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KERR COAL COMPANY <br />BOREHOLE RECLAMATION PLAN <br />(Revision 1 -January 29, 2002) <br />As part of the information gathering process for delineating and evaluating additional coal reserves to <br />the north and east of their mining operations, Kerr Coal Company (Kerr) drilled a number of <br />exploration boreholes within Federal Coal Lease C-22777 and adjacent to the lease in Exploration <br />License C-28056. Based on a preliminary field reconnaissance by the BLM, other entities have or <br />may have also drilled and completed boreholes or wells in this area. Documented well locations and <br />designations are shown on Map BLM-2, Marr Mine .Area -Exploration Boreholes/Wells. The <br />majority of the boreholes drilled by Kerr were cased and completed in various zones as potential <br />ground water monitoring wells to collect baseline and operational hydrologic data in conjunction with <br />potential future mining operations. On the basis of favorable reserve information from the drilling <br />program(s), Ken developed detailed mining and reclamation plans for development of a portion of <br />the identified reserves and proceeded with initial permitting activities. Unfortunately, coal market <br />conditions (over supply) and the loss of the rail spur line, which provided the only economical <br />transportation link to potential coal markets, has rendered development and production of the <br />identified reserves uneconotnic under current conditions. <br />Recognizing that the subject coal reserves will not be developed for some time, if ever, Kerr, at the <br />request of the BLM, has developed plans to identify, plug, and reclaim all boreholes completed by <br />Kerr for which there is no continuing beneficial use. Given the existence of known coal reserves and <br />the potential that those reserves could be developed at some time in the future, it may be appropriate <br />to retain some of the existing cased boreholes to monitor ground water conditions and effects Erom <br />existing oz fumze training operations. In addition, given the semi-arid climate, scazcity of significant <br />yeaz-round water sources, cost of completing new wells, and use of the subject Federal lands for <br />livestock grazing and wildlife habitat, it may also be appropriate to retain and develop selected wells as <br />water supply wells to support these existing land uses. As an integral pazt of the plan, therefore, Ken <br />will identify any wells that may have continuing beneficial uses (monitoring or water supply) and <br />provide justification for well retention and future use Eor BLM review and concurrence. <br />Ken's proposed borehole reclamation plan is comprised of Eour components, as detailed in the <br />following sections: <br />• Field reconnaissance and inventory of wells <br />• Determination of potential for beneficial use <br />• BLM review and concurrence on well retention Eor beneficial use <br />• Well plugging and reclamation <br />Field Reconnaissance and Inventory of Wells <br />BLM field reconnaissance in 1999 identified 38+ existing boreholes (with casing) in the area. Review <br />of available documentation on Kerr's historical exploration activities identified approximately 47 <br />boreholes and/or monitoring wells. Subsequently, field reconnaissance by Kerr personnel and <br />additional file review completed in 2000 further changed the well count. The current estimate is 72 <br />wells in the Marr mine azea including the exploration license to the northeast. The following <br />summarizes the well count by location. <br />