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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />This was a partial inspection of the West Elk Mine conducted on June 1, 2004 by Mike Boulay <br />of the DMG. Mike Peacock of Mountain Coal Company was present during the entire <br />inspection. Weather conditions were sunny and warm and ground conditions were dry. The <br />purpose of this inspection was to observe permanent sealing of methane drainage wells. <br />Plugging and abandonment procedures were observed at two methane drainage wells (15-3.5 and <br />16-04). Other sites were also inspected including an active methane drainage well (MDW) <br />location and several reclaimed MDW sites: The MDW sites aze permitted as small azea <br />exemptions with silt fence being the primary means of sediment control. <br />The procedures utilized by MCC for permanent sealing of methane drainage wells include: <br />• Placement of rubber bridge plug at the lowest point or until refusal in the blank well <br />casing; <br />• Running tremmie pipe into casing and determining depth of bridge plug; <br />• Placing mixture of Hole Plug and water via tremmie pipe to a level approximately <br />twenty feet above bridge plug and ensuring that gas flow to the surface has ceased; <br />• Pumping approximately 100 feet of cement (Quick Crete) via tremmie pipe; <br />• Filling remainder of hole to approximately ten feet below ground surface (bgs) with <br />bentonite slurry; <br />• Placing cement plug from ten feet bgs to within three feet of the surface and <br />---~----- --~a~'~anin ----- <br />• Marking and surveying the hole. <br />Lang Exploratory Drilling is the contractor being utilized for sealing the methane drainage wells. <br />At MDW 15-3.5 the bridge plug hit refusal at 317 ft. bgs. The total depth of this MDW is 1196 <br />ft. Pouring the final twenty feet of bentonite slurry was observed at this well. At MDW 16-04 <br />the placement of the rubber bridge plug, running tremmie pipe and placing Hole Plug was <br />observed. The bridge plug hit refusal at approximately 276.5 ft. bgs and the total depth of MDW <br />16-04 is 1105 R. <br />The silt fence was slightly damaged at MDW 15-3.5. Please continue to maintain sediment <br />control around the base of the small azea exemptions and make repairs to silt fence as needed to <br />ensure compliance. <br />Please ensure that the calculated well volumes of Hole Plug, cement, and bentonite slurry versus <br />how much of each material is actually used to plug each MDW site is included in the <br />abandonment reports submitted to the Division. <br />