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rock down the well casing, it took several seconds to hit water. This indicates that the <br />well was not sealed with concrete to the surface as indicated in the abandonment <br />report. In accordance with Rule 4.07.3(1), this well is required to be plugged from 10 <br />feet below ground surface to within 3 feet of the ground surface with cement or other <br />suitable media. Therefore, GVB -15 -07 was not sealed in accordance with 4.07.3 or the <br />approved permit and the abandonment report contains inaccurate information. <br />Additionally, the Teams field review of GVB -LW -1507 raised concerns regarding the <br />overall size of the surface disturbance at this location. The Team had brief discussion <br />about the need to confirm what the actual size of this pad was and before a <br />determination could be made in regards to the reclamation. The Team notes that <br />Section 2.04 E -3, Geologic Information Item 9 of the approved permit indicates that the <br />pad disturbance associated with this GVB was reported as 150'x150'. In order to <br />determine the pre- disturbance surface area and the post- disturbance surface area, <br />OSMRE used satellite imagery as a way to quantify and depict this information. As a <br />result, it was determined that this pad location has a surface disturbance size of 396'x <br />177', thus exceeding the size that was reported in the referenced document above by <br />approximately 1 acre. <br />Therefore, it is evident that 1) information reported in Section 2.04 -E3 is not accurate; 2) <br />construction of this pad was not in compliance with the permit at section 2.05, page 20; <br />and 3) there was a failure to comply with rule 4.05.5 (2)(c) (see pictures 12, 13, and <br />satellite image 1). <br />Six other observed GVBs were not capped although the casings were filled to the <br />surface with soil (GVB- 09 -04, 11 -02, GVB- 15 -06, GVB- 18 -09, 1808 and GVB- 19 -09). <br />Although the Team grew accustomed to seeing surface caps in the field, these are <br />temporary sealants which are not required for GVBs that have been sealed with <br />cement. Therefore, the Team attempted to determine whether these GVBs have been <br />appropriately sealed with cement. The abandonment report for GVB -11 -02 was listed in <br />the table of contents for Exhibit 2.04 -E3, but was not included in the document. GVB - <br />11-02 is identified on Drawing 2.05 -M1 as reclaimed. The abandonment report for GVB - <br />15-06 indicates that the 9 5/8" casing was abandoned to the surface with 30 cubic yards <br />of Portland type II cement in August 2010. The Team believes GVBs 11 -02 and 15 -06 <br />are sealed with concrete to prevent migration of materials between strata. Drawing <br />2.05 -M1 does not identify GVBs 18 -08, 18 -09, and 19 -09 as reclaimed. These GVBs <br />are above panels 18 and 19, where mining was not completed due to the fire. <br />As a result, the Team has reason to believe GVBs 18 -08, 18 -09, and 19 -09 have not <br />been temporarily or permanently sealed. Oxbow must place temporary or permanent <br />seals on all inactive GVBs in accordance with 4.07.2 or 4.07.3 (dependent upon <br />whether the GVBs have fulfilled their useful purpose or Oxbow wishes to retain them for <br />future use) and submit abandonment reports within 60 days of permanently sealing the <br />boreholes in accordance with 4.07.3(3). All other observed GVBs were temporarily or <br />permanently sealed. <br />roll <br />