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Coal MetlJane Drainage Projeet - Panelr 16-24 Wert Elk Mine • Page 2-9 I' conditions, operators would collect methane gas directly at the wellhead for sale or on-site use. Because of variable gas quality and quantity, difficulties in coordinating commercial gas recovery with underground mine degasification requirements, and the econotncs of commercializing methane I, mixed with air, however, coal mine operators commonly vent methane to the atmosphere and do not capture the gas. In these cases, safety and environmental objectives could be satisfied by carefully flaring emitted gas. ' Gas flaring is a standazd safety practice in some industries. For example, methane and other associated gases are routinely Flared during processing and production of od and gas, and are continuously flared from landfill collection systems. Incorporating a controlled flare system would ' mtnimize the potential of an unconfined conflagration occurtmg on the surface at the MDW discharge location(s), brought about by natural or man-made sources reduce greenhouse gas effects on the atmosphere through cample[ion of the hydrocarbons. The Environmental Protection Agency is currently sponsoring research and outreach efforts to coal mine operators to encourage coalbed and coal mine methane capture or Flaring. (Reference .vww.e~.eoa/coalbed). The methodology for flaring methane emissions from underground coal ' [noes is emerging but remains technologically speculative at this time. The hazazd that flaring could create an underground ignition has not been clearly dismissed by current technology. MSHA does not have regulations that would govern this activity, but has expressed concerns relative to safety with ' respect to the potential for propagation of fire into the underground mme. There would also be an assonated potential fire hazard where flammable brush, trees, or other vegetation extst in close proximity to the wellhead and the USFS does not have existing policy regulating this issue. The BLM ' does not have a polity governing flaring of gas from coal mining operations, so the issue of whether or not a gas lease would be required is uncleaz. These outstanding questions would have to be resolved if flaring is considered as an alternative to discharging methane into the atmosphere. ' Because the outstanding questions involve agenry policy issues and decisions, consideration of this alternative is not timely with respect to this environmental analysis but will be evaluated as the project progresses. However, as conditions change and/or mining progresses, MCC will evaluate the ' feasibility of commercially developing the methane. 2.3.8.4 Access Drill-Sites by Helicopter ' In evaluating projects requiring access to remote sites, environmentally sensitive azeas, or azeas where access or use may be restricted by classification or management objectives, the USFS sometimes considers access by helicopter. Helicopter use in lieu of roads can minimize surface disturbance and ' associated environmental effects, Circumstances in which helicopter access is often used include rruneral exploration activities and limited logging operations. Regardless of how they aze accessed, drill pads would still need to be constructed and large-diameter boreholes would still need to be completed to achieve effective methane drainage. Drill pad construction would require the use of heavy equipment such as a tracked dozer and drilling of deep, ' large-diameter boreholes that require a lazge rotary drill rig. The size and weight of the required equipment is beyond the lift capabilities of all but large twin-rotor helicopters. Heavy-lift helicopter operations would also require that a relatively large landing pad be cleared at each drill site or in dose proximity to the proposed drilling operations, potentially increasing drill pad disturbance. Because t contract rates for heavy-lift helicopter operations aze very high, helicopter access would substantially increase overall project costs, potentially rendering methane drainage operations economically infeasible. ' ~~/hile helicopter access would reduce project road construction and reclamation requirements, some of this reduction would be offset by the additional disturbance required for adequate landing pads. In addition, the noise associated with helicopter operations would disturb and temporarily displace wildlife in proximity to active operating azeas. Foz the proposed methane drainage activities, I~L~P/AH..u1 Cr'G/F~1/W.h J/~/n]Yr UtFJ J/r/oz m EnuimnmentalA.rrarment