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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 8663567 <br />FAX: (303) 832-8106 <br />2 May 2005 <br />Mr. Henry Barbe <br />Mountain Coal Company LLC <br />P.O. Box 591 <br />Somerset CO 81434 <br />Re: West Elk Miue; C-1980-007; MR-307 Adequacy Letter <br />Deaz Mr. Bazbe: <br />COLORADO <br />DIVISION O F <br />MIN SRALS <br />GEOLOGY <br />RE CLANATION•NINING <br />EAFETY•ECIENCE <br />Bill Owens <br />Governor <br />Russell George <br />Executive DIlCCIOr <br />Ronald W. Cattany <br />Division Director <br />Natural Resource Trustee <br />The Division has reviewed your application for minor revision number 307 and has the <br />following comment. <br />Rule 4.06.3 (2) <br />1. The revision of Map 53B, Surface Facilities, Sylvester Gulch Facilities Area, as <br />included in the submittal, does not cleazly show the location of the drillhole 23-08 in <br />relation to the Sylvester Gulch topsoil pile. Please revise the map to clearly show that <br />the pad is not on the topsoil pile, as required by Rule 4.06.3(2). <br />Rule 4.07.3 <br />2. Mountain Coal Company has indicated that the drillhole plugging and abandonment <br />procedures will be the same as approved in TR-96 and subsequent annual operating <br />plans. The Division points out that MCC changed plugging and abandonment procedures <br />in 2004 based on a meeting with the Division to include the Division's recent guidance <br />document Installation, Operation and Abandonment of Coal Mine Methane <br />Drainage/Monitoring Wells in Colorado. The Division has the following comments <br />regarding the submittal and its reference to the 1996 technical revision. <br />a. Under the drill hole plugging methods, MCC indicates that "each open hole <br />will be plugged with cement from bottom to within 50 feet above the uppermost thick <br />coal seam and from 50 feet below to 50 feet above any aquifers." Rule 4.07.3 makes no <br />mention of the uppermost thick coal seam and our rule actually requires 20 feet of sealant <br />above and below the water-bearing zone as an option in cases wehre holes intersect <br />multiple aquifers. Please refer to the Rule as stated. <br />Office of Office of Colorado <br />Mined Land Reclamation Active and Inactive Mines GEnlogical Survey <br />