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COLORADO WESTMORELAND IN . ___ .' P.O. Box 1299 Paonia, Colorado 81428 • 303-527-4135 October 24, 1°R8 Mr. Alan Kesterke Bureau of Land Management _', Montrose District Office 2465 5. Townsend Avenue Montrose, CO 81401 ~, RE: P?INOR MODIFICATION PANEL G ` LEASE #C-37210 Dear Mr. Kesterke: folorado Westmoreland Inc. (C41I) is reouestinq a change in the approved mine plan within the projected plans for Panel G retreat mining. P,s you are prohahl,y aware, MSHA is directing all Gassy mines in District 9 toward a bleeder system for methane control over the gob areas. MSHA has indi- cated that past ventilation methods vrhiie extracting pillars at the Orchard Val- . ley Mine (OVM) were not acceptable due to short circuiting the air to the return just inby the working face (i.e. leaving one standing pillar along the length of panel as seen on 11 & 12 North of the enclosed O.V.M. map). CIdI has therefore completed an in-house analysis of what we feel is the best bleeder system for the natural conditions (.methane & spontaneous combustion con- cerns) that are prevalent in the Orchard Valley West Mine (OVWM). We have eval- uated a true bleeder system min inn one panel into an adjacent gob area or keeo- ino the panels separate from one another, but each panel being connected to a bleeder svstem at both ends of the oanel. Cb~I is ultimately concerned about the effects that a t.r~_ie bleeder system would have nn spontaneous combustion concerns over the life of the mine. l•Je are very s4:.eotical about ventilating mined out nobs for long periods of time. or having seals on both ends of a mined out panel that would create a constant pressure differential thus a continuous oxygen supply. In the analysis of alternatives, we have evaluated an in-panel wrap around bleeder system (i.e. ventilating to the end of the gob and then out the bleeder return) with the use of our old equivalent bleeder system (one standing pillar along the length of the panel), but are concerned about the roof control prob- lems that could possibly he encountered in the standing entry. According to law, the bleeder system must be kept open so as to be inspected in its entire- ty. Therefore, CWI has proposed leaving two standing pillars within a panel to help stabilize the roof conditions within the bleeder entry and help regulate the amount of air over the gob (see enclosed maps and drawings). We have also in- cluded the pillars that would be left standing for the purpose of protecting the Steven's Gulch Drainage huffer zone area. • SUBSIDIARY OF WESTMORELAND COAL COM PANY.. „JR .. _ _.L::++aa~. ~ ~:~~. •'. s:.-,:_: ~ e-.-~.