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Recently the potential use of a flaring system was discussed. In review of the <br />documents regarding the conceptual design of such a system we have <br />detemlined that too many unknowns about this system exist at the present time <br />to approve 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 underground and <br />any flaring system envisioned that is more or less directly connected to the active <br />gob where miners work must have been fully evaluated by NIM3A 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 miners are exposed, such as a <br />sealed 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 ignition of gas <br />underground before flies office would consider incorporating it into an active <br />mine ventilation system. There are too many questions remaining unanswered, <br />no evaluations and no actual testing in a no-risk mine type situation- that <br />demonstrates the system's safety for this office to approve the incorporation of <br />such a system into the ventilation plan at the West Elk Mine at the present time. <br />If you have any furdler questions, please contact me at 303 231-5458. <br />Regards, <br />/S/ Allyn C. Davis <br />Allyn Davis <br />District Manager <br />Bcc: W. Knepp <br />W. Reitze <br />D. Gibson <br />DM Files <br />DM Chron <br />A. Davis <br />T:\CoaI\Mflaring at West Elk.doc <br />47