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Mr. Jim Burnell <br />May 5, 2004 <br />Page 2 <br />2. MCC also misinterpreted our surface plug requirement. Our rule requires placement of a <br />suitable plug 10 feet below ground surface to support aseven-foot cement plug. MCC is proposing a <br />5-foot cement surface plug. <br />3. MCC has not specifically addressed whether or not these holes will extend to aquifers. There <br />may be some contention as to the definition of aquifer. If they do extend to aquifers then the <br />Division must approve a suitable media for placement twenty feet above and below the water- <br />beazing zone. MCC is in compliance because they have indicated that they will use a CDMG <br />approved fill material for the remainder of the hole above the cement plug. MCC indicates the <br />remainder of the hole is to be filled with an approved completion mud, gel, cuttings, or cement. <br />MCC does not specifically state which of these they will use and the Division has not specifically <br />approved a sealant for above and below water bearing zones. I would recommend gel or cement if <br />water-bearing zones are encountered. <br />4. Under the drill hole plugging methods page 13, MCC indicates that they will reclaim existing <br />sites with interim reclamation methods until such time as it becomes evident from the results of <br />mining activities that these drill holes are no longer needed. MCC does not provide an explanation <br />of the interim reclamation methods. Just for our records, it might be useful to know what the interim <br />reclamation methods are particularly if the holes will remain open for long periods of time. <br />Please let me know if you have any questions regarding this review. <br />c: Sandy Brown <br />