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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 />A hand-held, survey grade GPS unit was used to field locate the former monitoring well <br />and exploration-hole locations (see attached Photo 1). In all but only a few cases there <br />was no evidence of the former monitoring well or drill hole in the field. This is due to the <br />fact that the number of acres reclaimed during the well abandonment is insignificant. <br />Each well takes a reclaimed area of less than 0.5 square feet at the surface. According to <br />WFC and information obtained from available records, the reclamation work was <br />conducted as per the permit requirements. <br />At all of the monitoring well locations for which bond release was requested, the <br />vegetation had become re-established at the site of the former well. From three feet <br />below ground to the surface was filled with topsoil and seeded at each location. In only a <br />couple of cases there were a small amount ofrock chips evident and in one case (GW- <br />N27) there was an old monitoring well tag with the well number left on the ground <br />surface (see Photo 2). <br />At the exploration holes that could be located, vegetation is less well established because <br />they have only recently been abandoned (2005). A large number of the exploration drill <br />holes were located in what is now the pit area and have been mined through including <br />NHOS-1 c through NHOS-13c, The remainder of the exploration holes aze located within <br />the permit boundary to the west and south of the active pit area. The majority of these <br />holes are in a current producing hay field and there was no evidence of the exploration <br />holes at the surface. <br />Based on this inspection, it was determined that all of the 21 groundwater monitoring <br />wells and 27 exploration drill holes had been abandoned. Abandonment reports have <br />been submitted to the Division for all of the exploration drill holes. These were <br />submitted with Minor Revision No. 72. Monitoring well abandonment reports were <br />located for all groundwater monitoring wells except for the following: GW-N4, GW- <br />N4R, GW-NS (indicated by WFC as mined through), GW-Nl l (indicated as reclaimed <br />but no abandonment report), and GW-N16, -17, and -18. As stated in WFC's amendment <br />to the bond release application dated January 31, 2007, GW-N16, -17, and -18 were <br />reclaimed by Peabody Coal Company while WFC was in the process of acquiring the <br />New Horizon Mine from them. If abandonment reports are available or can be located <br />for these seven wells mentioned above, please submit these records to the Division. <br />