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,; <br />On 9 June 2006, the Division received Technical Revision 51 from Oxbow. This revision <br />requested the drilling of two boreholes at the Hubbard Creek Fan site. The first borehole <br />was to transfer water from the active D-Seam workings at the Elk Creek Mine to the <br />abandoned B-Seam workings of the Somerset Mine. The second borehole was an <br />injection well into the B-Seam workings of the Somerset Mine. The submittal did state <br />that, in the event that the B-Seam injection well hit a rib (or pillar, as was the case) that a <br />second well may be drilled. Oxbow had to drill three holes before completing one <br />properly into the B-Seam workings. This is noted in the 25 October 2005 and 15 <br />November 2005 inspection reports. The November inspection report specifically states <br />that the two boreholes that were drilled and not required need to be plugged and sealed. <br />To date, one of the two boreholes that missed the B-Seam has been sealed; the other <br />borehole needs to be sealed. It was my opinion that, although the application stated that <br />Oxbow might need to drill a second hole (in the event that the B-Seam was not hit), the <br />drilling of the third hole was not a violation. It was my opinion that it was a problem <br />encountered by the operator during the drilling operations and, although an extra <br />borehole was drilled, it was for the purpose specifically stated in the TR application and <br />the first and second boreholes will be sealed. <br />Oxbow's statement that they requested the Division to complete a reclamation liability <br />for the TR-51 and the Division's final approval did not include an increase in liability is <br />correct. This was due to an oversight on my part, for which I take full responsibility. I <br />do not believe, however, that this has any bearing on the facts of this violation. As an <br />aside, the Division currently holds an excess of bond of approximately $140,000.00. <br />Oxbow also submitted Technical Revision 53 for the drilling of 15 Gob Vent Boreholes <br />on 27 July 2006. This revision was approved with few adequacy issues on 30 September <br />2005 and resulted in an increase in liability of $137,204.00. This revision did not include <br />the drilling of a GVB or any other utility boreholes at the Hubbazd Creek Fan site. <br />This brings us to the violation I wrote on 23 January 2006, based on the inspection of 18 <br />January 2006. The violation was for drilling one extra borehole on the Hubbard Creek <br />Fan site. On that inspection Jim Kiger told me that the extra borehole was a GVB. In the <br />6 February 20061etter he states it is "another utility borehole for possible methane <br />drainage, electrical, air or water". The point is that this was never permitted. TR-51 <br />specifically permitted for two permanent wells at the Hubbard Creek Fan site. The <br />additional two temporary boreholes were necessary because they kept hitting pillazs in <br />the Somerset Mine. The third permanent "utility borehole" was never permitted and so a <br />violation was issued. <br />Oxbow asserts that since they permitted the two water injection boreholes, they had the <br />right to drill a third, permanent borehole at the site and submit an as-built to permit it. <br />Oxbow assers that the current situation is analogous to their submittal of TR-52, which <br />provided additional details and as-built drawings for the Hubbard Creek Fan (permitted <br />with TR-49) because of minor field modifications to the original design. The Division <br />does not agree that this is the same situation. The as-built certification submitted with <br />