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Coal Methane Drainage Project - PaneG 16-24 War! Elk Mine • Page 2-9 <br />conditions, operators would collect methane gas directly at the wellhead for sale or on-site use. <br />Because of variable gas quality and quantity, difficulties in coordinating commercial gas recovery with <br />underground mine degasification requirements, and the economics of commercializing methane <br />mixed with air, however, coal mine operators commonly vent methane to the atmosphere and do not <br />capture the gas. <br />In these cases, safety and environmental objectives could be satisfied by carefully flaring emitted gas. <br />Gas flaring is a standard safety practice in some industries. For example, methane and other <br />associated gases aze routinely flared during processing and production of oil and gas, and ate <br />continuously Hazed from landfill collection systems. Incorporating a controlled flare system would <br />minimize the potential of an unconfined conflagration occurring on the surface at the MDW <br />discharge location(s), brought about by natural or man-made sources reduce greenhouse gas effects <br />on the atmosphere through completion of the hydrocazbons. <br />The Environmental Protection Agenry is currently sponsoring research and outreach efforts [o coal <br />mine operators to encourage coalbed and coal mine methane capture or flaring. (Reference <br />~~~.v.ena.nov/coalbed). The methodology for flaring methane emissions from underground coal <br />mines is emerging but remains technologically speculative at this time. The hazard that flaring could <br />create an underground ignition has not been deazly dismissed by current technology. MSHA does <br />not have regulations that would govern this activity, but has expressed concerns relative to safety with <br />respect to the potential for propagation of fire into the underground mine. There would also be an <br />associated potential fue hazazd where flammable brash, trees, or other vegetation exist in close <br />proximity to the wellhead and the USFS does not have existing policy regulating this issue. The BLM <br />does not have a poGry govemn~g flaring of gas from coal mining operations, so the issue of whether <br />or not a gas lease would be required is uncleaz. These outstanding questions would have to be <br />resolved if flaring is considered as an alternative to dischazging methane into the atmosphere. <br />Because the outstanding questions involve agency polity issues and decisions, consideration of this <br />alternative is not timely with respect to this environmental analysis but will be evaluated as the project <br />progresses. However, as conditions change and/or mining progresses, MCC will evaluate the <br />feasibility of commercially developing the methane. <br />2.3.8.4 Access Drill-Sites by Helicopter <br />1n evaluating projects requiring access to remote sites, environmentally sensitive azeas, or azeas where <br />access or use may be restricted by classification or management objectives, the USFS sometimes <br />considers access by helicopter. Helicopter use in lieu of roads can minimize surface disturbance and <br />associated environmental effects. Circumstances in which helicopter access is often used include <br />mineral exploration activities and limited logging operations. <br />Regardless of how they are accessed, drill pads would still need to be constructed and large-diameter <br />boreholes would still need to be completed to achieve effective methane drainage. Drill pad <br />construction would require the use of heavy equipment such as a tracked dozer and drilling of deep, <br />large-diameter boreholes that require a lazge rotary drill rig. The size and weight of the required <br />equipment is beyond the lift capabilities of all but lazge twin-rotor helicopters. Heavy-lift helicopter <br />operations would also require that a relatively large landing pad be cleared at each drill site or in close <br />proximity to the proposed drilling operations, potentially increasing drill pad disturbance. Because <br />contract rates for heavy-lift helicopter operations aze very high, helicopter access would substantially <br />increase overall project costs, potentially rendering methane drainage operations economically <br />infeasible. <br />While helicopter access would reduce project road construction and reclamation requirements, some <br />of this reduction would be offset by the additional disturbance required for adequate landing pads. In <br />addition, the noise associated with helicopter operations would disturb and temporarily displace <br />wildhfe in proximity to active operating azeas. For the proposed methane drainage activities, <br />EnevroromentalA.uurrmen! <br />W.Y'P/A/rM4 GdWLpVryr i/~/O)fl UIW <br />1/S/OI6 <br />