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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866.3567 <br />FAX: (303) 832-8106 <br />February 22, 2010 <br />COLORADO <br />D I V I S I O N OF <br />RECLAMATION <br />MINING <br />SAFETY <br />James A. Kiger <br />Environmental Manager Bill Ritter, Jr. <br />Govemor <br />Oxbow Mining, LLC Harris D. Sherman <br />P.O. Box 535 Executive Director <br />Somerset, CO 81434 Ronald W. Cattany <br />Division Director <br /> Natural Resource Trustee <br />Re: Elk Creek Mine, Permit No. C-1981-022, Oxbow Mining LLC (OMLLC) <br />Technical Revision No. 66 (TR-66), Gob Vent Borehole Sealing <br />Dear Mr. Kiger: <br />The Division of Reclamation Mining, and Safety (Division) has reviewed the above referenced <br />technical revision application materials submitted for the proposed change to the procedures for <br />sealing gob vent boreholes. On revised page 2.05-69a OMLLC proposes to revise the permit text <br />with the following; "Gob vent boreholes consist of a steel casing already cemented in place and <br />will be sealed with a plug at least 10 feet from the surface and then sealed with cement to the <br />surface." No other information was provided regarding the revised procedures for gob vent <br />borehole abandonment. The Division has the following adequacy review comments regarding <br />the proposed plan. <br />1. At a minimum, all drill holes must be abandoned in accordance with Rule 4.07.3. If the <br />gob vent borehole is completed through an aquifer(s), then sealing must be completed in <br />accordance with Rule 4.07.3 (2) and the entire depth of the blank casing should be sealed <br />using cement (from the bottom to within 10 feet of the surface). Please demonstrate that <br />each borehole to be sealed is not completed to an aquifer(s) and add this information to <br />the permit application package (PAP) under the Measures for Sealing, Plugging, and <br />Managing Mine Openings and Boreholes section. <br />2. In accordance with 4.07.3(1) If no aquifer is present, the well shall be sealed by replacing <br />a suitable media in the hole and placing a suitable plug 10 feet below the ground surface <br />to support a cement plug to within three feet of the ground surface. Sealing by a surface <br />plug only may be approved on a case by case basis where both physical and chemical <br />properties of the formation allow. <br />OMLLC has proposed sealing all gob vent boreholes with a surface plug only, therefore <br />please provide the Division with suitable demonstration(s) that the subsurface conditions <br />and the physical and chemical properties of the formation(s) allow for plugging with a <br />surface plug only. The Division will evaluate the adequacy of the demonstrations before <br />allowing sealing of gob vent boreholes by surface plug only. <br />Office of <br />Mined Land Reclamation Denver • Grand Junction Durango Office of <br />Active and Inactive Mines