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Step 3. Abatement: Submit all missing well abandonment reports within 30 days. <br />Please see comments to item #1 above. <br />Step 4. Abatement: Fill all open well casings to within three feet of the surface within 30 <br />days. <br />Alleged Nature of Violation: Failure to plug and/or seal well casing to within three feet <br />of the ground sur ace. <br />See discussion for item # 2 above. All borehole casings are filled to the top with cement grout <br />before the concrete truck and technician leaves the site. It often takes an additional 1 hour to <br />insure that "burping" of air and bubbling is responded to with additional concrete. Casing 15 -07 <br />was cut off at below ground surface on December 11, 2014, before Service of this NOV. We <br />believe the level of concrete in the borehole was within 3 feet of the top of the trimmed casing. <br />The borehole was topped off with adjacent earthen materials up to the top of the casing and <br />covered before leaving the site. <br />Step 5. Abatement: Cut all remaining well casings below the ground surface within 30 <br />d —� . <br />Alleged Nature of Violation: Failure to cut well casing below sur ace. <br />Oxbow had two boreholes (15 -07 and 11 -02) located on otherwise excellent reclaimed areas that <br />had casing extending above the ground surface. This was an oversite by the contractors who <br />otherwise performed excellent reclamation work on the sites. It is worthy of note that Oxbow <br />responded by performing the trimming and cutting of the casing, then burying and regrading the <br />area with dirt and rocks before receipt of Service of the NOV on December 12, 2014. <br />Step 6. Abatement: Temporarily cap all longwall panel 18 and 19 wells within 30 days. <br />Alleged Nature of Violation: Failure to temporarily can and or seal wells that will be <br />used in the future as required. <br />All of Oxbow's open boreholes have flanges and caps installed or the exhauster pumps remain <br />connected. It is worthy to note the capping task was completed before service of the NOV on <br />December 12, 2014. <br />Step 7. Abatement: Survey all pad and road sizes and locations and correct these on the <br />appropriate map and exhibit within 30 dates. <br />Alleged Nature of Violation: Failure to construct drill pads as permitted (the pads are <br />larger than permitted). Failure to construct light use roads in locations) shown on map. Failure <br />to construct light -use roads as permitted (road widths are larger than permitted <br />Road/Pad Locations: Each of Oxbow's proposals for the location of the GVB light use roads and <br />drill pads occur as our best estimate for the proposed locations. Light use roads are "field fit" to <br />the conditions eventually found in the field. Roads and pad locations often receive minor <br />changes to reflect actual site conditions. As -built road locations often need to negotiate around <br />obstacles such as steep slope areas, rock outcrops, springs and seeps, landslides, etc. Often local <br />USFS personnel will direct changes in the proposed road/pad locations on USFS managed lands. <br />• Page 3 <br />