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be achieved. A representative group of wells should be inspected by DMG during <br />installation if possible. Completion diagrams showing the actual as-built configuration <br />should be submitted to the DMG following installation of each methane drainage well. <br />These well completion diagrams should be incorporated into the permit document for <br />future reference. The completion diagrams will be used in conjunction with the <br />abandonment reports (described below) to assure compliance with permanent sealing <br />requirements. <br />Operation <br />Methane drainage wells may passively vent to the surface or they may require pumping <br />to liberate methane from underground. Regardless of how the wells are operated, <br />public health and safety is a primary concern during operation. At a minimum, the site <br />should be properly signed as potentially dangerous, especially on public lands and <br />National Forest. Anti-flare devices should be installed if necessary and fencing may <br />also be necessary in some circumstances. Monitoring during operation may be <br />necessary to ensure that the well is not leaking methane to the soil or surrounding area. <br />Dead vegetation is the usual indicator of a problem. <br />Abandonment - Rules 2.05.4 and 4.07 <br />Methane drainage well abandonment plans and procedures must comply with Rule 4.07 <br />Sealing Of Drilled Holes And Underground Openings. A reclamation plan and <br />abandonment procedures are standard requirements for all methane drainage wells. <br />Plugging and abandonment information and procedures shall be provided in writing in <br />the reclamation plan of the permit document. Site inspections of the methane drainage <br />well abandonment operations should be conducted periodically by DMG, if possible. <br />Following abandonment, operators will need to submit an abandonment report to the <br />DMG within 60 days. The abandonment report will verify that the methane drainage <br />well has been properly sealed. <br />Appropriate guidance for gas well abandonment has been developed by the American <br />Petroleum Institute (API). These abandonment procedures are contained in the <br />following document: Environmental Guidance Document: Well Abandonment and <br />Inactive Well Practices for U.S. Exploration and Production Operations jAPI Bulletin E3 <br />(BUL E3)). Detailed techniques for well abandonment are presented in the API <br />document. In general, the procedures discussed in this bulletin are applicable to the <br />abandonment of methane drainage wells. Operators may find this document useful for <br />obtaining specific information regarding various abandonment methods. There will be <br />differences in well installation and abandonment techniques due to the nature of <br />methane drainage wells versus gas production wells. The perforated casing intervals of <br />methane drainage wells are typically installed above areas to be mined. Following coal <br />removal, the potential for methane gas migration will increase due to subsidence effects <br />including caving of strata and fracturing of rock above the coal seam, and void <br />spaces/increased porosity created by mining. As described below, well casings may <br />also be damaged due to subsidence effects. Therefore, methane drainage wells may <br />present unusual abandonment situations. <br />3