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E 2 through E 12 Longwall Panels Methane Drainage Wells Project Plan <br />PR-14 <br />Page 12 of 13 <br />left in a condition equal to or better than that observed on Mountain Coal Company's <br />entry into the area. <br />9. Any coal recovered incidentally to this project will be in the form of cuttings or core <br />and would either be taken back to the mine site or disposed in the mud pits. <br />ANTICIPATED SCHEDULE <br />Drilling of these wells is anticipated to commence in Spring 2009 depending on drill rig <br />availability. The Annual Operating Plan as approved by the USFS will be submitted to the <br />CDRMS prior to commencing any construction activities for the Annual Operating Plan. It will <br />take approximately 2 weeks to drill and complete each hole and perform interim reclamation. <br />Development of the low-volume roads for these wells is expected to commence during the <br />summer of 2009 to ensure access in the 2009-drilling season. A schedule of drilling and the year <br />of anticipated reclamation for each MDW pad is attached. (See section following Alpine <br />Archeology Consultants Report). <br />MCC will submit an Annual Operating Plan (AOP) each year that describes the methane <br />drainage well roads, pads, and wells that are planned for construction in the coming drilling <br />season. The AOP submittal will include an incremental reclamation bond for the construction <br />planned for the year. <br />The term of use is variable due to levels of methane found in the mine as a result of the drilling. <br />If successful and the prospects for good methane drainage appear positive, then these sites could <br />be operational for up to five years. Therefore the sites will be fenced and signed for public <br />safety. <br />MEASURES TO BE USED TO COMPLY WITH PERFORMANCE STANDARDS FOR THE <br />PROJECT (43 CFR 3484.1 (a)30 CFR 815 15 and Colorado Division of Reclamation Mining <br />and Safety Rules and Regulations) <br />1. Operator shall comply with applicable requirements of surface management agency, 30 <br />CFR 815.15, or approved State program. <br />2. Install casing and blowout preventers in drill holes in known oil, gas, and geothermal <br />areas. <br />It is anticipated that gas will be encountered in the rubblized-zone of the E Seam. Gas is <br />known to be encountered after mining in previous methane drainage holes in the area. <br />Casing will be set in each hole as necessary to maintain circulation of cuttings to the <br />surface. <br />3. Drill hole plugging requirements. <br />In accordance with the Coal Program Guidance Document - Methane Drainage and <br />Monitoring Wells, MCC will plug and abandon these MDWs per DRMS Rules 2.05.4 <br />and 4.07.3 at the minimum. A mechanical packer will be set at the lowest possible point <br />in the well (note that subsidence damage to the casing may preclude access to the entire <br />12