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Mountain Coal Company <br />West Elk Mine <br />Minor Revision 316: MDWs 19-Ola, 20-O1 and 20-03 <br />Page 2 of 2 <br />proposed MDW 19-Ola will not result in additional environmental impacts beyond those already <br />assessed in MR-306 and TR-96. <br />MDWs 20-O1 and 20-03 were both approved in TR-96, but were not identified for drilling in the <br />2005 MDW program when MR-306 was submitted and approved. In order to help resolve the <br />methane gas buildup recently encountered in the mine, MCC now proposes to drill these wells in <br />2005. <br />In accordance with the Coal Program Guidance Document -Methane Drainage and Monitoring <br />Wells, MCC will plug and abandon these MDWs per DMG Rules 2.05.4 and 4.07.3 at the <br />minimum. A mechanical packer will be set at the lowest possible point in the well (note that <br />subsidence damage to the casing may preclude access to the entire depth of the casing). Above <br />this packer the hole will be plugged with CDMG approved materials to the bottom of the 5-foot <br />cement surface cap using tremmie line. The top 5-feet of the well below the sub-surface casing <br />cut-off point (3-feet below the surface) will be plugged with a cement cap. The top 3-feet of the <br />casing will then be cut off and the hole filled in with subsoil. A permanent mazker shall be <br />installed on top of the plug identifying the MDW. The pad will then be reclaimed to <br />approximate original contour. <br />Attached aze three copies of <br />• Figure 1 showing typical Plug and Abandonment procedures, <br />• Schematics depicting the well designs (indicating among other features, surface <br />elevations and total well depths), <br />• A map highlighting the locations for these pads and wells, and <br />• The CDMG Revision Form <br />Tentatively, MCC will begin construction activities and drilling these wells (19-Ola, 20-01 and <br />20-03) as soon as the minor revision to the permit is approved. <br />This letter will be incorporated into the permit document with MR-316 in Volume 11A. Also, <br />the MS Excel workbook associated with MR 313, MDW Data Compilation will be updated to <br />include the activity associated with these MDWs subsequent to CDMG approval. <br />Please notify me with the Division's bond liability estimate so that arrangements can be made <br />should the estimate exceed the current total bond amount of $11,500,000.00. If you have <br />questions regarding this minor revision and information please call me. <br />Sincerely, `~ <br />enry be <br />Environmental Engineer <br />cc: P. Wyckoff P. Schmidt <br />Mike Peacock Ryan Taylor, USFS <br />