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~~. <br />~~ <br />t ,. <br />FE8.26.2003 2:06PM MSHA COAL D1ST 9 000 <br />NO. 0531 F. 3 <br />Recently the potential use of a flaring system was discussed. Tn xevtew of the <br />documents xegarding the conceptual design of such a systezx~ we have <br />determned that too many unknowns about -ttu.s system. exist at the present time <br />to appro-~e such a system and have advised the operator as such. This office <br />must do its up-most to ensure the safety of persons working undexgro~und and <br />any flaring system envisioned that is more or less dixectly coxtnected to the active <br />gob where miners work m~xst ktave been fully evaluated by 1viSI~A and <br />determined to be of a safe design, Any such system design should be tested in a <br />coal mine methane flaring situation in which no nvners are exposed, such as a <br />seai.ed and abandoned mine, for sufficient time to test the viability and durability <br />of the system and ensure it has zero potential to cause the igr-itzon of gas <br />underground before this office would cor-sider ix-corporating it into an active <br />mine ventilation system. There are too many questions remaining unansvrexed, <br />no evaluatior~s and no actual testing in a no-risk mine type situatiozi that <br />deui.onstrates the system's safety fox this offzce to approve the incorporation of <br />such a system into the ventilatiox< plan at the West Elk Mine at the present time, <br />If you have any ftzxther questions, please contact me at 303 23~-545, <br />Regards . <br />/s/RI(yn C: Davis <br />Allyn Davis . <br />District 1Vlanager <br />BCC: <br />W. Knepp <br />W. Reitze <br />D. Gibson <br />DM piles <br />DM Chxon <br />A. Davis <br />T:\CoaJ.\DM\flaxing at West Blkc.doc <br />