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Appeal Deciding Officer 12 <br />• Analyze reasonable alternatives to limit - reenhouse mas (GHG) <br />• "ekplorink options" that reduce the level of)rasted methane <br />In Sections 2.2 and 3.2 of the environmental analysis, there is discussion of mitigation measures <br />related to methane release and climate change. <br />A cumulative effects discussion regarding Greenhouse Gas (GHG) emissions would not provide <br />practical or meaningful effects analysis for the deciding officer. Consenting to the lease <br />modification and the expected emissions associated with extending the duration of mining from <br />2 days to 3 weeks is not expected to exceed the current rates of permitted /regulated pollutants <br />from the parent lease. <br />EA, 3.2, Air Quality, starting on page 41: <br />No data is available regarding current ambient methane concentrations in air because <br />methane is not yet a regulated constituent. <br />The values used to estimate methane emissions included in the analysis were based on <br />values associated with averages from 2009 and 2010 as reported to MSHA and submitted <br />to EPA. This data is somewhat non - representative of over -all operations in the North <br />Fork because methane at this mine is the direct result of the depth of over - burden Where <br />over - burden is the deepest, the methane emissions are the highest and where over - burden <br />is the shallowest, the methane emissions are nearly non - existent. <br />EA, 3.2, Air Quality, page 46: <br />A detailed air quality assessment, including modeling, of the original mine was <br />conducted as part of the environmental analysis for the Elk Creek Coal Lease Tract in <br />2000 (North Fork Coal EIS). The air quality analysis conducted for the original mine <br />included an emissions inventory and modeling analysis. That emissions inventory <br />quantifies PM NO,,, and SO z emissions. The modeling analysis also includes a <br />visibility impacts assessment in the West Elk Wilderness Area (Class I Area) as well as <br />an atmospheric deposition impacts assessment. Emissions that were calculated and <br />modeled included tailpipe emissions from mining equipment, haul trucks, and <br />locomotives (railway emissions). The results of that detailed impact assessment predicted <br />no significant impacts to air quality as a result of authorizing the Oxbow Mine. <br />EA, 3.2, Air Quality, page 46 <br />Preliminary modeling results using EPA's SCREEN3 air model indicate that methane <br />concentrations from existing methane drainage wells ... would still be below the Mine <br />Safety and Health Administration (MSHA) level of 1 %. No new methane drainage wells <br />will be needed for mining this lease modification area <br />EA, 3.2, Greenhouse Gases, beginning on page 45: <br />Potential impacts may occur from reasonably foreseeable activities related to <br />subsequently mining the lease modification such as continued methane drainage on the <br />