2003-02-05_REVISION - M1998013 (5)

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interest in the structure, that the applicant is to provide compensation for any damage to the structure; or (b) where such an agreement can not be reached, the applicant shall provide an appropriate engineering evaluation that demonstrates that such structure shall not be damaged by activities occurring at the mining operation -Rule 6.4.19. Hall-Irwin has provided a Geotechnical Stability Exhibit as part of their response to the Division's adequacy review, to demonstrate that no structures will be damaged. On January 31, 2003, Tetra Tech RMC, on behalf of Hall-Irwin Corporation, submitted revised Mining and Reclamation Plan Maps which included the location of the existing and future potential well and tank locations pursuant to information provided by Kerr-McGee. The maps also included reining setback distances of 150 feet. The mining and reclamation azeas were also adjusted to account for these wells. The Division has reviewed Hall-Irwin's adequacy responses, and the January 31, 2003 Mining and Reclamation Maps, and concluded that the proposed 150 foot setbacks from the wells will adequately protect the wells from the mining activity. Environmental Risks-Health and Safety 1. "Kerr-McGee is also concerned about the health and safety issues raised by the proposed mining operations. Although mining can occur in a manner compatible with the current and future oil and gas development on these lands, this requires mutual cooperation and coordination during the planning process." (Ann Lane, December 31, 2002) DMG Response- Kerr-McGee was not specific as to what health and safety issues they were concerned about. The Division does recognize that any release of hydrocarbons caused by damage to a pipeline or well would be a violation of the Division's Rules regazding damage to structures and causing impacts to the hydrologic balance. B. ISSUES RAISED DURING THE INITIAL COMMENT PERIOD THAT THE DIVISION BELIEVES ARE NOT WITHIN THE .iURISDICTION OF THE DIVISION OR BOARD 1. "In addition to the existing well, Kerr-McGee is also legally entitled and currently has plans to drill future wells and to construct gas gathering pipelines, tank batteries, heater/treaters and related facilities ("Facilities") on the Application Lands. The Applicant's plan does provide for a setback azea in the SE/4NE/4 of Section 2, however once again from the plats provided, it is difficult to ascertain the proximity of the Applicant's proposed mining operations in relation to any such future well and Facilities. Moreover, this setback area does not appeaz to be a legal well location in the SE/4NE4 Of Section 2. Finally, the Applicant's plan fails entirely to provide for future wells and related Facilities which Kerr- 3