Please find attached our comments regarding Refuge Alternatives for Underground Coal Mines; Proposed Rule.

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1 ,,m",*~~m,,,,,,, *,,,*,* a, rom: Stuart McLean Sent: Monday, ugust 18, :34 M To: zzmshstandards omments to ed Reg roup Subject: RIN Refuge lternatives for Underground oal Please find attached our comments regarding Refuge lternatives for Underground oal Mines; Proposed Rule. The response is specific to: ederal Register 1 Vol. 73, No. 116 I Monday, June 16, Proposed Rules Page Section ommunications acilities; Refuge lternatives Kind Regards, Stuart McLean ngineering Manager Mine Site Technologies

2 Mine Site Technologies Pty Limited N Website:www,minesite.com.au Sydney 2527 Whitina Street rtarmon ~Sih, 2064 (PO ox 156, rtarmon, 1570) Tel: ax: mail:mst@minesite.mau Kalgoorlie 17 Darcy Lane West Kalgoorlie W 6430 (PO ox 4200, Kalgoorlie, 6430) Tel: ax: mail:mstwa@minesite.wm~au ~t lsa / 15 Duke Street /"" ~t Isa QLD 4825 MIN SIT IXHNOLOlS (PO ox 2436, Mt Isa, 4825) Tel ax Part IV RIN Department of Labor Mine Safety and Health dministration 30 R Parts 7 and 75 Refuge lternatives for Underground oal Mines; Proposed rule With regards to: ederal Register / Vol. 73, No. 116 /Monday, June 16,2008 / Proposed Rules Page Section ommunications acilities; Refuge lternatives Paragraph (a) would require that refuge alternatives be provided with a twoway communication system and an additional communication system when approved in the mine operator's mergency Response Plan. ommunications with the persons in refuge alternatives are vital to mine rescue efforts. The knowledge of where miners are in refuge alternatives, their condition, and the conditions in the mine may make the difference between lifeanddeath in a postaccident crisis. Paragraph (a)(]) would require a two way communication facility that is a part of the mine communication system, which can be used from inside the refuge alternative. The communications device must be usable without further exposing persons to smoke and toxic gases. MSH solicits comments on the proposed twoway communication facility. Please be specific in your response, including alternatives, rationale, safety benefits to miners, technological and economic feasibility, and data to support your comments. Paragraph (a)(2) would require an additional communication system when approved in the operator's mergency Response Plan (RP). Pream ble. s MSH is soliciting comments on a proposed twoway communication facility, Mine Site Technologies (MST)is attending MSH's public hearings and making comment to inform MSH (and others) that MST are actively working on a dedicated and truly wireless solution for communications with refuge structures. Overview. Mine Site Technologies has spent 20 years designing and developing mining specific communication systems dedicated for use in underground coal environments and always with an emphasis on safety. MST have been widely known for their "Through the arth" communications technology and recent collaboration with ustralia's "ommonwealth Scientific and Industrial Research Organisation (SIRO), have developed and demonstrated a "Proof of oncept" 2 way system highly suited to refuge environments. MST proposes a communications system suited to a refuge & rescue environment consisting of a near field (magnetic) idirectional (2 way) synchronous Through the arth (TT) communications link. This link will provide the miner retreating to a refuge with the ability to send and receive text messages from the surface without any dependence on extensive underground infrastructure, such as antennas cables or numerous underground nodes or devices that would possibly be destroyed or severely disabled in any major incident underground.

3 The communication link's proprietary protocol and modulation scheme are noise tolerant, advantageous, self adjusting and specifically devised to provide a robust transfer of data considerate of the noise and geophysical strata typically associated with underground coal mining environments (inclusive of surface noise). The system consists of a permanently fixed refuge based unit assigned as a "Slave" whilst the "Master" unit is intended to be portable and would be deployed on the surface above the refuge (collinear with the refuge unit). The master unit can also be deployed beside the refuge e.g. on the other side of a rockfall, mine collapse or hazard (coplanar with the refuge unit). Other than distinctly different power requirements1 components, both units have 3 primary elements. High sensitivity receiver. Simple single turn transmit antenna The actual Slave1 Master units electronics, hardware and the user interface. The Refuge Slave. Devised to provide 96 hours of operation % duty and a further 48 hrs at a reduced duty of 50%. ontinually outputs a beacon type signal consisting of its designation, occupied state of the refuge, power status and could possibly be interfaced with other refuge facilities to provide useful information e.g. ir quality etc. Once contacted by a Master it adopts synchronous communications as dictated by the Master where Quality of Signal will dictate communications rates. Tactile QWRTY keyboard backlit cognisant of low to zero light environments. ognisant of the need to provide efficiency thus minimal impact to the thermal state of the refuge. LD screens indicating link status, sent and received messages, logging, scrolling etc. variety of audible and visual aids as to system status and user input response. The system is intuitive and instructions (both printed and reinforced on the LDs) assist the miner in proper use of the system. ble to repeat signals from other refuge units within range of refuge unit but may be isolated from the Master. The Surface Master s above including: Portable easy deployable. n ability to associate with up to 3 refuge units directly or sequential serially. Dictates all communications selectable normal and Deep Mine (or high noise) mode. Mine Site Technologies are now in the development phase of production ready units for submission to MSH and other Intrinsically Safe approval entities. ttached drawings provide a general view of the concept of the system. Yours faithfully, Stuart Mclean ngineering Manager Mine Site Technologies Pty Limited.

4 f KY 1. ILD VHIL DPLOYD 2. SUR UNIT DLIVRD TO PPROPRIT R MRKR/ PS DIND etc. 3. SUR UNIT PORTL an ommunlcate with up to 3 Refuge Units 4 SUR RNIN MODUL 5. SUR DPLOYD LOOP 6. INTRINSILLY S SUPPLY 8 TTRY KUP 7. RU UNlT PRMNNT (Typically) 8. RU RNIN MODUL 9. PRMNNT RU LOOP USULLY URID 10. MlN WID POWR SOUR (1 lov to 1kV) Power Is Removed if a Hazard Presents 11. RU Y HMR Distributed Throughout the Mine Steel. 12 ILD VHIL S LTRNT / SUPPLMNTRY nry KUP/ R~HR 9 NVIRONMNT XTRM WTHR HIH LVLS O LTRIL / INTRRN NOIS PORTL POWR ONLY RSTRITIV TRRIN? 10 \ D SD[MNTRY~STRT a NVIRONMNT ONLY PLMP LIHT. MTHN IL OL DUST. KUP POWR ONLY. THRML DIRNTIL TO SUR. i NOTS SL PROVISSIONL (ONPT ONLY) DNS D O ISION NOT PROVISSIONL DRN SML PP DT 19/3/08 MIN SIT THNOLOIS PTY. LTD WHITIN STRT. THNOLOIS 'IT RTRMON NSW 2064 Phone ax: Th~s draw~ng and des~gn is the property of MlN SlT THNOLOIS PTY LTD. It is subject to their recall and must not be reproduced or 11s contents divulged to any th~rd party wlthout prior written approval of MlN SlT THNOLOIS PTY LTO PRDDUT SPT DRWlNlD RRN RPOOI RU Y PD SYSTM OMPONNTS XPTD DPLOYMNT DT SHT 1 O 1

5 MSTR NORMLDPLOYMNT UP TO 3 RU YS SQUNTIL SINLIN MSTR RU 2 RU 1 RU 3 I b RU I RPTR 1 ONSIDRTIONS > 48 HOUR ONTINUOUS DUN. > 96 HOUR RDUD DUTY RU UNITS LWYS POWRD RU ONTINULLY ONS ID. POWR STTUS. OTHR STTIONS SN 8 I RU IN US. ON DUTY SUITL OR 5 MINUT SRH OR POSITIV RSPONS. RU LISTNS OR OTHR STTIONS. INVOK 'SNOOZ' YLS ON LINK STLISHD TO XTND OPRTIN TIM. MSTR N DPLOYD OV SUR OR UNDRROUND w. T ROK LL. NO USR OMMS TWN RUS LL USR OMMS VI MSTR. KY DOWNLINK SINL TRNSMIT LOOP MSTR ISOLTD RU RU 1 TS S RPTR OR RU 2. SQUNTIL 1 SRIL RRNMNT DT PSSS THROUH RPTR ONLY ND IS NOT DISPLYD T RU (RPTR) 1. RU 2 UPLINK SINL NOTS. PROVISSIONL ONPT ONLY1 SL DNS c 0 O ISION NOT PROVISSIONL DRN SML PP DT 10/4/0a Phone. MIN SIT THNOLOIS PN. LTD WHITIN STRT, TIINOLWIS 'IT RT RMON NS ax HRDROK MlN DPLOYMNT (DLIN) RU 1 TS S RPTR OR RU 2 RU 2 TS S RPTR OR RU 3 SQUNTIL / SRIL RU Y PD Th~s drawlng and destgn IS the property of MlN SlT THNOLOIS PTY LTD. It IS subject to the~r recall and must not be reproduced or 11s contents d~vulged to any th~rd party w~thout prlor wrltten approval of MlN SlT THNOLOIS PTY LTD SPT SHOWIN DRWIN/D RRN RP002 DPLOYMNT NTIIPTD RRNMNTS P OT SHT 1 O 1