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2013-04-11_REVISION - C1981018
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2013-04-11_REVISION - C1981018
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Entry Properties
Last modified
8/24/2016 5:19:27 PM
Creation date
4/11/2013 12:57:25 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981018
IBM Index Class Name
Revision
Doc Date
4/11/2013
Doc Name
Letter to SHPO (Emailed) & Attachment
From
DRMS
To
SHPO
Type & Sequence
PR8
Email Name
ZTT
DIH
Media Type
D
Archive
No
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remote and speculative. About 29 U.S. coal mining operations use vertical methane drainage <br />wells to vent gas from the mines. In all cases, gas vented from these wells is discharged directly <br />into the atmosphere. Under ideal conditions, operators would collect methane gas directly at the <br />wellhead for sale or on -site use. Because of variable gas quality and quantity, difficulties in <br />coordinating commercial gas recovery with underground mine degasification requirements, and <br />the economics of commercializing methane mixed with air, coal mine operators commonly vent <br />methane to the atmosphere and do not capture the gas. <br />In these cases, safety and environmental objectives could be satisfied by carefully flaring emitted <br />gas. Gas flaring is a standard safety practice in some industries. For example, methane and other <br />associated gases are routinely flared during processing and production of oil and gas, and are <br />continuously flared from landfill collection systems. Incorporating a controlled flare system <br />could minimize the potential of an unconfined conflagration occurring on the surface at the <br />methane drainage discharge location(s) and would potentially reduce greenhouse gas effects <br />through combustion of the associated hydrocarbons. <br />The Environmental Protection Agency (EPA) is currently sponsoring research and outreach <br />efforts to coal mine operators to encourage coalbed and coal mine methane capture or flaring <br />(refer to www.epa.gov /coalbed). The methodology for flaring methane emissions from <br />underground coal mines is emerging, but remains technologically speculative at this time. The <br />hazard that flaring could create relative to the potential for an underground ignition has not been <br />clearly dismissed by current technology. The MSHA does not have regulations that would <br />govern this activity, but has expressed concerns relative to safety with respect to the potential for <br />propagation of fire through methane drainage boreholes into underground mines. There would <br />also be an associated potential fire hazard where flammable brush, trees, or other vegetation <br />exists in close proximity to the wellhead. These outstanding questions would have to be resolved <br />if flaring is considered as an alternative to discharging methane into the atmosphere. <br />Additionally, flaring of methane would result in the release of other air pollutants, including <br />nitrogen oxides, carbon dioxide, and carbon monoxide; these pollutants are regulated by the EPA <br />for national ambient air quality standards (NAAQS). Methane is not a regulated gas. Therefore, <br />the implementation of methane flaring is unlikely, given past and current practice and <br />technology. <br />Also taken into consideration is the quantity of methane liberated from the B -Seam coal; <br />Deserado's 2011 gob degas operations consisted of operating two degas holes 7 out of 365 days. <br />PLAN CONFORMANCE REVIEW: The Proposed Action is subject to and has been reviewed <br />for conformance with the following plan (43 CFR l 6l 0.5, BLM 1617.3): <br />Name of Plan: White River Record of Decision and Approved Resource Management <br />Plan (White River ROD /RMP). <br />Date Approved: July 1, 1997 <br />Decision Number/Page: 2 -7 <br />DOI- BLM -CO- 110 - 2012 - 0023 -EA 9 <br />
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