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<br />Gregory L. Hunt <br />Bowie Resources, Ltd. <br />PO Box 1488 <br />Paonia, CO 81428 <br />RECEIVED <br />7 April 2003 <br />APR 1 1 2003 <br />Sandy Brown <br />Colorado Division of Minerals and Geology DivisienolMineralsandGeology <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Dear Mrs. Brown: <br />In response to the draft document "Installation, Operation, and Abandonment of <br />Coal Mine Methane De-gas Holes in Colorado", Bowie Resources Ltd. has the <br />following comments and suggestions relative to two sections of the document, <br />installation and abandonment. <br />Installation and Completion -Proposed Rules 3.03.2 4.03.2 4.04 and 4.07 <br />We agree with the statement under installation and completion -Rules 3.03.2, <br />4.03.2,4.04 and 4.07 that ..."proper completion is necessary to ensure the <br />abandonment of a well can be successfully accomplished." <br />To that end we note that the most important aspect of a well completion is the <br />responsible and careful operational practices demonstrated by the driller. <br />Aririitinnall~/ in many 'n +c.an^oe ~ <br />an issue. Type I Portland cement is the most readily available and most <br />commonly used for most construction applications. Many hydrocarbon-rich <br />sedimentary environments contain small amounts of sulfur, in the form of sulfates <br />(S04), which have been shown to inhibit proper curing of Type I Portland <br />Cement. Due to the importance of a successful completion, we believe it is <br />necessary to use sulfate resistant cement in all completions. <br />We are not recommending any one specific type or class of cement other than it <br />should be sulfate resistant. It should be noted that the API recommends class G <br />for well abandonment, but we believe Type 5 or similar cements will function <br />equally well. Attachment A is a summary of our research relative to sulfate <br />resistance. <br />