2008-06-09_PERMIT FILE - C1980007 (5)

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Alternatives Considered in Detail • • . Exception applies to proposed road construction associated with methane drainage wells on all IRA lands included in the federal coal leases C-1362 and COC-56447 on which operations are proposed. The need for proposing operations on the federal. coal leases that overlap with the IRA is based upon the configuration of the mining operations, meeting MSHA approval for the mine ventilation plan (which includes having adequate methane drainage facilities), functionality of the mine ventilation system, and limitations on using directional drilling because of overburden thickness. General mining operations for recovering the E Seam reserves at the West Elk Mine include developing longwall panels which are oriented in a southeast to northwesterly direction. Mining these panels would occur from southeast to northwest. The configuration of the mine plan in federal coal reserves is reviewed by the BLM to ensure that maximum economic recovery of the coal resource occurs. Thus, the projected mine plan is configured to ensure that all recoverable reserves are included. Based on experience mining B Seam reserves at other parts of the West Elk Mine, MDWs work most efficiently when placed on the "tailgate" side of the longwall panel where the fresh air traveling across the longwall face is drawn in to the return ventilation system. If MDWs are not placed in this manner, then the ventilation system `fights' with them and makes them less efficient, which leads to reduced capacity to regulate the amount of methane in the workings leading to safety concerns and operational downtime. For the E Seam reserves, to maximize efficiency, the MDWs are placed on the north side of the planned longwall panels where the tailgate for each panel will lie. The aligiunent of the longwall panels and need to place MDWs near the tailgate side requires that these facilities be placed in the IRA. Spacing requirements for MDWs of 750 feet are currently directed by MSHA based on anticipated mine conditions as submitted in a Mine Ventilation Plan. provided by MCC, as is the need for additional ventilation at the beginning of a longwall panel which is also the limit of recoverable E Seam coal. reserves. The development and implementation of a mine ventilation plan requires several steps as outlined below: Conceptual mine plans are developed to recover the mineable coal deposit. Ventilation layouts are then applied. to the mine plans and are used to help distinguish the most feasible plan to meet the following criteria: . Provide for the health and safety of all. miners; • Comply with the Federal Coal Mine Safety Standards (30 CFR Part 75). The Department of Labor is charged with enforcing these laws/standards. MSHA represents the Department of Labor in the field by physically inspecting each mine; and Provide ventilation for the safe production of coal in today's competitive market place. Ventilation engineering firms develop computer models of the mine ventilation system based on exiting mine ventilation to project ventilation needs for proposed future mining. The projected ventilation plan is taken to MSHA for preliminary discussion. Several meetings with MSHA usually result in a plan ready for submittal. MSHA reviews the submitted plan and can either reject it or approve it. Once MSHA approves a plan the contents of that plan become part of the "Standards" (30 CFR Part 75) that MSHA enforces as the mining takes place. The approved ventilation plan changes as the mining advances and each change has to be submitted to MSHA for review and approval before it can be implemented. Deer Creek Ventilation Shaft and E Seain Methane Drainage Wells FEIS 21