator statement of intent to comply with the regulations does not satisfy the Division's concern expressed in original Stipulation No. 12. Further, the company proposes to take steps to control sparks and other sources of ignition, which should definitly reduce the hazard of vented gas ignition. However, I believe it would also be appropriate to determine what level of vented gas actually exists prior to blasting. It should not be difficult to monitor the area of the proposed blast with an appropriate hydrocarbon sniffer prior to detonation. I do not believe that the operator's response in this regard is sufficient to satisfy the Division's concerns. For both the above reasons, I believe the company's response to be inadequate to satisfy the Division's concerns regarding the detonation of explosives within 500 feet of a petroleum or gas producing well. Therefore, I recommend that Stipulation No. 12 be retained as originally drafted. /ph cc: Mike Savage Doc. No. 4144 423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567