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III. COMMENTS - COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions takers during the <br />inspection and the facts or evidence supporting the enforcement action. <br />This was a partial inspection conducted by Kent Gorham of the Colorado Division of <br />Minerals and Geology. Ron Thompson represented Basin Resources during the inspection. <br />This former underground mine is now reclaimed. Activities consist mainly of monitoring <br />and maintenance. The weather was mild and ground conditions were dry. <br />Revegetation <br />Mr. Thompson has used a roto-tiller on a few areas where limited inter•seeding is <br />necessary. These areas had not been interseeded at the time of the inspection. No weed <br />spraying has been conducted at this time. The growing season is over clue to numerous <br />killing frosts. Live vegetative cover and litter cover is qualitatively rated as good <br />over the vast majority of the reclamation. <br />Soil Methane Monitors <br />The two gas wells on the Toupal property east of the reclaimed area ware abandoned and <br />reclaimed by the gas operator, Geo-Met Inc, beginning on Monday, October 9, 2000. Well <br />casings were cemented in-place using high-pressure equipment. Well casings were cut off <br />some 50 inches below ground level following cementing operations. Metal plates were <br />welded to the top portion of the cut-off casing and the sites were re-graded to original <br />topography. Loren Avis of the Oil and Gas Conservation Commission was also present <br />during abandonment operations. Methane gas was not detected around the casing annulus <br />before or after cementing. <br />Some difficulties were encountered when pumping cement in the eastern well (28-10). <br />Three times the computed volume was pumped down the well without any returns at the <br />surface indicating a loss of cement into the formation. The well did accept cement the <br />following morning and appeared to be successfully sealed. Ron Thompson indicated the <br />next round of soil monitoring will be done prior to the Thanksgiving holiday. <br />Significant reductions in the percentage of methane in the monitoring wells would <br />indicate the gas wells as the likely source. <br />The Chavez coal exploration site has not been mitigated yet due to difficulties in <br />securing a drill rig to do the work. <br />Overall, the site is ~n good condition for the fall season. <br />Page 3 <br />