2008-01-28_REVISION - C1980007 ‎(2)‎

• Permit No: C1980007
• IBM Index Class Name: REVISION
• Doc Date: 1/28/2008
• Doc Name: Review Letter
• From: Division of Water Resources
• To: DRMS
• Type & Sequence: TR111
• Media Type: D
• Archive: No

DEPARTMENT OF NATURAL RESOURCES
DIVISION OF WATERESOUIZCES
Bill Ritter, Jr.
Governor
Harris D. Sherman
F' EP Executive Director
0
Dick Wolfe, P.E.
V Min Director
January 28, 2008
Tom Kaldenbach
Environmental Protection Specialist
Division of Reclamation, Mining and Safety
1313 Sherman Street, Room 215
Denver, Colorado 80203
Re: West Elk Mine (Permit No. C-1980-007)
Technical Revision Application No. 111 (TR-111)
E Seam Methane Drainage Wells for Longwall Panel E1 (Conceptual Plan)
Dear Mr. Kaldenbach:
The Division of Water Resources has reviewed the West Elk Mine (Permit No. C-1980-
007), Technical Revision Application No. 111 (TR-111). The revision proposes a
conceptual plan to drilling methane drainage wells to the mine's underground workings
in longwall panel E-1 The revision also includes the construction of 6 access roads and
14 drill pads, from which 16 wells will be drilled.
Methane drainage wells are not "wells" as defined in the Water Right Determination and
Administration Act and the Ground Water Management Act (Water Rights Acts), and
operators do not need to obtain a water well permit to withdraw water from these wells
as part of the extraction process. However, if water from an oil or gas well is put to
beneficial use other than those uses allowed under Colorado Oil and Gas Conservation
Commission (COGCC) Rule 907, then the Division of Water Resources has certain
jurisdiction over the water and the well, and the well is subject to the Rules and
Regulations for Water Well Construction, Pump Installation, and Monitoring and
Observation Hole/Well Construction (2CCR402-2). The COGCC Act grants certain
authority to COGCC to promote oil and gas conservation, and rescinds any authority of
any other agency as it relates to the conservation of oil and gas. Produced water from
an oil or gas well is considered a waste product by operators and must be properly
disposed of to prevent adverse environmental impacts. Pursuant to COGCC rules, an
operator may dispose of such water in any of the following ways: 1) inject into a
disposal well; 2) place it in a properly permitted lined or unlined pit for evaporation and/or
percolation; 3) dispose the water at a permitted commercial facility; 4) dispose of the
water by road spreading on lease roads outside sensitive areas for produced waters; 5)
discharge the water into waters of the state in accordance with the Water Quality Control
Act and the rules and regulations promulgated thereunder; 6) reuse the water for
enhanced recovery, recycling, and drilling; or 7) mitigation to provide an alternate
domestic water supply to surface owners within the oil and gas field.
Office of the State Engineer
1313 Sherman Street, Suite 818 • Denver, CO 80203 • Phone: [phone] • Fax: [phone]
www.water.state.co.us