2013-04-03_PERMIT FILE - X201322801 (2)

Home Browse Search

�.y c,datrsi Te T a age tneL t The uniqud geologic. ten : am. and economic conditions a each coal mine de' ern- i n, whether. when. and how methane use mitigation options are feasible. Additionally. if coal ceases are overlaid with oil and gas leases, the coal and oil and gas operators must reach an agreement with regard to any potential methane use and /or liberation. There are currently three Federal oil and gas leases that cover portions of the West Elk Mine (COC -651 16, COC -651 15. and COC -6X483 ). These leases do not cover any portion of the lease modification areas or coal leases COC -' 362 and COC -6 2. The West Elk Mine has lease addenda (described above in Section 7.0) that allow for methane use when economically feasible, and for which the BLM requires additional analysis when certain economic trigger values are reached. Pursuant to these lease addenda on leases COC -1362 and COC- 67232. if determined to be economically feasible, the BLM wdI require the appropriate mitigation use. or the equivalent royalty payments. The current conditions at the West Elk Mine are not conducive to any of the methane use options analyzed in the 2009 West Flk Mine E -Seam Cias Economic Evaluation Report The geology of the current mining area is not resulting in high methane liberation The terrain is very rugged. and as such. placing pipelines through the area to the MDWs is geographically. technically. and economically infeasible. The MDWs used at the West Elk Mine are temporary and those used to liberate methane from the E -Seam mine workings are in service for an average of 12 weeks per MDW as underground mining progresses. There can be a range of 1 to 5 E -Seam MD\Vs draining at any given time while methane content attic exhausted gases can range from 20 "t, - 95"0; this temporary and fluctuating nature of the MDWs drainage reliability is a major contributor to the infeasibility of economic methane use. '\dditionally, to make a methane flaring option economically feasible, a robust carbon credit market is necessary. Such a market does not currently exist. but as described above in Section ''.O. a future increase in carbon credit price is one of the trigger values that will necessitate further review of methane use by the West Elk Mine While the methane use options analyzed in the 2009 Report are not currently economically feasible, the West Elk Mine is able to utilize liberated methane to heat the mine when outside temperatures so require. The BLM supports this methane use, which is within the purview of the lease addenda. Therefore, when methane liberation concentrations in the mine and outside temperatures allow West Elk to use methane to heat the mine. this BLM ROD requires the West Elk IVline to do so The lease addenda on COC -1 362 and COC- 67232, coupled with the accepted trigger values described above in Section 7 .0, require additional potential future analysis by MCC. If such analysis snows that additional methane use measures are warranted. the BLM will require the appropriate use or royalty payment as provided by the lease addenda