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• MWH MONTGOMERYWATSON HARZA January 29, 2002 III IIIIIIIIIIIIIIII • ~ 999 //~a~ ~. Linda M. Gross, Field Manager Bureau of Land Management - Kremmling Field Office 1116 Pazk Avenue Ktetnmling, Colorado 80459 Re: Kerr Coal Company -Borehole Reclamation Plan Deaz Ms. Gross: This letter, provided by MWH on behalf of Kerr Coal Company (Kerr), responds to your letters dated August ]2, 2001 and December ]0, 2001 pen~i*+~~g to dtillhole and well abandonment on Coal Exploration License C-2805G and Coal Lease C-22777. This letter also addresses Stipulations 22 and 23 (copies attached for reference) to the approved Colorado Division of Minerals & Geology (CDMG) Mining and Reclamation Plan and associated permit. Pursuant to CDMG Stipulation 22, research of Kert's azchives resulted in additional information on borehole Locations, designations, completion information, and history. This additional information (summarized by the attached Borehole Infoanation Update Summary) has been incorporated into the supporting tables for the previously submitted (] /3/00, updated 9/]5/00) borehole reclamation plan. The originally submitted Borehole Reclamation Plan remains valid with minor modifications reflecting the additional information recently obtained and updates to reflect current status and timing. A copy of the updated Borehole Reclamation Plan is attached for reference. The BLM's original correspondence (8/]2/01) on this matter indicates a tazget date of August ] 2, 2002 for completion of borehole reclamation activities. More recent BLM correspondence (12/10/07) and CDMG Stipulation 23 have moved this date up significantly to May 31, 2002. Kerr has significant concerns relative to completion of the borehole reclamation activities by this earlier date. Ground conditions in Noah Pazk are typically wet and muddy well into the spring, effectively limiting field operations. Based on experience in this azea, it is not reasonable to expect acceptable access conditions until late May or eazly June. Since most of the boreholes were drilled over fifteen years ago, both drill-sites and access have stabilized with vegetation. Trying to access these sites before the ground dries out would result in significant surface damage and very difficult field operations. Kea, therefore, tequesu that the target completion date for borehole reclamation of August ]2, 2002 be retained as originally proposed. Kerr plans to complete the field reconnaissance portion of the borehole reclamation plan as soon as ground conditions allow this spring. Borehole abandonment and reclamation activities would then be initiated in June or]uly and completed prior to the August ]2, 2002 completion date. All borehole reclamation activities will be conducted in accordance with the accompanying updated Borehole Reclamation Plan. The primary outstanding question relative to the proposed borehole reclamation progtarn is retention of some of the boreholes/wells for potential future beneficlal use. Kerr has attempted to address this question in the Borehole Reclamation Plan and supporting F.O. Bos 77W18 le I: 9706796260 GeOvennc tnnnva hve Pro/ens snC £olimm~e INOtldx•ioe 1475 Fine Grove Foad, Sure i09 Fax- 9>0 B79 9048 SteamOOal Sprmas, Coleradc 90417