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POCAHONTAS GAS LLC EE43 Underground Injection Control Well Application For disposal ofproduced fluids TAZEWELL COUNTY, VIRGINIA Prepared for the USEPA REGION 3 OFFICE Mr. Kevin Rowsey Source Water & U/C Section Water Division 1650 Arch Street Philadelphia, PA 19103-2029 PO Box 570 Pounding Mill, VA 24637 phone: 276-596-5137 [email protected] POCAHONTASNX GAS LLC December 18, 2020 Mr. Kevin Rowsey U.S. EPA Region 3 Office Source Water & UIC Section Water Division 1650 Arch Street Philadelphia, PA 19103-2029 RE: UIC Permit Application Well EE43 UIC Dear Mr. Rowsey; Pocahontas Gas LLC hereby submits this application for a UIC well, EE43. This application has been prepared using all the guidance documents as provided by the US EPA as well as public and private information regarding the Area ofReview. After you have had an opportunity to review this application, feel free to contact us with any questions or comments. Thank you for your attention to this matter. Sincerely, tMs.f!:r1~~5 Senior Production Engineer ~ 06~ Permitting Agent III TABLE OF CONTENTS Attachment A. Map and Area ofReview Part I Individual Permit form 7520-6 Part II Area ofReview Size Determination (fixed radius ¼ mile from well site) Part III Maps 1,2, 3 & 4 1. Topographic map showing Area ofReview (AOR): • Name and location ofall production wells, injection wells, abandoned wells, dry holes, and all water wells, noting their types. • Springs and surface bodies ofwater • Mines (surface and subsurface) and quarries • Other pertinent surface features 2. Topographic map extending ¼ mile from the AOR • Name and location of all production wells, injection wells, abandoned wells, dry holes, and all water wells, noting their types. • Springs and surface bodies ofwater • Mines (surface and subsurface) and quarries • Other pertinent surface features 3. Topographic map extending one mile beyond the facility property boundary, showing the following items; • Project injection well, well pad, and/or project area • Applicable AOR • All outcrops of injection and confining formations • All surface water intake and discharge structures and, • All hazardous waste treatment, storage, or disposal facilities. Part IV Area ofReview and Corrective Action Plans Part V Landowners Information Attachment B. Geological and Geophysical Information Part I. Geological Data Part II. Formation Testing Program Part III. Well Logs Part IV. Completion Reports Attachment C. Well Construction/Conversion Information Part I. Well Schematic Diagram Part II. Well Construction or Conversion Procedures Attachment D. Injection Operation and Monitoring Program Attachment E. Plugging and Abandonment Plan Attachment F. Financial Assurance Attachement G. Site Security and Manifest Requirements Attachment I. Existing EPA Permits Attachment J. Description of Business Attachment K. Optional Additional Project Information This certification statement is being submitted as an addendum to a letter to Mr. Kevin Rowsey, in reference to UIC Permit Application for EE43. CERTIFICATION STATEMENT I certify under penalty ofJaw that this document and all attachments were prepared undermy direction or supervision in accordance with a system designf:Jd to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry ofthe person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best ofmy knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility offine and imprisonment for knowing violations. Name: __...;c....ra___..ig..._W,___. .._N__e=al________ Date: /2-/S--~a~o Title: '{P O,iltWo-lta II'/~ Phone No. 12-</-</3:f-31/1, Signature: ~ N~~- 0MB No, 2040.0042 Approval Expires 4/3012022 United States Environmental Protection Agency For 0fftclal Use Only Underground Injection Control Date Received Permit Application for a Class II Well PennltNumber &EPA (CoUected under the ,uthorlty of the Safe Drlnlclng Weter Act. Sections 1'21, 1,22, and ,o CFR Part 1U) I 7 Read Attached Instructions Before Starting I. Owner Name, AddNu, Phone Humber end/or Email II. Opel'lltl)r Name, Address. Phone Number and/ot E1neU POCAHONTAS GAS LLC OCAHONTASGASLLC PQBOXS70 ~ OBOX570 CEDAR BLUFF, VA 24609 CEDAR BLUFF, VA24609 ~✓ [email protected] [email protected] 276-598-5048 276-596-5048 m. Commerolal FaoUlty IV. Owne,-hlp V. Permit AcUon Requeated -- VI. SIC Code(al VII. Indian Country ~ v.. 181 Prtvate !Zi NewPtrmlt O v• 0 No 0 Federal 0 Permit Renewal fgj No □ State/Tribal/ D Modification Municipal □ Add Well to Araa Permit 0 0ther L ~ l VIII. Type of Permit (F~ multiple wella, - eddltlanal page(•) to provide Iba lnformaUon requellted ~ Neb additional -II) t:8:1 A. Individual Number of Wells Well Field and/or ProJect Name ■ Q e.,- [ l If,-Oakw- ood-Field------_----, IX. ClaN and Typo of Well (He revel'N) /1. Clas■ B. Type (enter code(e)) c. If typo code I ■ "X.• explain. EJ[n II,._ _____________________________________...I. X. W•II Status XL WeU lnfom,ation 0 A. OperaUng @ B. Conv•111lon De. Proposed API Number @51850010700 I Date ln)11ctlon Started Date Well Con ■truct•d Permit (or EPA ID) Number I ) I...._. ____,I L_.--~-] :=:=====~--­ FuII Well Nam• f EE43 UIC XIL LouUon of Well or, for Multiple Wells, Apprulmate C.11t.r of Field or Project Locate well In two direction• from nHre■ t llnH of quarter ■action and drllllng unit LaUtude l.__3_7_.1_34_____ _ _,j Surface Location [=:]11, of i:=]11" of Sectlonc::]Townshlp c==]Rana•L Longitude !...·_8_1._85_1_______,I [ f ft. from (N/S) c:::=l Line of quarter aectlon ::=== ._!___...( ft. from (E/W) C:J Une of quarter aectlon. In .addition to this form, complete Attachments A-U (es approprlete for the specific -11 class) on Hparate sheets. Submit complete Information, as requ/18d In the Instructions and I/st Bil attec.hmants, maus or other t111urea, by the aaollcab/e letter. XIV, Cer.tlfloatlon I certify under the penalty of law that I have peraonally examined and am familiar with the Information submitted In thla document and all attachment■ and that, based on my Inquiry of tho■ e Individual ■ lmm ■ dlately re ■ ponalble for obtaining the lnfonnatlon, I believe that the Information I ■ true, aeeurate, ■ nd c:ompleta. I am aware thal there are significant penalties for submitting false Information, Including the poulblllty of fine and Imprisonment. (Ref. ,o CFR § 1.«.32) N11me and Offlcl ■ I TIUe (Please Type or Print) Date Signed ICraig W. Neal VP ofOperations IIZ -r~-Z.02<:J EPA Fonn 7520-S (Rev. 4-19) Attachment A Map(s) and Area of Review Well Location The well location for EE43 is in Tazewell County, Virginia, within the Maiden Springs District and the Jewell Ridge USGS topographic quadrangle. The site is located in the drainage area of Mud lick Creek, which is a tributary of the Clinch River. Specifically, from the community of Doran, go north on Mudlick Creek approximately 3.1 miles and the well is on an bench on the eastern hillside. Area of Review and Maps The subject proposed well, EE43 UIC, is a vertical, shallow natural gas well. An Area of Review Map (AOR) was prepared using the current information available for all wells, of all types, that are identified within the one-quarter mile radius of the project area. There are four CBM wells within the AOR. All the data was obtained from Pocahontas Gas LLC internal records; the Virginia Department of Mines, Minerals and Energy (DMME); and the Division of Gas and Oil (DGO). See Map 1. Map 2 shows pertinent surface features within the one quarter mile radius from the AOR. There are a total of 13 coalbed methane (CBM) wells and three surface water sources (springs). See Table 1 and Table 2. The CBM wells are drilled and completed within the Pocahontas No. 3 Seam at an average depth of 2,100 feet. These wells are currently producing coalbed methane from the Pocahontas No. 3 Seam and several other overlying coal seams. Water wells, Springs and Surface Water Domestic water supply wells and springs were identified by survey during the drilling of the CBM wells as required by the Division of Gas and Oil (see Table 2). The identified three water sources are natural springs, with no water wells located within the AOR. Surface waters are limited to small streams and tributaries of Mudlick Creek which flows south and adjacent to well EE43, then into the Clinch River near Richlands, and the Tazewell-Russell County Line, Virginia. Other surface features within the AOR are roads and previous mining reclamation scaring of the topography. There are no hazardous waste treatment, storage or disposal facilities; no surface water intake or discharge systems. There are no outcroppings of the confining or injection layers that are in the well, EE43, due to the rock formations being generally flat lying, horizontal, sedimentary rock layers that slightly dip to the west and north. See Map 3. Surface owners Map 4 is a depiction of the surface tracts and ownership based on our current mapping and parcel identification. In addition, we relied on county tax records available on the Buchanan County electronic database system (see Table 3). Mining Mining is entirely for coal from the nearby surface and underground. Surface mining is afforded by contour, high-wall, and mountain top removal methods. Underground mining is accomplished from slope entries driving horizontally into the coal seam. Mining predominately occurs in the Raven, Jawbone and Tiller seams, with lesser amounts from coal seams in the elevations above these seams. Currently, there is no active mining occurring within the Area of Review. There is no other mineral mining in the area. See Map 1A. Other Features There are no outcroppings of the proposed injection strata.

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