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To Pile <br />Page k <br />May 28, 1985 <br />The 1980 Drilling Program began on November 17, 1980 and ended on December 15, <br />1980. Copies of drilling tickets and invoices for the 1980 program were <br />obtained from Mateti Exploration, drilling contractor on the project. Based on <br />these documents, the program used a high-yield sodium bentonite gel with brand <br />names of Petroplus Gel or Bed Devil Gel as a hole abandonment mud. The mud was <br />used on an average rate of .089 lbs/foot of hole. Mixing and circulating took <br />approximately 20-30 minutes per hole. <br />Existing records do not indicate what the final mud weight or viscosity was. <br />However, Bob Timmer, currently with Mobil in Midland recalled that a viscosity <br />measuring funnel was used at least on an occasional basis. He could not recall <br />what the character of final product was. An attachment to a 1977 letter from <br />Charlie Greenberg to the State of South Dakota (attached, Fig. 7) described a <br />Mobil hole abandonment procedure in which the abandonment fluid would have a <br />weight of nine pounds per gallon and a tunnel viscosity of 45 seconds/quart. <br />it should be noted that in a recent telephone conversation, Marti Gardner, mud <br />engineer with Advanced Fluid Systems, Denver indicated that, as a rule of <br />thumb, when mixed solely with water, Petroplus Gel and Red Devil Gel are <br />required at a rate of approximately .5 lbalfoot of hole for a five inch diame- <br />ter hole in order to meet current Wyoming standards. Although this is consid- <br />erably more than our 1980 usage, Bob Goble, with Western Exploration, indicated <br />that over our 1980 usage was consistent with industry practice at the time. In <br />addition, if we mixed the gel with natural, formation mud from the drilling, we <br />would have obtained a higher viscosity that if we had mixed the gel with water. <br />in his letter of April 13, 1981 (attached Fig. 8) to Linda Walker (MLR) Bruce <br />Norton, Field Coordinator for Mobil stated that "No artesian flow was encoun- <br />tered in any hole. All holes were plugged from bottom to within ten feet of <br />surface with a high viscosity drilling fluids". <br />A cement surface plug was installed from the top of the mud plug (ten feet <br />below the surface) to within two feet of the surface or to the surface, depend- <br />ing on local cultivation practices. Invoiced cement usage of slightly more <br />than one bag per hole is consistent with this surface plug installation. <br />Based on the above findings, it appears that mobil plugged the drill holes in a <br />manner consistent with the procedure approved by Bretz of the State Board of <br />Land Commissioners. However, it is uncertain if it complies with the wishes of <br />the Mined Land Reclamation Board. <br />1.978-r9 PF . <br />Applicable Standards <br />Page 2 of the 1978-79 program permit (Colorado Prospecting Permit NO. 665) <br />states with regard to hole plugging: <br />4