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Hernandez, Alysha <br />From: <br />Boulay, Mike <br />Sent: <br />Thursday, May 24, 2012 2:46 PM <br />To: <br />DRMS - Coal -Admin <br />Cc: <br />Brown, Sandy <br />Subject: <br />FW: well abandonments <br />Alysha /Mary: <br />Please file this entire e -mail correspondence in laser fiche in Hydrology for Seneca II, Seneca II -W, and Yoast Mines. File <br />it in the Hydrology Index for each of these 3 mines. <br />From: Boulay, Mike <br />Sent: Thursday, May 24, 2012 2:40 PM <br />To: 'Jones, Dennis D.' <br />Cc: Burgmaier, Susan; Musick, Jason <br />Subject: RE: well abandonments <br />Dennis, <br />This plan is consistent with our discussions this morning and as proposed will meet the requirements of our <br />Rules and the SOE Rule for plugging wells (Rule 16). Keep in mind Rule 16.2 listed below in your original e -mail <br />is for unconfined bedrock and alluvial wells only. This plan would not be appropriate for confined bedrock <br />wells. The SOE plugging regulations assume that the wells were originally constructed in compliance with their <br />rules (Rules and Regulations for Water Well Construction, Pump Installation, Cistern Installation, And <br />Monitoring and Observation Hole /Well Construction). It assumes proper well construction and the use of <br />steel surface casing and approved grout plans for Type II Aquifers (unconfined bedrock) and Type III Aquifers <br />(unconsolidated, unconfined). If that is the case then their method for plugging and abandoning wells <br />completed in Type II and Type III aquifers is adequate. As you are aware we have varying levels of well <br />construction and well construction documentation. I'm not referring specifically to Seneca Coal Co. mine sites <br />but generally speaking that is the case. In particular older wells without good completion information could <br />be problematic. <br />As you pointed out SOE only requires cuttings, sand or gravel up to the static water level, then clean native <br />clays, cement or high solid bentonite grout to the ground surface for unconfined bedrock and alluvial wells. <br />Our permanent sealing rules are similar but differ primarily in that we allow our discretion in what constitutes <br />a "suitable sealant ". Your use of bentonite pellets in combination with a cement surface plug is a suitable <br />sealant and will suffice for unconfined bedrock wells (Type II). With regard to alluvial wells (provided the well <br />construction is competent), your proposal to use sand to a level above the perforated interval then grout to <br />the surface will be adequate to meet the requirements of our Rules and the SOE Rules for wells completed in <br />Type III Aquifers. For permanent sealing of confined bedrock wells refer to DRMS Rule 4.07.3(2). <br />Let me know if you have questions. I will have this e -mail correspondence scanned into the appropriate files <br />for each respective mine site for documentation. <br />Thanks, <br />35 =I- <br />