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Formal Hearing Staff Presentation by Tom Kaldenbach <br />Colorado Mined Land Reclamation Board Environmental Protection Specialist <br />July 9-10, 2008 Colorado Division of Reclamation, Mining and Safety <br />Technical Revision 111 <br />16 Methane Drainage Wells in "E" Coal Seam <br />West Elk Mine (Permit C-80-007) <br />Gunnison and Delta Counties, Colorado <br />Work proposed in TR-111 <br />• 6 access roads. <br />• 14 drill pads (ave. `/2 acre, each). <br />• 16 methane drainage wells. <br />• 10 acres of total new land disturbance in a 700-acre area. <br />• All on U.S. Forest Service Land. <br />• TR-111 is a conceptual plan, with precise road/well locations to be submitted in a subsequent MR <br />(or TR if significantly different from TR-111). <br />• TR-112 was submitted simultaneously with TR-111, proposing 168 wells, 80 acres of disturbance <br />in 6-square mile area next to TR-111 area, currently in DRMS review. <br />Summary of Objector's Comments (in bold italics) and DRMS's Comments <br />1. DRMS should consider USFS right-of-entry invalid. - TR-111 complies with DRMS right-of- <br />entry requirement (2.03.6) based on USFS consent/concurrence letter of June 6, 2008 approving <br />the methane drainage well project as proposed in TR-111. <br />2. DRMS should require permittee to capture or flare methane to reduce greenhouse gas <br />emissions. - DRMS has limited air quality jurisdiction. DRMS does not have jurisdiction over <br />methane emissions. TR-111 complies with DRMS air quality rules, as follows: <br />• Identification of other permits (2.03.10) - CAQCD permits are listed in mining permit. <br />• Control of fugitive dust (4.28.3(9)) - Operational history indicates no dust problem. <br />• Air resource protection (4.17) - Operational history indicates continued compliance with <br />State and Federal air quality standards. <br />The operational history of the mine also indicates TR-111 complies with DRMS requirement <br />to minimize adverse environmental impacts (4.18(1)). <br />3. DRMS should consolidate TR-111 and TR-112 into one "Permit Revision "to enable review of <br />methane drainage well project as a whole. - Work proposed in TR-111 and TR-112 meets the <br />definition of a TR in 1.04(136). No regulation requires consolidation of related permit actions. <br />The two TRs were submitted in a logical sequence that corresponded with the sequence of NEPA <br />approvals (EISs and EAs) for PR-10, PR-12, TR-111, and TR-112. PR-10 and PR-12 added new <br />leases which require the methane drainage wells proposed in TR-11 I and TR-112. This <br />permitting sequence follows past permitting process (e.g., TR-96 and its associated Permit <br />Revisions). <br />4. DRMS should require permittee to submit future "actual" plan as a TR (with public notice) <br />rather than an MR (no public notice). - DRMS would allow an MR only if there is no <br />significant change from the conceptual plan. This follows past permitting process (e.g., TR-96).