RECEIVED

CLERK’S OFFICE

lillfl:C..IS

Department of

.•

MAY

272005

Natural

Resources

One

Natural. Resources Way

Springfield,

Illinois

627O2~127i

Joel

BrjnsvOld,

Director

http~//dnr.stateJLus

May 26,

2005

DorothyGunn, Clerk

illinois Pollution Control Board

100 W. Randolph, Suite 11-500

Chicago, IL 60601

Re:

Proposed New and Updated Rules

for Measurement and Numerical Sound Emission

Standards/Amendments to

35

Iii.

Adm. Code 901

and 91 0/Docket R03-9

COmments

Dear Ms. Gurm:

The following comments are submitted by the Illinois Department ofNatural Resources, Office of

Mines

and

Minerals,

Mine

Safety and

Training

Division

in

reference to

the above

referenced

amendments.

Blasting operations at all surfaceaggregate and coal mines are regulatedby the Illinois Department

ofNatural Resources (IDNR), Office of Mines and Minerals, Mine Safety and Training Division.

I1DNR’s•

comprehensive blasting regulations

help prevent personal injury and

property damage

through the use of the conservative

limits of one inch per second

ground vibration and

133

dB

maximum air over pressure.

These limits

are nationally recognized

and

accepted industry and

regulatory standards.

The IDNR determines regulatory compliance by routinely inspecting’ and

monitoring blasting at all oftheState’s

172 active aggregate and coalblasting sites.

IDNR’ sblasting

regulations are administered by a staff of 13 people with over

100

years ofcombined explosives

related

experience.

Field inspectors trained

in

the.technical

elements of seismology regularly

monitor blasting induced ground vibration and air over pressurewith stateofthe art seismographs.

TheDepartment currentlymaintains an in

t~iy~f3Q

.

si~ich

seismographs...

The Department respectfully submits the following comments for your consideration:

1.)

Sectjon 901.109(a) amends the Receiving Class

A Land limit from 109

to

107

and

the Receiving Class

B

Land limit from

114 to

1 12~The Office of Surface Mining

(0SM), the federal surfacemining agency with oversight authority over the IDNR’

s

coal regulatory program, and IDNR’s aggregate blasting regulations correctly allow

105dB C-weighted as the equivalentto 133 dB.

Theproposed limits areinconsistent

with

and

less

restrictive than the previously stated

105dB

C-weighted /133

dB

equivalency.

Printed on recycled and recyclablepaper

---

2.)

Section

901.1.09(c)

introduces

a

10dB

reduction

to the

133dB

airbiast limit for

blasting prior to

7:00 A.M.

It should be noted that decibels are a logarithmic scale

-

and reducing thelimitfrom 133dB to 123 dB is a 70

limit reduction.

It should also

be noted that IDNR regulations limit routine blasting conducted at surface coal and

aggregateoperationsto theperiod betweensunrise and sunset except in documented

emergency situations.

IDNRsuggests that this section be amended to solelyreflect

the established IDNR sunrise to sunset blasting restrictions.

3.)

The regulatory

limits

referenced in

the proposed amendment

appear to

address

monitoring

and

limits

at

the “property line.”

IDNR’s regulatory

performance

standards applyto limits atthe nearestprotected structure.

A protected structure as

defined under 62

Illinois Admin.

Code 300.210, is any dwelling, public building,

school,

church or commercial

or institutional

building that

is

not

owned by the

operatororsubject to a waivergranted to the operatorfrom theDepartment’s airblast

and

ground vibration requirements.

It

is unclear

what the intent of the proposed

establishment ofthe proposedlimits atthe propertyline willaccomplish asitpertains

to controlling adverse affects from mining.

.

.

4.)

Monitoring methods for the limits proposed

in Section 901.109 are not referenced

in Section 910.

5)

The

monitonng

methods

descnbed

in

Section

910

do

not

apply

to

IDNR’s

established

and required monitoring procedures.

“Highly Impulsive

Sound

from’

Blasting” is monitored with the use ofa blasting seismograph specifically designed

for this purpose utilizing

a

flat response,

sound pressure level

microphone

and

recording device.

.

It

should

be noted that

air over-pressure

resulting

from pnmary

airblast

is

charactenzed as an

impulsive

noise pnmarily

in the infrasomc range

Most of the

energy is

maudible because its

frequency content

is

below

the range of human hearing (20Hz to

20kHz)

Consequently,

the

proposed rules are trying to

fit ‘air over-pressure (airbiast) within the scope ofintrusive noise and

sound regulations when in fact they are two totally separate issues.

IDNR respectfully suggests that the surface aggregate and coal blasting provisions ofthese statutes

_.be

deferred to. our agency. for reguJation. SMchdeferm~nt

would help preventi

consis

sand

redundancies between regulatory authorities with distinct and separate regulatory roles.

Sincerely,

~

osep

R. Angleton, 0ffi~’~itector

•

0

fMines and Minerals

cc:

N.Banach

N.Williams

M.Falter

J.Hafliger

.

.

Service List

.

.

Printed

on recycled

and

recyclablepaper