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Independent Review of MSHA's Actions at Crandall Canyon Mine

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though Owens conducted on-site evalu<strong>at</strong>ions <strong>of</strong> mining activities in both the North and<br />

South Barriers, those investig<strong>at</strong>ions took place during development mining. It would be<br />

prudent, in order to evalu<strong>at</strong>e the additional abutment loading from pillar extraction, to<br />

also observe pillaring oper<strong>at</strong>ions. When pillaring oper<strong>at</strong>ions began on the North Barrier<br />

section on February 16, 2007, there was a ro<strong>of</strong> control specialist assigned to the Price Field<br />

Office, yet Owens did not assign him to observe retre<strong>at</strong> oper<strong>at</strong>ions. In addition, neither<br />

Knepp nor Davis questioned the lack <strong>of</strong> on-site observ<strong>at</strong>ion <strong>of</strong> retre<strong>at</strong> mining oper<strong>at</strong>ions.<br />

In keeping with the intent <strong>of</strong> the four-stage plan approval process, an evalu<strong>at</strong>ion <strong>of</strong><br />

pillaring oper<strong>at</strong>ions in the North Barrier section should have been used as a basis for<br />

determining approval <strong>of</strong> pillaring in the South Barrier section. Furthermore, knowledge <strong>of</strong><br />

the March bounce event raised the need for observ<strong>at</strong>ion <strong>of</strong> pillaring to an even higher level,<br />

but such observ<strong>at</strong>ion never took place.<br />

Conclusion: To adequ<strong>at</strong>ely evalu<strong>at</strong>e the retre<strong>at</strong> mining process <strong>of</strong> a four-stage approval, an<br />

on-site investig<strong>at</strong>ion should have been conducted while retre<strong>at</strong> mining was ongoing. The<br />

failure <strong>of</strong> District 9 to observe pillaring oper<strong>at</strong>ions in the North Barrier section was a missed<br />

opportunity to obtain valuable inform<strong>at</strong>ion concerning approval <strong>of</strong> pillaring in the South<br />

Barrier section.<br />

Recommend<strong>at</strong>ion: An on-site investig<strong>at</strong>ion should be conducted <strong>of</strong> each phase <strong>of</strong> all unique<br />

or non-typical mining plans.<br />

5) Contradictions between approved plans and supporting d<strong>at</strong>a submitted to justify<br />

approval. According to Owens, recommend<strong>at</strong>ions made by AAI were used to justify<br />

approval to mine the North and South Barriers. However, several <strong>of</strong> the recommend<strong>at</strong>ions<br />

made in the April 18, 2007, report were not implemented into the June 15, 2007, approval<br />

for pillar extraction in the South Barrier section.<br />

In the April report, AAI recommends th<strong>at</strong> the pillars be lengthened by 37 feet. However,<br />

the site-specific plan approved in March for development <strong>of</strong> the area was not modified to<br />

reflect the new recommended pillar size. Although the new pillar size was implemented<br />

by mine management, the lack <strong>of</strong> a plan change meant th<strong>at</strong> it was never a requirement to<br />

do so.<br />

AAI concluded th<strong>at</strong> skipping pillars, or leaving pillars unmined, contributed to the March<br />

10 th bounce in the North Barrier section, and emphasized the importance <strong>of</strong> this with the<br />

st<strong>at</strong>ement in the April report th<strong>at</strong>, “skipping pillars should be avoided in the South Barrier,<br />

particularly under the deepest cover.” This recommend<strong>at</strong>ion was not reflected in the ro<strong>of</strong><br />

control plan. The impact <strong>of</strong> skipping pillars was not examined by the District (no modeling<br />

<strong>of</strong> this aspect was undertaken), nor was the aspect <strong>of</strong> “deepest cover” defined in any<br />

manner. In fact, Owens required three full rows <strong>of</strong> pillars to be skipped around the sump<br />

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