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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made during the <br />inspection. Comments also describe any enforcement actions taken during the inspection and the facts or <br />evidence supporting the enforcement action. <br />The purpose of this inspection was to observe the permanent sealing operations for a gob vent <br />borehole, to ensure that the agreed upon methane degas borehole sealing procedures aze being <br />followed. Greg Hunt represented the operator in the coordination of the gob vent borehole sealing and <br />inspection. Edward Scartezina of Reclamation, Abandonment and Completion Services (RAGS) <br />performed the field work. <br />The borehole that was to be sealed is designated as GVB-WD-3A. The total depth of this 5.5 inch <br />diameter borehole was 960 feet, with blank casing down to 553 feet The open hole perforated casing <br />ran from 553 feet down to 763 feet. The annulus was cemented from the surface down to 490 feet. <br />Attached to this report is the well completion diagram for GVB-WD-3A, provided by the operator. <br />The day before the field inspection, BRL ran a borehole camera down the hole and recorded the <br />images. The images were reviewed by BRL and the Division on the day of the inspection. The images <br />showed that subsidence-induced shear had affected the borehole casing. There was a small bump in the <br />borehole casing at a depth of 143 feet and a major bump in the casing at a depth of 342 feet. The <br />operator could not get the camera past the casing bump at 342 feet depth. The camera images did not <br />show any areas where the casing was completely sheared off or completely closed. Based on the <br />camera data, a determination was made to place the packer just above the large bump in the casing. <br />Even though this meant that the borehole seal would be well above the perforated casing, there did not <br />seem to be a reasonable way to seal the borehole at a deeper point. <br />The major equipment at the well site consisted of a flatbed trailer, a cement truck and a water truck. On <br />the flatbed trailer were a large spool of 1500 feet of coiled pipe and a small spool of metal cable. A <br />hydraulic power pack powered the two spools. The cement mixture consisted of cement, fly ash and a <br />plasticizer. The fly ash is to give the cement increased resistance to deterioration from sulfur. The <br />plasticizer is to give the cement more fluidity while it is being pumped into the borehole. Four workers <br />were present. <br />The well cap was removed and methane recordings were measured. Methane was coming out of the <br />borehole. A tag weight was lowered into the borehole by cable to find the depth. The tag weight got <br />past the small bump in the casing at a depth of 143 feet but couldn't get past the large bump in the <br />casing at a depth of 342 feet. <br />An inflatable packer was lowered into the hole by cable, with a plastic tube attached, and was set at a <br />depth of 335 feet, confirmed by the cabled tag weight. The packer was set in a section of straight pipe <br />just above the large casing bump to ensure a positive fit in the casing. Carbon dioxide gas was injected <br />into the packer through the plastic tube so that the packer would expand and close off the borehole. <br />The carbon dioxide gas pressure was monitored to ensure that there were no major leaks in the packer. <br />The borehole was monitored for methane again. No methane was coming out of the borehole. With the <br />plastic tube removed, the tag weight was, again, cabled down the hole to get the depth to the packer <br />and to ensure that the packer was still in place. The packer was set at a depth of 335 feet. <br />