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To File <br />Page 3 <br />May 28, 1985 <br />Plugging and Abandonment Procedures <br />1980 Program <br />Applicable Standards <br />Section & of "Operational Instructions - Relating to Exploration on State-owned <br />Lands and Minerals" issued by the Board of Land Commissioners, State of Colora- <br />do (ref. SLB 9180) and attached to prospecting permit No. 854 from the Mineral <br />Department of the State Board of Land Commissioners (for the Indian Springs <br />Project) states: <br />"All holes shall be substantially and safely plugged according to the <br />State Engineer's requirements for water wells. Cement all geologic <br />formation contacts. Cement all aquifers top and bottom. ...Uranium <br />exploration holes shall be cemented from bottom to three feet below <br />plow depth. Any other method of plugging uranium exploration holes <br />shall be submitted for Board approval prior to use." <br />Attached to permit No. 854 was a proposed "Mobil" plugging procedure (see <br />attached Fig. 4). This method was approved by T. E. Bretz, Mineral Director, <br />on November 12, 1980. Briefly, the proposed Mobil procedure states that we <br />will plug all dry holes (those encountering no aquifers) from bottom to within <br />ten feet of the surface with a "high viscosity drill mud". Viscosity, mud <br />weight and gel strength were not specified. Atiy aquifers encountered were to <br />be "cemented off top and bottom". In the upper ten feet of all holes, we <br />proposed plugging with a concrete surface plug from ten feet to a minimum depth <br />"compatible with local cultivation practices". <br />In correspondence from Linda Walker. Mined Land Reclamation to Bruce Norton <br />(attached Fig. 5) in reference to the Indian Springs program, Ms Walker states: <br />"Note: Drill holes must be plugged in compliance with Rouse Bill. 1195. When <br />the regulations and drill hole reporting forms are approved, I will forward <br />them to Mobil.." House Bill 1195 stipulates (Section 34-32-113 (b) (?a.)) <br />(attachad Fig. 6) that "Drill holes which have encountered any aquifer isx <br />volrani.e or sedimentary rock..... shall he sealed using a sealing procedure <br />which is adequate to prevent fluid communication between aquifers". ho more <br />specific standards are mentioned. In addition, Sections 34-32-113 (h) (I) <br />specifies cementation of aquifers which produce artesian flow to the surface. <br />Section 34-32-113 (b) (III) specifies, in general terms, surface capping <br />procedures. <br />Procedure Followed <br />3