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Steps Necessary to Abate Violation (Remedial Action) <br />Step 1. Abatement: Provide well abandonment reports in a timely manner. The Division <br />recommends changing the text to allow for all well abandonment reports to be submitted <br />to ether, by the end of the calender year in which they are sealed. <br />Alleged Nature of Violation: Failure to provide well abandonment reports in 30 days. <br />Oxbow acknowledges the Division's typo regarding 30 days vs. the 60 days required for <br />abandonment report submittals. Oxbow has previously submitted the borehole abandonment <br />information in three previous MRs 91, 94 and 102. The Division indicates it did not have a report <br />for 11 -02, while our records indicate it would have been included with MR -91 materials. We <br />have no explanation for this particular discrepancy. We will include an additional copy of 11 -02 <br />for the Division's records in the follow -up response to the NOV. Our further research indicates <br />abandonment reports for boreholes 16 -05 and 17 -05 need to be forwarded to the Division. An <br />abandonment report for 16 -08 was noted by OSMRE, but this borehole has not been sealed or <br />abandoned. We agree with the Division's suggestion that we change the PAP to indicate the <br />submittal of abandonment reports at the end of the year after the conclusion of the field season. <br />Ironically, this procedure is largely consistent with the practice already employed by Oxbow in <br />abandonment report submittals. <br />Step 2. Abatement: Correct all inaccurate well abandonment reports and resubmit within <br />30 days of the date of this violation. <br />Alleged Nature of Violation: Failure to provide accurate information in well <br />abandonment reports. <br />We are not aware of inaccurate reports. Perhaps there is confusion regarding the statement <br />"casing abandoned to surface with Portland cement." In all cases, concrete trucks filled the <br />casing to the top with cement grout. Often and routinely, the concrete trucks are held an extra <br />hour onsite at each pad in order to ensure filling to the top of the casing. Entrained air may cause <br />some "burping" and settling before the concrete is fully cured and the truck will continue to top <br />off the cement. Note that some boreholes may be over 2000' in depth and contain air that does <br />not consolidate immediately, and may in fact rise to the surface after the sealing operation moves <br />on to the next borehole. In no case did the Oxbow technician leave the borehole sealing <br />operation unless the cement was at the top of the casing. The reports were accurate when <br />prepared. <br />Other noted boreholes in the NOV. <br />We believe that 9 -04 and 15 -06 were appropriately sealed and cut off at the ground surface. 16- <br />08 was found capped, but not sealed and will undergo eventual further abandonment sealing and <br />reclamation. 18 -08, 18 -09 and 19 -09 are not abandoned and were capped before Service of the <br />NOV on December 12, 2014. All of these boreholes are in compliance with the Rules. <br />• Page 2 <br />