2009-02-23_PERMIT FILE - X200921208 (3)

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No significant aquifers are anticipated to be encountered. The Mesa Verde Formation is known to contain limited water bearing sandstones, although no aquifers are anticipated. If significant quantities of water are encountered, the appropriate regulatory officials will be notified and if so directed, the hole may be completed as additional water monitoring well. Modification of Drill Holes to Methane Drainage Wells (MDW) For the Dry Fork area holes, three of the four planned holes in the exploration program will be converted from exploration holes to MDW holes. Upon completion of core drilling and geophysical logging, the bottom of the drill hole will be plugged with cement, and the annulus of the hole reamed to 7 7/8". Solid and slotted casing will be installed in manner consistent with approved MDW holes. A locked valve assembly will be left in place for future use as an MDW. The pad site will be partially reclaimed as described below. For reference, the identification of the holes will change upon initiation of drilling. Site 2009-A will become MDW E4-35. Site 2009-B will become E4-38.5. Site 2009-C will become E4-54. Drill Hole Abandonment Methods The hole plugging method described in 43 CFR II 3484.1(a) or Colorado Division of Reclamation, Mining and Safety (CDRMS) Rules and Regulations at 4.07.3, states that each open hole will be plugged with cement from bottom to 50 feet above the uppermost thick coal seam and from 50 feet below to 50 feet above any aquifers encountered in the hole. The remainder of the hole is to be filled with an approved completion mud, gel, cuttings, or cement to within 5 feet of the surface. A 5-foot cement surface plug would be set, and an appropriately labeled monument marker to be cemented into the surface plug. Surface casing is to be cut off at or below the level of the soil surface. In accordance with the recent Coal Program Guidance Document-Methane Drainage and Monitoring Wells, MDW wells will be plugged per CDRMS Rules 2.05.4 and 4.07.3 at the minimum, recognizing that due to subsidence, damage to the casing may preclude setting a packer within 50 feet of the perforated casing. In such cases, the packer will be set at the lowest possible point in the well. A cement plug will be installed with tremmie line beginning at the plug and preceding a minimum of 50 feet up the well. From that point the hole may be plugged to within 5 foot of the casing cut-off point with approved materials. The top 5 feet of the well below the sub-surface casing cut-off point (3 feet below surface) will be plugged with a cement cap. The top 3 foot of the casing will then be cutoff and the hole filled in with subsoil. A permanent marker shall be installed on top of the plug identifying the MDW. The pad will then be reclaimed to approximate original contour. Associated drill roads will be obliterated per USFS direction. Reclamation Plan 10