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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations <br />made during the inspection. Comments also describe any enforcement actions taken during <br />the inspection and the facts or evidence supporting the enforcement action. <br />This was a complete inspection of the Meadows No. 1 Mine, in conjunction with a Phase <br />III (Final) Bond Release inspection for the portion of the reclaimed pit area owned by John <br />and Allie Silts. The inspection also focused on the continuing evaluation of the reclaimed <br />pit area owned by Grassy Creek Coal Company, to determine its eligibility for final bond <br />release. Present during the inspection were Larry Routten and Susan Burgmaier of CDMG, <br />Bryan Archer of Sun Coal Company; and Michael Savage, of Savage and Savage, who is a <br />consultant for Sun Coal Company. John Silts and Mitch Rollings, of the Office of Surface <br />Mining, were present at the beginning of the inspection. Weather conditions were cool and <br />cloudy, ground conditions were dry. <br />Mitch Rollings came to the site to discuss a concern that John Silts had regarding a broken <br />oil well casing. Mr. Silts telephoned Mr. Rollings on September 17, 1996, and described <br />the problem to him. During the inspection, Mr. Silts told the inspectors that he suspects <br />that a broken casing in an oil well adjacent to the mined area had been caused by blasting <br />operations at the Meadows No. 1 Mme. Details provided by Mr. Silts included: <br />^ The well was drilled in 1958, and produced (off and on) through 1994. <br />Production of the well was 3-5 barrels per day. The production zone was at <br />4700'. <br />^ Mr. Silts acquired the well in 1983. <br />^ In 1994, 3000' of the 5000' of tubing in the well was pulled. At that time, two <br />breaks, at 400' were discovered. The breaks were clean breaks, nearly all the <br />way through the pipe. The pipe is a 23/a" diameter pipe. <br />^ Mr. Silts has contacted the Oil and Gas Conservation Commission, and was <br />told that he should abandon the well. <br />^ Mr. Silts estimates it will cost $5,000 - $10,000 to abandon the well. <br />^ Mr. Silts indicated the cause of the casing break may also have been <br />subsidence of a pre-SMCRA underground mining operation in the vicinity of <br />the well. <br />Mr. Archer indicated: <br />^ Sun Coal Company has maps of previous underground workings in the area <br />(maps were obtained from the Division), and that the Routt Pinnacle Mine <br />had main entries running North/South with the strike of the coal. He did not <br />believe the mined area went as far as the well location. <br />^ Blasting at the Meadows No. 1 Mine concluded in 1982, and the deepest pit <br />in the mine was 70' deep. <br />Mr. Rollings informed Mr. Silts that in order for the complaint to be addressed, he must <br />file a wntten coinptaint with the Division. If a written complain[ is filed, and he is not <br />satisfied with the Division response, he should contact OSM. Mr. Rollings also mentioned <br />that any written complaints should be filed before final bond release on the site, as the <br />Division and OSM would no longer have jurisdiction over the site once release occurs. <br />Meadows No. ]Mine 1 September 23, 1996 <br />