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Methane Drainage Wells Project Plan <br />Technical Revision 101; Holes 19-09, 19-10 and 19-11 <br />Page 13 of 14 <br />and perform interim reclamation. Development of the access roads for these wells is <br />expected to commence during the summer of 2005 to assure access in August 2005. <br />The term of use is variable due to levels of methane found in the mine as a result of the <br />drilling. If successful and the prospects for good methane drainage appear positive, then <br />these sites could be operational for up to five years. Therefore the sites will be fenced <br />and signed for public safety. <br />MEASURES TO BE USED TO COMPLY WITH PERFORMANCE STANDARDS <br />FOR THE PROJECT143 CFR 3484.1(a~, 30 CFR 815.15, and Colorado Division of <br />Minerals and Geology Rules and Regulations) <br />1. Operator shall comply with applicable requirements of surface management <br />agency, 30 CFR 815.15, or approved State program. <br />Mountain Coal Company has reviewed, and will comply with, all applicable requirements <br />of 30 CFR 815.15 and the Colorado Mined Land Reclamation Regulations stated in <br />C.R.S. 34-33-101. <br />2. Install casing and blowout preventers in drill holes in known oil, gas, and geothermal <br />areas. <br />It is anticipated that gas will be encountered in the rubblized-zone of the B Seam. Gas is <br />known to be encountered after mining in previous methane drainage holes in the area. <br />Casing will be set in each hole as necessary to maintain circulation of cuttings to the <br />surface. <br />3. Drill hole plugging requirements. <br />In accordance with the Coal Program Guidance Document -Methane Drainage and <br />Monitoring Wells, MCC will plug and abandon these MDWs per DMG Rules 2.05.4 and <br />4.07.3 at the minimum. A mechanical packer will be set at the lowest possible point in <br />the well (note that subsidence damage to the casing may preclude access to the entire <br />depth of the casing). Above this packer the hole will be plugged with CDMG approved <br />materials to the bottom of the 5-foot cement surface cap using tremmie line. The top 5- <br />feet of the well below the sub-surface casing cut-off point (3-feet below the surface) will <br />be plugged with a cement cap. The top 3-feet of the casing will then be cut off and the <br />hole filled in with subsoil. A permanent mazker shall be installed on top of the plug <br />identifying the MD W. The pad will then be reclaimed to approximate original contour. <br />The Methane Drainage Well drilling experience for Mountain Coal Company has shown <br />that no aquifers have yet been encountered. However, the procedures described above <br />would serve to properly protect any aquifers that would be encountered. <br />A drawing of a typical abandoned MDW is attached as Figure No.l, Proposed <br />GVB/MDW Hole Plugging Method. Anticipated total depths for each well are: 19-09, <br />1170 feet; 19-10, 630 feet; 19-11, 630 feet. <br />