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Memo to Tyson Powell 2 September 2I, 2006 <br />Blasting Vibration Control Plan File No. M-2004-067 <br />The DRMS rejects the foregoing statements and the entire azgument that the Mined Land Reclamation <br />Boazd (NLRB} erred in its determination that sufficient blasting controls are included in the permit <br />application. The basis for the DRMS's position is as follows: <br />The so-called commonly acceptable vibration levels maligned by the sanitation district do in fact <br />assure that through compliance with permit conditions that blasting at the proposed quarry will <br />cause no more than 0.75 inches per second peak particle velocity ground vibration at the sewage <br />treatment plant. Vibration studies conducted over the last 44 years, and the literature produced, <br />consistently demonstrate that vibrations of this amplitude are so small that they will not propagate <br />pre-existing tiny plaster cracks in sheet rock walls. Given the results of these studies, any <br />assertions that quarry blasting could damage concrete tanks at the sewage treatment plant aze <br />patently absurd. <br />It is likely that the sewage treatment plant uses monitoring instruments and other equipment with <br />limited vibration tolerance. However, any designer and/or manufacturer of industrial equipment <br />recognizes that vibration is pervasive and will produce equipment that will tolerate vibrations that <br />will ordinarily occur in facilities where the equipment will be deployed. The DRMS produced a <br />memo dated November 21, 2005 with literature citations demonstrating that vibration sources <br />including door slamming, nail hammering, and walking across floors by heavy set persons can <br />cause vibrations in excess of one inch per second peak particle velocity. That same memo <br />references literature citations demonstrating that door slamming causes vibrations with amplitudes <br />from 0.47 to 1.38 inches per second and foot stamping causes vibrations of 0.20 to 1.97 inches per <br />second peak particle velocity. The memo is part of the MMRR permit application file, and thus is <br />part of the record of the NLRB hearing on the quarry permit application. A copy of the DRMS <br />November 21, 2005 memo is attached. <br />If industrial requirements are such that vibration sensitive instruments and/or equipment must be <br />deployed, there aze readily available and effective vibration damping mounting devices that will <br />prevent vibration related damage. The DRMS testified to these facts during the NLRB hearing <br />into the MMRR Quarry permit application, and the DRMS testimony in this regazd was then, and <br />remains to this day un-refuted by the objectors to the quarry permit application. No qualified <br />industrial engineer or industrial facilities designer would neglect the criticality of vibration <br />tolerance in design of a sewage treatment plant such as the plant in question. If this plant is <br />incapable of operation under vibration stresses as trivial as the 0.75 inches per second maximum <br />peak particle velocity allowed under the approved MMRR Quarry permit application, then the <br />plant is incapable of operation under normal operating conditions. <br />When the Sanitation District initially asserted the claim that the instnunents and equipment in the <br />sewage treatment plant were particularly vibration sensitive, the DRMS requested information <br />about the plant's equipment and instnunentation vibration sensitivity. The Sanitation District, <br />through their consultant, Leonard Rice Engineers provided vibration tolerance information for one, <br />and only one, of the instruments in the sewage plant. That instrument is certified by the <br />manufacturer to be tolerant of vibrations of up to 2.Og, or two times the acceleration of gravity. <br />Tolerances in this range aze typical of highly sensitive instrumentation. The DRMS presented un- <br />refuted testimony at the NLRB hearing into the subject permit application that 2.Og acceleration <br />vibrations aze well in excess of the maximum 0.75 inches par second peak particle velocity <br />