2008-03-10_REVISION - C1980007 - Laserfiche WebLink

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w ~' +: Appendix D- Supplemental Information Report: Flaring of Methane Gas Introduction The Deer Creek Shaft and E Searn Methane Drainage Wells Project Final Environmental Impact Statement (FEIS) was completed in August 2007. In response to permit actions submitted by the mining company to revise their existing State-approved mine permit, GMUG Forest Supervisor, Charlie Richmond, issued a ROD for the E Seam Methane Drainage Wells Project. This decision was appealed as evidenced by the following summarized appeal language: The Forest Service considered, but eliminated from detailed study, an alternative that would have flared methane gas vented as a result of the Project. See Project FEIS at 44. While the Forest Service noted that, "flaring may be used to reduce green house gas emissions," the agency stated that "FS understands from the MSHA District Office in Lakewood; CO that this activity is not approved by MSHA due to the potential safety hazard to the underground mine." Id. The FEIS's claim is contradicted by information provided to Appellants by the Forest Service.... The decision was reversed and remanded to the GMUG by the Rocky Mountain Regional Office with the following Language: The Reviewing Officer, based on review of the record, found that the record contained conflicting information provided by the Mine Safety and Health Administration regarding the viability of methane flaring. The reviewing officer recommended the decision be reversed and remanded back to the Forest Supervisor. I concur with the Reviewing Officer and by this letter instruct Forest Supervisor Richmond to further evaluate the feasibility of methane flaring as an alternative. I am fiu-ther inshzicting the Forest Supervisor to assure that any decision he makes with respect to this project be consistent with the Forest Service's role, responsibility, and authority concerning these types of surface activities pursuant to federal coal leases, as prescribed in the Federal Coal Leasing Amendments Act of 1975, the Surface Mining Control and Reclamation Act of 1977, and federal regulations pursuant thereto. This supplemental information report describes the situation with regard to further evaluating the feasibility of flaring as an altemative and describes the Forest Service jurisdiction regarding flaring as directed in the reverse/remand. This supplemental .information report causes no change to the proposed action or to the decision issued in November 2007 nor does it change the conclusions of the FEIS. Background Flaring of Methane Gas was considered as an Alternative Considered but Eliminated from Detailed Study in the FEIS (pg 44). It was eliminated from detailed study because it was not an approved action due to safety concerns of the regulatory agency (MSHA). Flaring as a potential method to reduce greenhouse gas emissions was discussed in the Air Quality analysis in the FEIS (FEIS, Pg 61), which also referred to flaring not being approved by the applicable regulatory agency (MSHA). In the course of researching flaring for the Draft and Final EISs, the GMUG made contacts with MSHA District 9 Office in Lakewood, Colorado, and MSHA's Headquarters Office in Washington, DC. 43