2008-06-09_PERMIT FILE - C1980007 ‎(6)‎

• Permit No: C1980007
• IBM Index Class Name: Permit File
• Doc Date: 6/9/2008
• Doc Name: Exhibit 79 Part 2
• Section_Exhibit Name: Exhibit 80 Drilling Activities - TR111
• Media Type: D
• Archive: No

Response to Comments
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C
Table 5-1
DEIS Comments and Responses
Commenter Comment Comment/Response

their plamling and decision-making processes and to evaluate and report those
efforts, as appropriate, in documents prepared pursuant to NEPA. Moreover,
EPA's Coal bed Methane Outreach Program, which began in 1994, is a
voluntary program through which the U. S. coal industry has captured and
used 308 billion cubic feet (Bcf) of coal mine methane. The 10 active mines
in the U.S. with methane capture projects operating in 2002 used 44 billion
cubic feet of methane, which offset almost 18 million metric tons of carbon
dioxide emissions. In turn, this provided enough energy to heat 638,000
homes. To date such efforts are being accomplished in underground coal
mines in Alabama, Virginia, West Virginia and Pennsylvania. Indeed, the
portion of the West Elk Mine's methane released from the drainage wells
would be sufficient to heat several thousand homes, and has a value of
approximately $15 to $25 million dollars annually.
Given the project's release of significant quantities of methane, there is an
important economic and environmental opportunity here to capture and utilize
the methane resource.
RESPONSE: MCC is a member of EPA's CMOP program; however, since
the Federal gas reserve (methane) is not under lease, it is illegal for it to be
used for these beneficial purposes until leased (see FEIS, Chapter 2,
Alternatives Considered but Eliminated from Detailed Study).
US EPA 4 Given the potentially significant amount of methane that will be released from
the project, we recoirunend that the final EIS analyze measures for capturing
all or a part of the methane to be vented from the mine. While EPA
understands that there is no lease in place that would allow the methane
encountered as a by-product of the mining to be captured and put to beneficial
(i.e., profitable) use, the lack of a lease should not preclude evaluation of
measures to capture and reuse this resource. CEQ's regulations direct an
agency to analyze reasonable alternatives not within the jurisdiction of the
lead agency. Methane capture and reuse is a reasonable alternative to the
proposal of venting the methane to the atmosphere, and thus, we recommend
that it be analyzed.
REPPONSE: See EPA response #3. Leasing of the gas resource and its
reduction in the methane is not being analyzed at this time. EPA's suggestion
has been considered in Chapter 2, Alternatives Considered but Eliminated
from Detailed Study.
Deer Creek Ventilation Shaft and E Seam Methane Drainage Wells FEIS
195