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scheduled to commence for a determination of whether or not specific permit approval is <br />required. <br />(5) Please clarify that drillholes 17-01 d, 17-01 e, and 17-01 f will be drilled from the <br />17-01 pad as it is depicted on Map 2. <br />(6) It is assumed that MCC wishes that the drillpads be classified as "small area <br />exemptions" for purposes of drainage and sediment control. Please acknowledge the <br />intention to satisfy DMG rules directly related to sediment controlincluding 4.05.5, <br />4.05.2(3) and 4.05.2(6) and provide the necessazy descriptions so that the Division can <br />evaluate the drillpads as small area exemptions. <br />(7) On page 15, first paragraph, the statement is made that "interim reclamation <br />methods" would be used for drillholes awaiting fmal disposition. Please provide <br />information on these methods for the Division's review and approval. <br />(8) Please amend the annual operating plan to include, at a minimum, the sealing and <br />abandonment procedures as required in rule 4.07.3 rather than the method proposed by <br />MCC in the plan. <br />The Division is preparing a guidance document for the installation, operation and <br />abandonment of methane drainage wells. Once approved, this document will provide the <br />recommended approach for these situations. In the meantime, the Division will require <br />that drillholes be sealed and abandoned according to the existing rules as described in <br />4.07.3. A preferred method would be that described on page 14 of the annual operating <br />plan in the first pazagraph under "Drillhole Plugging Methods." This method has been <br />discussed by MCC and DMG previously but not used. <br />If you have any questions please feel free to call me. <br />Sincerely, <br />~ti~2~~~ <br />Jun Burnell <br />Environmental Protection Specialist <br />cc: Sandy Brown <br />