Laserfiche WebLink
Appeal Deciding Officer <br /> <br />12 <br />• Analyze reasonable alternati ves to limit greenhouse gas (GHG) <br /> <br />• “exploring options” that would reduce the level of wasted methane <br /> <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 /> <br />A cumul ative 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 o f 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 /> <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 /> <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 no n -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 me thane emissions are nearly non -existent. <br /> <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 10 , NO x , and SO 2 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 res ults of that detailed impact assessment predicted <br />no significant impacts to air quality as a result of authorizing the Oxbow Mine. <br /> <br />EA, 3.2, Air Quality, page 46: <br />Preliminary modeling results using EPA’s SCREEN3 air model indicate that methane <br />concentratio ns 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 mini ng this lease modification area . <br /> <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