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iiiiuiiiiiiiiniu Burnell, Jim From: Brown, Sandy Sent: Wednesday, November 07, 2001 1:38 PM To: Burnell, Jim Subject: FW: Oxbow -----Original Message----- From: Brown, Sandy Sent: Wednesday, November 07, 2001 1:11 PM To: Burnell, Jim Subject: Oxbow Questions 17. 18. R 19. The coal de-gas methane wells at the Sanborn Creek Mine are now an integral part of the mine operating plan. As such, they are considered part of the mine disturbance and we are responsible for permitting, inspecting and making sure they are reclaimed. The mine permit application needs to clearly address these holes and show where they are located. The text in Section 2.05.3, page 2.05-19 is a generic discussion of the coal bed methane (CBM) holes. In the permit application, we need the specifics to track all these holes. In their response Montgomery Watson agrees that hte operation plan text, surface disturbance summary, and maps will be updated as appropriate to identify new degassification boreholes. (They say this has been done to date. W E have not updated the permit, I guess, because I don't see it.) Since the revised pages were not submitted, I do not know if it is acceptable. I can agree with them that the soil information for the overall soil balance can be handled separately from the overall soil balance. Without the revised pages it is difficult to know exactly what MW is proposing. Below are my initial thoughts based on what I think they are saying. Oxbow has proposed (through Montgomery Watson) is to update the drill hole tabulation in Exhibit 2.04-E3. As you saw, that is not a convienent location and the table references the mines coordinates. I prefer to have a table that clearly addresses these wells. This is what I had suggested in comment 17. A map showing the locations is also needed. It would be helpful to have a typcial coal bed methane well completion table in their permit also. We could go with the generic discussion in Section 2.05.3 and the table I suggested. If MW does not want to prepare a separate CBM table then they need to update to Table 2.05.3-T1, Mine Facilities summary, Table 2.05.4-T1, Surface disturbance Summary, and one or two of the Maps (General Facilities Map - 2.05-M1, Surface Disturbance Map 20.4-M3 or as MW suggested the Mine ARea Geology Map 2.04-M3). These tables and maps will need to clearly show the drill holes, pads, and roads leading to the holes. Mike Boulay, Kent and I have been working on a document to address the sealing of these de-gas holes. We hope to have something drafted soon. I don't think OMI has a clear reclamation plan for the holes and we will need to be sure they will abandon the holes to prevent gas seepage to the surface. Their abandonment plan on page 2.05-69 is very generic and we will need additional information from them before they start to seal these wells. Let's wait until the DMG document is final before we ask OMI for additional information for abandoning. Please do not forward this a-mail to them Sandy