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r-~--.. ~,~: ~ MOUNTAIN COa~ ~~. COMPaNVL.L.t:. A subsidiary of Arch Wesiem Resources, I.LC May 31, 2001 Ms. Sandy Brown Colorado Division of Minerals and Geology Office of Ivtined Land Reclamation 13 ] 3 Sherman Street, Room 21 ~ Denver, Colorado 80203 RECEIVED MAR 4 -'r~1? Division of Minerals and Geology West Elk Mine P.0. Box 591 5174 Highway 133 Somcrsc4 CO 81434 (970)9?9-5015 Fax (970)9?9-1595 Re: Mountain Coal Company LLC (MCC), West Elk Mine; Permit No. C-80-007; Minor Revision 270, Thermal Event Drill Hole Abandonment Procedure, Request for Authoriaation. Dear Ms. Brown: • As we discussed in our telephone conversation today, MCC is requesting authorization from the CDMG to place ~0' surface plugs in the cased wells used for water injection, and monitoring of water and gas levels at the thermal event drilling area. As you may recall, the 24 wells scheduled for abandonment, were cased to an average depth of 1,295 feet with an average O.D. of the casing at 5 inches. As the cosine was installed the exterior of the casing was grouted with cement slurry between the outside altnulus of the casing (~" O.D.) to the outside diameter of the hole (7 7/8" I.D.) or bedrock. Essentially, any water bearing formations and coal seams are effectively sealed between the outside annulus of the casing and the outside diameter of the hole. MCC is requesting authorization from the Division to place a packer at a depth of ~0' and install a cement plug to the top of the surface ca"sing in order to abandon these 24 holes. The area where these holes were drilled will require a minimum of 4' of subsoil and topsoil cover. The holes will be marked afrer the area is graded to the approximate original contour. We believe the proposed abandonment procedure is effective and addresses the regulations at 4.07.3 (1). The regulation states, "Sealing by a surface plug only may be approved by the Division on a case by case basis where both the physical and chemical properties of the formation allow." A schematic of the proposed procedure is attached for your reference. Also attached is the order for drill hole abandonment and a map depicting the location of the wells. . This request is necessary and prudent for MCC to proceed with the reclamation of the thermal event drill pad area. The Division's response to this request will determine the timing for reclamation for 2001.