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;ti <br />a '~~i ~r ~ <br />a ~,~: i <br />~I <br />- '~ <br />^~~ ,.-• <br />April 29, 2002 <br />V i't~.~v. Color III IIIIII IIIIIII III <br />999 <br />United States Department of the Interior <br />BUREAU OF LAS ID MANAGEMENT <br />Kremmhng Field Office <br />2103 E. Park Ace. <br />P.O. Bor GS <br />Kremmling, Colorado SU4i9 <br />9 i0-i_4-3000 <br />h~q)..~w~~~~ cu.hlm.¢nc Lia kr.unda:.hun <br />EFC[ Southfield Mine <br />Kerr Coal Company <br />George Patterson <br />PO Box 459 <br />Florence, CO 81266 <br />Dear Ivir. Patterson: <br />RECEIVED <br />APR 3 ~ ~~ <br />pivision of Minerals and GeolegY <br /> <br />I~ REarv RErER To: <br />This letter is written in response to Montgomery Watson Harza (MWH) letters dated 4/3/02, S[a[e of <br />Colorado letter dated 4/1 x/02, meeting of 3/27/02, and field reconnaissance of Kerr wells on 4/16 & <br />4/ 17/02. <br />Data was collected by GPS and a map was made (and copy delivered to MWH, and Colorado (J. S.)) <br />showing mis-labeled and mis-located wells from the previous Kerr "BLM-2" map. Mostly minor <br />relocation of sites resulted, but AK- and AL- wells were apparently mislabeled, and hole ?9-23 was <br />relocated. Again, this map only covers the wells found in the 4/16 reconnaissance that were found to be <br />mislabeled or mislocated. <br />Casing and well completion types (2" vs. 4", PVC, steel and fiberglass) were noted in the field <br />reconnaissance. It appears that Kerr only used 2" PVC in coal drill hole locations, with USGS using 2" <br />and 4" and fiberglass in wells. Kerr also sometimes used a shallow surface conductor 6" steel pipe <br />(example found excavated was 5' - 6' long (deep)) in cement. <br />Colorado State letter identifies that wells BLM-34 (DH-4), DH3-3b, DH-~, and DH-6 are Kerr's <br />reclamation responsibility. We concur. <br />This leaves the BLM responsible for bedrock well DH-3a, and alluvial wells 9,10,11,12,li,14, 23, G-1, <br />G-2, G-3, K-4, `C-~, X-6, #32 and X33 (16 wells). All other wells are the responsibility of Kerr. <br />The methods for abandonment of alluvial wells that do not intercept the federal coal resource only need <br />to be plugged to Colorado State standards (for both Kerr and BLM wells). Ho~.vever, the method <br />descr.bed in MWH letter is not thought ro necessarily meet such standards. We will defer approval of <br />any standards to the state for these wells. <br />