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2017-10-23_GENERAL DOCUMENTS - C1980007
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Last modified
10/24/2017 7:12:12 AM
Creation date
10/24/2017 6:56:38 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
General Documents
Doc Date
10/23/2017
Doc Name
Compliant and Request for Inspection Over Failure of West Elk
From
Wild Earth Gurdians
To
DRMS
Permit Index Doc Type
General Correspondence
Email Name
MPB
JRS
LDS
Media Type
D
Archive
No
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1980-007. This permit was most recently renewed in 2011 and West Elk submitted renewal <br />applications in 2016. Further, because much of the coal mined by West Elk is leased federal <br />coal, mining has also required approval from the Secretary of the U.S. Department of the Interior <br />in the form of a "mining plan" issued pursuant to 30 C.F.R. § 746. Over the years of West Elk's <br />operation, the Secretary's Office has approved a number of mining plans and modifications of <br />those plans. Most recently, the Secretary approved mining plan modifications authorizing coal <br />extraction from federal coal leases COC -67232 (approved June 10, 2008), C-1362 and COC - <br />56447 (approved July 31, 2008), and C-1362 and COC -67232 (approved January 15, 2009). <br />While the West Elk mine is an underground mine, the operations require extensive <br />surface disturbance associated with methane venting. While normally methane gas, which is a <br />safety hazard, is vented through a mine's central ventilation system, West Elk must vent methane <br />through drainage wells drilled above the mine. The U.S. Forest Service has explained: <br />In recent years, the coal mines operating in the Somerset coal field have experienced the <br />build-up of methane gas in the underground workings after the overlying rock strata have <br />subsided into the mine void (called the gob).... <br />Typically, the in -mine ventilation system cannot effectively keep methane levels within <br />safe working range, therefore additional methane liberation methods have to be <br />employed. Existing operations at the West Elk Mine, as well as other mines in the North <br />Fork Valley, have used a system of methane drainage wells (MDWs) to assist in <br />liberating methane from underground mine workings. These MDWs are drilled from the <br />land surface into the strata overlying the coal, and use an exhausting blower to pull gas <br />from the rock formation, and subsequently air from the mine .... Due to the large amount <br />of methane found in the West Elk Mine, the agency requires MDWs to be placed every <br />1,000 to 750 ft. along the longwall panel .... Methane drainage well construction is <br />essential for operating longwall operations in the North Fork Valley. <br />U.S. Forest Service, Final Environmental Impact Statement, Federal Coal Lease Modifications <br />COC -1362 and COC -67232 (August 2012) at 51 (hereafter referred to as the "FEIS"), available <br />online at <br />http://al23.a.akamai.net/7/ 123/11558/abc 123/forestservic.download.akamai.com/l 1558/www/ne <br />pa/68608_FSPLT2 263949.pdf. <br />According to West Elk's most recent reports to the U.S. Environmental Protection <br />Agency ("EPA"), the mine emitted 16,115 tons of methane in 2016, making it the single largest <br />industrial source of methane emissions in the State of Colorado. See EPA, "West Elk Mine <br />Greenhouse Gas Emissions," available at <br />https:Hghadata.epa.gov/ghgp/service/facilit_yDetail/2016?id=1010310&ds=E&et=&popup=true. <br />Methane is not only a safety hazard, it is a potent greenhouse gas. The Intergovernmental <br />Panel on Climate Change ("IPCC") reports that methane is 34 times more potent than carbon <br />dioxide over a 100 -year period and 86 times more potent over a 20 -year period See IPCC, <br />Climate Change 2013: the Science Basis. Working Group I Contribution to the Fifth <br />Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge University <br />5 <br />
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