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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) 866-3567 <br />FAX: (303) 832-8106 <br />INTEROFFICE MEMORANDUM <br />TO: Jim Burnell <br />FROM: Mike Boulay ~~g' <br />DATE: May 5, 2004 <br />COLORADO <br />DIVISION OF <br />MIN SRALS <br />GEOLOGY <br />RECLAMATION•M WING <br />SAFETY•SCIENCE <br />Bill Owens <br />Governor <br />Russell George <br />Executive Director <br />Ronald W. Canany <br />Division Director <br />Natural Resource Trustee <br />SUBJECT: West Elk Mine C-80-007, Methane Drainage Well (MDW} Drilling Project Plan <br />I have reviewed MCC's annual operating plan for MDW drilling in 2004. I am very pleased with the <br />plan that MCC has submitted for the drilling and abandonment of 12 MDW holes in 2004. As <br />submitted, the drill hole plugging method is in compliance with DMG Rule 4.07.3 and our recent <br />guidance document: Installation, Operation, and Abandonment of Coal Mine Methane <br />Drainage/Monitoring Wells in Colorado, MCC submitted both a Typical MDW Well Design and a <br />Proposed Drill Hole Plugging diagram for our review prior to initiating the drilling program. MCC's <br />plan is absolutely compliant with our specific closure recommendation presented in the guidance <br />document (fifry feet of cement plug be placed at the lowest point inside the solid casing, above the <br />perforated interval of the well). MCC is also proposing to fill the remainder of the hole with a <br />suitable media. <br />I have a couple of minor comments regarding the submittal, which you may or may not choose to <br />forward to the operator. <br />1. Under the drill hole plugging methods page 13, it appears that MCC has misquoted our Rule <br />4.07.3. MCC indicates that rule 4.07.3 states "that each open hole will be plugged with cement from <br />bottom to within 50 feet above the uppermost thick coal seam and from 50 feet below to 50 feet <br />above any aquifers". Our rule makes no mention of the uppermost thick coal seam and our rule <br />actually requires 20 feet of sealant above and below the water bearing zone. <br />Office of Office of Colorado <br />Mined Land Reclamation Active and Inactive Mines Geological Survey <br />