Independent Review of MSHA's Actions at Crandall Canyon Mine

disapproval to the District Manager. The District did not comply with the above stated
program policy manual nor their own SOP.
Recommendation: The District Manager should implement a system to assure that, when
appropriate, input from field office personnel is obtained prior to recommending approval or
disapproval of a plan or plan revision.
8) Assistance from Technical Support not requested. MSHA’s Technical Support maintains
a Roof Control Division (RCD) that provides engineering and geological technical services
concerning the evaluation of roof support systems, mine design, and actual ground
conditions at surface and underground mining operations. The RCD has routinely used
the ARMPS program to evaluate retreat mining scenarios. The RCD has also conducted
numerical modeling since 1985, and has used the LAMODEL program extensively to
evaluate retreat mining layouts, including scenarios at bump-prone mines. In light of
District 9’s inability to conduct a LAMODEL analysis and their failure to properly evaluate
barrier pillar stability factors in the ARMPS analysis, assistance from the RCD should have
first been requested in September 2006 to help review the AAI reports.
Another instance where the RCD was not properly utilized was in May 2007. On May 10 th ,
District 9 requested RCD assistance in an investigation at the Company’s Aberdeen Mine.
The RCD responded by sending two investigators to accompany Owens to the mine on
May 23 rd . On May 22 nd , Owens traveled the Crandall Canyon Mine and observed
conditions on the South Barrier development section. RCD assistance was not requested
for this investigation even though both mines were in the same area and it would only
have required traveling to the Price area one day earlier.
When questioned about why he did not request Technical Support assistance for any
evaluations of the submittals at Crandall Canyon, Owens stated that he had “a high level of
confidence” in AAI. He also stated that in a lot of instances he didn’t have enough time to
send things to the RCD for review. However, in this case, a copy of the AAI reports could
have been forwarded to the RCD for review without requiring a field investigation. For
example, in another scenario from District 9 involving a retreat mining plan, the roof
control specialist from the Delta, Colorado Field Office requested assistance via e-mail in
early April 2007. An RCD engineer conducted an ARMPS analysis and replied to the
specialist within two weeks.
In addition to Owens’ failure to consult with Technical Support, Knepp and Davis again
failed to demonstrate adequate oversight. Knepp, as Assistant District Manager of
Technical Programs, had the responsibility to ensure that sufficient analysis of the
submitted data was conducted. Proper oversight by Davis and Knepp would have
revealed the inability of the District to conduct a thorough analysis of the data, and should
have prompted a request for Technical Support’s assistance.
30