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FEB.26.2008 2:06PM <br />MSHA COAL DIST 9 000 <br />jr,?C, <br />(f 1766 007 <br />Toe-III <br />NO. 0531-'/, P. 2 <br />e ti r- ? <br />Coal Mine Safety and Health <br />District 9 <br />F B 2 5 2008 <br />Mr. Charles Richmond <br />Porest Supervisor <br />Grand Mesa-Uncompahgre-Gunnison National Forest <br />2250 Highway 50 <br />Delta, CO 81416 <br />Dear Mr. Richmond: <br />There have been inquiries as to whether my office will approve flaring of <br />urethane gas venting from de-gas wells that are proposed to be installed in the e- <br />seam longwall, panel at Mountain Coal Company's West Elk Mine located near <br />Somerset, Colorado. <br />In looking into this issue, I am aware of the Conceptual Design for a Coal Mine <br />Gob Well Flare, dated August 1999 and prepared by the Coalbed Methane <br />Outreach Program, Atmospheric Pollution Prevention Division of the U.S. <br />Environmental Protection Agency. I am also aware of e-mails between Lune <br />Madsen of the U.S. Forest Service and Hubert Sherer of the Mine Safety and <br />Health Administration (MSHA) in which it was stated that there is no MSHA <br />regulation preventing flaring of methane gas at a coal mine. <br />The District 9 Office of MSHA has the responsibility of approving mining plans <br />for all coal mines in the western part of the United States. We have approved <br />raining plans submitted by the '(Nest Elk Mine for longwall mining in the E-seam. <br />Experience in 7 to 8 years of longwall mining at the West Elk Mine has proven <br />that methane drainage is an essential element of their mine ventilation system. <br />The mine faits alone are not capable of adequately handling the methane <br />encountered in the seams being mined in order to provide a safe and secure <br />environment for miners who work underground. We have already advised the <br />West Elk management that we cannot approve future longwall panels without <br />sufficient de-gas wells to control methane. <br />6x.'