2007-11-16_REVISION - C1992081 - Laserfiche WebLink

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November 16, 2007 Mr. Daniel Hernandez Re: Hayden Gulch Loadout - MR-16 Page 3 Permit 22772-F was issued to H-G Coal Company in September 1977. The permit application shows a proposed well location in the SW/4 SWA Sec. 14, T6N R88W. The CDWR file indicates the permit expired (on September 21, 1978). However, the file also contains a well completion form that indicates the well was completed on August 18, 1978. As noted above, the CDWR files indicate Shallow Well No. 1 (Permit 24567-F) was completed as a replacement well for 22772-F (in January 1980). There is no information in the files as to why H-G Coal Company had to replace 22772-F. Furthermore, the files do not appear to have a well abandonment report for 22772-F. However, there is a letter from H-G Coal Company to Division of Water Resources, dated November 20, 1980, that reads "Well No. 22772-F has been plugged and abandoned in accord with item 5 under Conditions o Approval (for 24567-F). It would be appreciated if you would send the required affidavit form to me for completion. " The abandonment affidavit (dated November 25, 1980) sent to HGTI as part of the Coal Bond Compliance Inspection Form is for a well located in SWA NEA Sec. 30 T5N R88W. This legal description does not correspond with the legal provided in the well permit application for 22772-F; it is outside of the permit boundary for the Hayden Gulch Loadout (Permit C-92-081) - the location corresponds with the reclaimed and closed Hayden Gulch Mine. The CDWR files suggest this affidavit corresponds to Permit 22771-F (Grace-Hayden Well A), which was permitted, and completed in the same period as 22772-F. HGTI and CDRMS representatives conducted a ground reconnaissance at the Loadout on September 19, 2007 in an effort to locate signs of 22772-F (Grace-Hayden Well B). An approximate location was identified immediately west of the existing dust control system pressure tank building and existing water tank using the distances from section lines provided on the Statement of Beneficial Use (dated November 20, 1980). A steel cap, casing and concrete pad were found; the casing was filled with concrete up to the ground surface. Mr. Byron Walker, CDRMS's inspector, took a picture of the abandoned well and included in it in the September 19, 2007 Coal Inspection Report. Abandonment documentation that should be inserted into the PAP include the November 20, 1980 letter and page 4 of the September 19, 2007 inspection report. Item 5. The removal of Yampa Valley Electric Association, Inc. (YVEA) power lines and the substation at the site are, in a lease agreement, at the option of YVEA (Tab 3, Appendix 3-4, PAP). The PAP reads as though the lines were dedicated to the site operations. Please acquire from YVEA, and insert into the reclamation plan, a letter of anticipated course of action (removal, or retention in support of current other or future uses) in the event that the site is abandoned and permit terminated. Response: As noted in the comment, YVEA owns electrical distribution facilities that cross-over and/or are located on the Loadout permit area. HGTI contacted YVEA regarding the status of these facilities (e.g., 69KV transmission line and power substation) in response to CDRMSs question. According to Mr. Paul Vaillancourt, YVEA's Manager of Operations and Engineering, the 69 KV transmission line and electrical substation are part of YVEA's electrical power distribution system in the Hayden, Colorado area and are used to service other areas, facilities and customers besides the Hayden Gulch Loadout. The 69KV transmission line will not be removed. YVEA has indicated Hydro-Environmental Solutions, Inc. P.O. Box 772996 5710`h Street, Suite B Steamboat Springs, CO 80477 970-871-6125 * 970-871-6196 (fax)