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00,0.0e00, <br />OXBOW MINING, LLC <br />3737 Hwy 133 P.O. Box 535 Somerset, Colorado 81434 USA Tel (970)929 -5122 Fax <br />(970)929 -5177 <br />August 30, 2013 RECEIVED <br />Mr. Brock Bowles SEP Q 4 2013 <br />Environmental Protection Specialist <br />Colorado Division of Reclamation, Mining and Safety DMSION OF RECLAMATION <br />1313 Sherman Street, Room 215 MINING AND SAFETY <br />Denver, Co. 80203 <br />Re: Oxbow Mining LLC, Permit No. C- 1981 -022 <br />TR -75 Application for 3MW, LLC pipeline and Borehole. <br />Dear Mr. Bowles, <br />The purpose of this letter is to respond to the Division's August 23, 2013 PAR #1 for Technical <br />Revision No. 75 to the Oxbow Mining LLC ( OMLLC) Permit No. C- 1981 -022. <br />Item #1. <br />The initial paragraph misstates the intent of the TR by stating that OMLLC is proposing to install <br />a de -gas borehole into the Sanborn Creek Mine. Rather, the TR provides for the modification of <br />the sealed and reclaimed Sanborn Creek Mine Portal area by 3MWLLC and North Fork Energy <br />for the installation of their de -gas borehole. The sealed Sanborn Creek portal area was seeded by <br />the Oxbow in 2003 and represents an area that is in the final reclamation time frames. Since the <br />Sanborn Creek Mine is now sealed and coal mining activities are no longer being conducted, the <br />control of the gas resource in the mine reverts back to the owners of the gas resource. Rule <br />1.04(132)(a) specifically provides that "Surface coal mining operations" do not include the <br />exploration and extraction of natural petroleum in a liquid or gaseous state by means of wells or <br />pipe. The proposed methane recovery project is considered a component of the "extraction" of <br />the gas resource and is permitted as such by 3MWLLC and North Fork Energy with the <br />Colorado Oil and Gas Conservation Commission (COGCC). OMLLC is trying to accommodate <br />the extraction of the gas and merely informing the Division, through the TR -75 process, where <br />the footprint of the gas extraction activities may overlap past coal mining activities. The <br />proposed project is not a surface coal mining operation. <br />For the Division's information, we have shown the footprint of the proposed pad on the modified <br />Map 2.05 -M1, Sheet 2 of 6. Subsequently, questions were raised by the Division as to the proper <br />location of the disturbance boundary for the previous coal mining activities. While we modified <br />the earlier map by excluding the proposed gas extraction project from the disturbance area, we <br />are in the process of modifying the map to return the disturbance boundary line shown on the <br />• Page 1 <br />