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Request for Hearing on TR-11 1 for the West Elk Mine (Permit No. C-1980-0007) Page 7 <br />June 20, 2008 <br />B. If the Methane Cannot Be Captured, DRMS Should Require the Mine <br />to Flare the Methane. <br />If DRMS concludes that it cannot mandate capture, DRMS should require the Mine to <br />flare vented methane. Although CO2 resulting from the combustion of fossil fuels is often cited <br />as the leading cause of global warming pollution, release of raw methane has a more than <br />twenty-fold greater impact on the climate. The Forest Service's EIS recognizes that "flaring may <br />be used to reduce green house gas emissions." Exh. 1 at 44. Further, flaring of methane could <br />occur safely. According to an October 26, 2007 e-mail from Erik Sherer, a mining engineer with <br />the Division of Safety at the MSHA: <br />There is a long and safe history of flaring waste gas and volatile hydrocarbons in <br />the petroleum and chemical industries. MSHA would approve flaring of <br />methane drainage if appropriate protections are incorporated into the <br />flaring system. <br />See email of Hubert E. Sherer, MSHA to Liane Madsen, USFS, et al. (Oct. 26, 2007 3:12 PM), <br />included in Exh. 8 (emphasis added). Additionally, in a November 1, 2007 e-mail, Mr. Sherer <br />responded to the EPA's comments suggesting that the Mine flare methane. Mr. Sherer stated: <br />MSHA would approve a methane flaring system that incorporates adequate <br />protections to prevent a flame or explosion from propagating to the coal Mine.... <br />MSHA has no regulation or policy that prohibits the flaring of methane.... <br />MSHA has reviewed the EPA flare system and concurs that this is an acceptable <br />method for flaring methane produced from coal Mine degas holes. However, any <br />proposed flare system would have to be designed for Mine-specific conditions <br />(flow rates, gas concentrations, etc.) and must be approved in the ventilation plan. <br />See email of Hubert E. Sherer, MSHA to Liane Mattson, USFS, et al. (Nov. 1, 2007 4:31 AM), <br />included in Exh. 8.1 ° <br />These communications demonstrate that no regulatory hurdles exist to methane flaring. <br />Although a flare system would have to be designed for mine-specific conditions, nothing from <br />the MSHA indicates that this alternative is unreasonable or speculative. Further, methane flaring <br />is used safely at numerous mines around the world, and is already in use in the Mine's winter <br />heating system. See Exh. 2 (Appeal) at 14-16. <br />10 While another MSHA official subsequently disagreed with Mr. Sherer, that official's <br />statements are entirely undermined by the fact that flaring is conducted routinely at a number of <br />coal mines around the world. See Exh. 2 at 14-16.