2008-04-22_PERMIT FILE - X200822901 (4)

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Monitoring or Water-Supply Well Completion -CCR anticipates coverting drillholes CCU013, CCU014, CCU021 and CCU025 into groundwater monitor wells. These drillholes will be completed as underburden monitor wells (e.g., will be used to monitor groundwater in the stratigraphic unit below the Wadge coal seam). In addition to these underburden monitor wells, a hole will be drilled and a well completed at each exploration site (CCU013, CCU014, CCU021 and CCU025) to monitor groundwater in the Wadge coal and overburden units. The drillholes and monitor wells are designated as "a" and "b" for the Wadge coal and overburden monitor wells, respectively (e.g., CCU013a and CCU013b; see Table 2). In compliance with applicable provisions of 43CFR 3484.1(a) and 37-92-602, C.R.S, prior to conversion of an exploration drillhole to a monitor well, authorization will be obtained from the appropriate regulatory authority(s). Monitor well permit applications have been submitted to Colorado Department of Water Resources (CDWR). Per Rule 5.2.31 (2 CCR 402-2), a temporary drillhole can be converted into a monitoring or observation well within one year of being drilled after proper notice of intent is given CDWR. The well permit applications constitute proper notice of intent; consequently, CDWR permit issuance is not needed prior to initiating the exploration activities. Monitor wells will be constructed in accordance with the Water Well Construction Rules (2 CCR 402-2). In general, monitor well construction will involve placement of steel surface casing, casing the open drill hole with solid steel pipe (0.188-inch minimum wall thickness), placing perforated-slot screen and 8/12 silica sand or apre-packed, stainless steel or PVC well screen in the desired completion interval, establishing bentonitic plugs above and below the screened interval and grouting the well annulus to prohibit vertical migration and cross-contamination of aquifers. Following construction, the monitor well will be developed by successively flushing and pumping the well bore to remove drilling fluids, drill cutting and other materials introduced into the borehole during the drilling process. Figure 2, Typical Monitoring Well Completion, illustrates typical completion methods. In accordance with Rule 14.2.6 (2 CCR 402-2), a well completion report (Form GWS-31) will be submitted to CDWR within 60 days of completing the well. Once the well is no longer needed, it will be plugged and sealed in accordance with the appropriate rules and regulations (Rule 16, 2 CCR 402-2). If CCR permits the Cow Camp project as an underground mine under Regulations of the Mined Land Reclamation Board for Coal Mining, all relevant well permit and completion forms will be included as part of the permit application package. Proposed Reclamation Methods: The proposed exploration program is designed to minimize new surface disturbance by utilizing existing roads and trails to the extent possible, placing drill pads adjacent to existing roads, utilizing previously disturbed areas for drill pads, and limiting pad size. Surface disturbance, and reclamation requirements and costs calculated by CCR are summarized on Table 3, 2008 Exploration Program Reclamation Cost Estimate. Upon approval of the NOI, CCR will file a corporate surety with the Land Mined Reclamation Board to ensure that the reclamation obligations are fulfilled. If CDRMS completes an independent bond calculation estimate as part of the NOI review CCR may choose to file a corporate surety for the least cost estimate. The following sections describe the specific proposed reclamation practices to be used to return areas disturbed by the exploration activities to a stable condition and productive use. Drill Hole or Well Plu~~ing= Sealing and Abandonment: All drillholes will be plugged, sealed, and abandoned unless they are converted into a groundwater monitor well. Deeper drillholes will be plugged with a minimum of 6 cubic yards (about 750 feet) of cement slurry -this is the off-road Cow Camp Project - 200R N01 a/l5/08 12