Independent Review of MSHA's Actions at Crandall Canyon Mine

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On February 23, 2007, District 9 received a request to develop the South Barrier of Main West. The wording for the South Barrier submittal was essentially the same as submitted and approved for the North Barrier. The only notable difference was the plan for the South Barrier development contained the statement that was added via the January 18, 2007, amendment for the North Barrier section that permitted roof coal to be left in areas where weak immediate roof is encountered. On March 6 th , Owens recommended approval of the plan, with Knepp reviewing and recommending approval on March 7 th . The plan was approved by Davis on March 8, 2007. On May 17, 2007, a site-specific roof control plan amendment to allow pillar extraction in the South Barrier section was received by the District Office. A drawing, submitted as part of the plan, reflected a change in pillar dimensions that was implemented by the mine as recommended by AAI following a bounce in the North Barrier section in March 2007. Pillar width remained unchanged, but the pillar length increased by 37 feet. The plan included wording similar to that approved for pillar extraction in the North Barrier section. Statements that, “consultant reports indicate the development will avoid the majority of the side abutment stress transferred from the adjacent longwall panels,” and that, “these assessments have been validated by conditions experienced in the mine,” were once again included. On May 22, 2007, Owens traveled to the Mine to evaluate conditions on the South Barrier development section to determine if retreat mining would be feasible. An MSHA roof control specialist from the Price Field Office joined Owens in this investigation. According to notes taken by the specialist, an observation of the four entries revealed good roof conditions and “hourglassing” of the pillars. Owens stated that, compared to the North Barrier section, the observed pillar yielding was occurring closer to the face, and even the solid coal rib was yielding. As in the North Barrier section, the observed pillar yielding was thought to be desirable, and viewed as evidence that the pillars were not storing energy and, therefore, were not bounce-prone. Owens determined that retreat mining could be conducted. Also during the May 22, 2007, investigation, the issue of leaving pillars unmined to protect the bleeder entry was examined in detail. Like the plan for the North Barrier section, the original plan submittal for pillaring in the South Barrier section proposed leaving the pillar between No. 3 and No. 4 entry to protect the No. 4 entry as a bleeder entry. The South Barrier plan also specified that three pillars between entries Nos. 2 and 3 would be left for bleeder entry protection around an area where only three entries were mined at crosscut 140. Owens believed that this was inadequate because the entry to be traveled would now “stair-step” into the gob, creating a pillar-point. Mine management re-submitted the map portion of the plan to reflect that all pillars from crosscuts 139 to 142 would be left intact, and the barrier in this area would not be "slabbed" (mined into). On June 14, 2007, Owens recommended approval of the plan, also signing for Knepp on that day. On June 15, 2007, William Denning, District 9 Staff Assistant, was acting on behalf of Davis when this plan was forwarded for the District Manager’s approval. Denning stated that 16
he had concerns about approving this plan, but after consulting with Owens and receiving his recommendation, he signed the plan approving pillar extraction in the South Barrier section. Plan Approval Deficiencies Identified by the Independent Review Team The IRT identified the following shortcomings with District 9’s plan approval process. • Inadequate evaluation of the engineering data submitted by the operator to justify mining in the North and South Barriers; • Inadequate resolution of the inconsistencies identified in the engineering data that was submitted to justify mining in the barriers; • Failure to properly consider the impact of the March 10, 2007 bounce in the North Barrier section prior to approving retreat mining in the South Barrier section; • Failure of MSHA personnel to observe and evaluate pillaring operations; • Contradictions between approved plans and supporting data submitted to justify approval; • The manner in which MSHA 2000-204 forms were used impacted the adequacy of the required six-month plan reviews; • Field office personnel not involved in the plan approval process; • Assistance from Technical Support was not requested; and • Contradictions between Approved Roof Control and Ventilation Plans. These are discussed in detail as follows. 1) Inadequate evaluation of the engineering data submitted by the operator to justify mining in the North and South Barriers. At the request of Owens, Crandall Canyon mine management submitted information to support mining in the barriers in the form of two consultant’s reports. One of these reports consisted entirely of a discussion of numerical modeling using the NIOSH software program LAMODEL. Neither Owens, nor the engineer assigned to review the information, had ever used LAMODEL to analyze a retreat mining plan. Compared to empirically-based programs (like ARMPS), LAMODEL is fairly complex, requiring the user to construct a mining grid representative of the mining layout and correlated to overburden, and to make informed decisions concerning input parameters such as coal strength, rock modulus, and gob yield properties. Without 17
Page 1: Independent Review of MSHA’s Acti
Page 4 and 5: Protective Ground Support Used Duri
Page 7: Location of March Bounce Last Known
Page 10 and 11: EXECUTIVE SUMMARY The Federal Mine
Page 12 and 13: • Persons who could have contribu
Page 14 and 15: There was no lack of hard work and
Page 16 and 17: BLM INSPECTIONS OF CRANDALL CANYON
Page 18 and 19: oxygen and dust into the fresh air
Page 20 and 21: MSHA’S ACTIONS PRIOR TO AUGUST 6,
Page 22 and 23: that the proposed retreat sequence
Page 26 and 27: technical guidance from someone exp
Page 28 and 29: District management’s oversight w
Page 30 and 31: elieved that a higher stability fac
Page 32 and 33: questions were asked in an attempt
Page 34 and 35: offset between crosscuts 139 and 14
Page 36 and 37: To determine the validity of the in
Page 38 and 39: disapproval to the District Manager
Page 40 and 41: amendments for the South Barrier re
Page 42 and 43: The following table contains certai
Page 44 and 45: The Price Field Office did not inve
Page 46 and 47: The inspector stated that this even
Page 48 and 49: conducted every seven days. However
Page 50 and 51: Recommendation: MSHA should establi
Page 52 and 53: DIRECTION AND ACTIVITIES DURING THE
Page 54 and 55: 111-8, which was in effect at the t
Page 56 and 57: MSHA Person-In-Charge of Mine Rescu
Page 58 and 59: Davis stated that when Stickler and
Page 60 and 61: There was also no verification that
Page 62 and 63: employee stated, “Everybody got f
Page 64 and 65: Underground Phone Communication Sys
Page 66 and 67: PROTECTIVE GROUND SUPPORT USED DURI
Page 68 and 69: equipment to tram in and out of the
Page 70 and 71: Top of Rockprop Bottom of Rockprop
Page 72 and 73: Canyon the inby end of the ropes wa
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educed to writing and served to the
Page 76 and 77:
planned to film the underground res
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Stickler stated that family members
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Conclusion: MSHA failed to enforce
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Later on August 6 th , a mine rescu
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anybody sit down with the MSHA peop
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EXPLORATIONS During the underground
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since the ribs could not further ex
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DRILLING OF BOREHOLES Boreholes pla
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pump for a period of time, the meas
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After this hole was drilled, MSHA
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The borehole showed there was no vo
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RISK VERSUS VALUE In all rescue and
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stoppings to crosscut 95 would also
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section were equipped with Self-Con
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data, the idea was not pursued any
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for an hour and one-half and then w
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sampling equipment to their truck a
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Agency. The handbook consisted of 9
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updates and briefings on the rescue
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Utah Governor Jon Huntsman, Jr., MS
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Stickler contradicting or correctin
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trapped miners should, to the exten
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Conclusion: The MSHA person-in-char
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An attachment to the policy sets fo
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air and water waiting for us to com
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Davis did clarify that there was no
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the family and press briefings, and
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emergency with role-playing by all
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MINER ACT AND MINE EMERGENCY EVACUA
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Post-Accident Communications The MI
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Recommendation: The Agency should d
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At the time of the accident, the ER
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locations, and along normal travel
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CMS&H STAFFING AND RESOURCE UTILIZA
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CMS&H STAFFING LEVELS District staf
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In addition to the decreased levels
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completion rate decreased dramatica
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Other specialists had limited inspe
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ALLEGATIONS OF INFLUENCE BY THE MIN
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GENERAL CONCLUSION Internal Reviews
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APPENDIX A LIST OF PERSONS INTERVIE
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Moore, III, Clarence W. ...........
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List of Ground Control Panel Member
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Event Number Activity Code Genwal R
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Borehole #3 Location: #4 Entry, X-c
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Oxygen Content of Air: Sign and Sym
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EFFECTIVE DATE: 12/22/2006 EXPIRATI
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Act, Pub. L. No. 109-236, June 15,
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APPENDIX G PROGRAM POLICY LETTER NO
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2006. The MINER Act requires that t
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The above table is based on the 199
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2. Inflatable shelters or equivalen
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APPENDIX H PROGRAM INSTRUCTION BULL
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I. Quantity of Breathable Air. In d
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What is MSHA's authority for this P
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NORTH BARRIER Last Known Location o
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Independent Review of MSHA's Actions at Crandall Canyon Mine

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