| In the matter of Boone Resources, Inc. Boone No. 1 Mine I.D. No. 0102908 | Petition for Modification Docket No. M-96-074-C |
Date Issued: 02/01/1997
PROPOSED DECISION AND ORDER
On May 31, 1996, a petition was filed seeking a modification of
the application of 30 CFR 75.1700 to Petitioner's Boone No. 1
Mine, located in Shelby County, Alabama. On July 26, 1996, the
Petitioner filed supplemental information completing the petition
and listing provisions for mining through plugged abandoned gas
well. The Petitioner alleges that the alternative method outlined in the petition, as amended by the supplemental information, will at all times guarantee no less than the same measure
of protection afforded by the standard.
MSHA personnel conducted an investigation of the petition and filed a report of their findings and recommendations with the Administrator for Coal Mine Safety and Health. After a careful review of the entire record, including the petition, the amending supplemental information, and MSHA's investigative report and recommendation, this Proposed Decision and Order is issued.
MSHA personnel conducted an investigation of the petition and filed a report of their findings and recommendations with the Administrator for Coal Mine Safety and Health. After a careful review of the entire record, including the petition, the amending supplemental information, and MSHA's investigative report and recommendation, this Proposed Decision and Order is issued.
Finding of Fact and Conclusion of Law
The alternative method proposed by the Petitioner (as amended by
MSHA) will at all times guarantee no less than the same measure
of protection afforded the miners under 30 CFR 75.1700.
On the basis of the petition and the findings of MSHA's investigation, Boone Resources, Inc. is granted a modification of the application of 30 CFR 75.1700 to its Boone No.1 Mine.
On the basis of the petition and the findings of MSHA's investigation, Boone Resources, Inc. is granted a modification of the application of 30 CFR 75.1700 to its Boone No.1 Mine.
ORDER
Wherefore, pursuant to the authority delegated by the Secretary
of Labor to the Administrator for Coal Mine Safety and Health,
and pursuant to Section 101(c) of the Federal Mine Safety and
Health Act of 1977, 30 U.S.C., sec. 811(c), it is ordered that
Boone Resources, Inc.'s Petition for Modification of the application of 30 CFR 75.1700 in the Boone No. 1 Mine is hereby:
GRANTED, for plugging of gas wells and the mining through of plugged gas wells at the Boone No. 1 Mine, conditioned upon compliance with the following terms and conditions:
I. Boone Resources, Inc. shall provide to the MSHA District Manager, at least 30 days prior to any mining within 300 feet of a gas well in preparation of mining through of any gas well, written certification that the gas well was plugged using methods that meet or exceed the technique and procedures set out in paragraphs (a), (b) or (c) below:
a) Cleaning out and preparing oil and gas wells. Prior to plugging an oil or gas well, the following procedure shall be followed:
(1) A diligent effort shall be made to clean the borehole to the original total depth. If this depth cannot be reached, the borehole shall be cleaned out to a depth which would permit the placement of at least 200 feet of expanding cement below the base of the lowest minable coalbed.
(2) When cleaning the borehole, a diligent effort shall be made to remove all the casing in the borehole except surface casing. If it is not possible to remove all casing, the casing which remains shall be perforated, or ripped, at intervals spaced close enough to permit expanding cement slurry to infiltrate the annulus between the casing and the borehole wall for a distance of at least 200 feet below the base of the lowest minable coalbed.
(3) If the cleanedout borehole produces gas, a mechanical bridge plug shall be placed in the borehole in a competent stratum at least 200 feet below the base of the lowest minable coalbed, but above the top of the uppermost hydrocarbonproducing stratum. If it is not possible to set a mechanical bridge plug a substantial brush plug may be used in place of the mechanical bridge plug.
(4) A suite of logs that is suitable for deter mining the top and bottom of the lowest min able coalbed and potential hydrocarbon-producing strata shall be made available.
(5) If the uppermost hydrocarbon-producing stratum is within 200 feet of the base of the lowest minable coalbed, properly placed mechanical bridge plugs or a suitable brush plug as described in subparagraph (a)(3), shall be used to isolate the hydrocarbon-producing stratum from the expanding cement plug. Nevertheless, a minimum of 200 feet of expanding cement shall be placed below the lowest minable coalbed.
(6) The wellbore shall be completely filled and circulated with a gel that inhibits any flow of gas, supports the walls of the borehole, and densifies the expanding cement. This gel shall be pumped through openend tubing run to a point approximately 20 feet above the bottom of the cleanedout area of the borehole or bridge plug.
(b) Plugging oil and gas wells to the surface. The following procedures shall be utilized when plugging oil and gas wells to the surface:
(1) A cement plug shall be set in the wellbore by pumping an expanding cement slurry down the tubing to displace the gel and fill the bore hole to the surface. (As an alternative, the cement slurry may be pumped down the tubing so that the borehole is filled with, Portland cement, or a Portland cement-fly ash mixture, from a point approximately 200 feet above the top of the lowest minable coalbed to the surface, with a expanding cement plug extending from at least 200 feet below the lowest minable coalbed to the bottom of the Portland cement. There shall be at least 200 feet of expanding cement below the base of the lowest minable coalbed.
(2) A surface casing or a small quantity of steel turnings, or other small magnetic particles, shall be embedded in the top of the cement near the surface to serve as a permanent magnetic monument of the borehole, if a steel surface casing is not present. Where state law or regulation requires removal of surface casing and placement of a steel plate bearing identification of the well, such practice shall be a suitable permanent magnetic monument of the borehole.
(c) Plugging oil and gas wells using the vent pipe method. The following procedures shall be utilized when using the vent pipe method for plugging oil and gas wells:
(1) A 4 1/2inch or larger vent pipe shall be run into the wellbore to a depth of 200 feet below the lowest minable coalbed and swedged to a smaller diameter pipe, if desired, which will extend to a point approximately 20 feet above the bottom of the cleanedout area of the borehole or bridge plug.
(2) A cement plug shall be set in the wellbore by pumping an expanding cement slurry, Portland cement, or a Portland cement-fly ash mixture down the tubing to displace the gel so that the borehole is filled with cement. The borehole and the vent pipe shall be filled with expanding cement for a minimum of 200 feet below the base of the lowest minable coalbed. The top of the expanding cement shall extend upward to a point approximately 200 above the top of the lowest minable coal bed.
(3) All fluid shall be evacuated from the vent pipe to facilitate testing for gases. During the evacuation of fluid, the expanding cement shall not be disturbed.
(4) The top of the vent pipe shall be protected to prevent liquids or solids from entering the wellbore, but permit ready access to the full internal diameter of the vent pipe when necessary.
(d) Plugging gas wells of the McKenzie Coal Beds
(1) The petitioner shall identify the lowest and highest coal seam exposed in each well. All exposed coal seams shall be plugged using methods that meet or exceed the procedures in paragraphs (a), (b) or (c) outlined above without regard to present or future mineability of the exposed seam.
(2) The petitioner shall give special attention to assuring that the coal seams immediately above and below the Gholson Seam being worked at the Boone No. 1 Mine are plugged in accordance with this modification and shall confirm the accuracy and completeness of existing records for each gas well as a part of the well plugging design utilized.
(e) The certification required in this item I. shall reference the Docket Number of this Proposed Decision and Order (PDO, Docket No. M96074C) and include a detailed report of the specific methods used in plugging the gas well. This plugging report shall identify the location, name and number of the well(s), the depth at which bridge plug(s) are placed, the interval of perforation of casing, the type and length of column of cements injected and all other pertinent information necessary to show the plugging method meets or ex ceeds the above provisions of paragraphs (a), (b) or (c).
II. The following procedures shall apply to mining-through a plugged oil and gas well:
(a) The operator shall notify the District Manager or designee:
(1) Prior to mining within 300 feet of the well; and,
(2) When a specific plan is developed for mining through each well.
(b) The MSHA District Manager or designee shall conduct a conference prior to mining-through the plugged well to review the specific procedures for mining-through the well as set forth in this Proposed Decision and Order. Representatives of the miners, miners on the section, and the appropriate State agency shall be informed, within a reason able time prior to the conference, and all persons who will be present during the mining through shall attend and participate. This meeting may be called by the operator.
(c) mining-through a plugged well shall be done on a shift approved by the District Manager or designee.
(d) The District Manager or designee, representatives of the miners, the miners on the section, and the appropriate State agency shall be notified by the operator in sufficient time prior to the mining through operation in order to have an opportunity to have representatives present.
(e) When using continuous mining or conventional mining methods, drivage sights shall be installed at the last open crosscut near the place to be mined to assure intersection of the well. The drivage sights shall not be more than 50 feet from the well. When using longwall mining methods, drivage sights shall be installed on 10-foot centers for a distance of 50 feet in advance of the wellbore. The drivage sights shall be installed in the head gate and tailgate.
(f) Firefighting equipment, including fire extinguishers, rock dust, and sufficient fire hose to reach the working face area shall be available. The fire hose shall be located near the working face. When the longwall mining method is implemented, the fire hose shall be extended to the face area of the mine-through . All fire hoses shall be ready for operation during the mining-through .
(g) Sufficient supplies of roof support and ventilation materials shall be available and located not more than two crosscuts outby the mining-through location on intake air. In addition, an emergency plug and/or plugs, shall be available within the immediate area of the mine-through.
(h) During the mine-through operation, the quantity of air required by the ventilation plan, but not less than 9,000 cubic feet per minute (cfm) shall reach each working face where coal is being cut, mined or loaded by continuous mining or conventional mining methods being employed during a mining-through of a plugged well. The quantity of air required by the ventilation plan, but not less than 30,000 cfm, shall reach the working face of the longwall during the mine-through operation.
(i) Equipment shall be checked for permissibility and serviced on the maintenance shift prior to mining-through the well and the water line maintained up to the tail piece with a sufficient amount of fire hose to reach the farthest point of penetration on the section.
(j) The methane monitor(s) on the continuous mining machine, cutting machine and loading machine or longwall shall be calibrated on the maintenance shift prior to mining-through the well.
(k) When mining is in progress, tests for methane shall be made with a handheld methane detector at least every 10 minutes from the time that mining is within 30 feet of the well until the well is intersected and immediately prior to mining-through . During the actual cutting through process, no individual shall be allowed on the return side until mining-through has been completed and the area has been examined and declared safe.
(l) When using continuous or conventional mining methods, the working place shall be free of accumulations of coal dust and coal spillages, and rock dusting shall be conducted and placed on the roof, rib, and floor to within 20 feet of the face when mining through the well. On longwall sections, rock dusting shall be conducted and placed on the roof, rib and floor up to both the headgate and tailgate gob.
(m) When the wellbore is intersected, all equipment shall be deenergized and the place thoroughly examined and determined safe before mining is resumed. Any well casing shall be removed and no open flame shall be permitted in the area until adequate ventilation has been established around the wellbore.
(n) After a well has been intersected and the working place determined safe, mining shall continue inby the well a sufficient distance to permit adequate ventilation around the area of the wellbore.
(o) No person shall be permitted in the area of the well mining-through operation except those actually engaged in the operation, company personnel, representatives of the miners, personnel from MSHA, and personnel from the appropriate State agency.
(p) The mining-through operation shall be under the direct supervision of a certified individual. Instructions concerning the mining-through operation shall be issued only by the certified individual in charge.
(q) MSHA personnel may interrupt or halt the mining-through operation when it is necessary for the safety of the miners.
(r) A copy of this Proposed Decision and Order shall be maintained at the mine office and be available to the Secretary's representatives, miners' rep resentatives, and miners.
III. Within 60 days after this Proposed Decision and Order becomes final, the Petitioner shall submit proposed revisions for their approved 30 CFR Part 48 training plan to the Coal Mine Safety and Health District Manager. These proposed revisions shall include the initial and refresher training regarding compliance with the terms and conditions stated in the Proposed Decision and Order.
Any party to this action desiring a hearing on this matter must file in accordance with 30 CFR 44.14, within 30 days. The request for hearing must be filed with the Administrator for Coal Mine Safety and Health, 4015 Wilson Boulevard, Arlington, Virginia 22203.
If a hearing is requested, the request shall contain a concise summary of position on the issues of fact or law desired to be raised by the party requesting the hearing, including specific objections to the proposed decision.
A party other than Petitioner who has requested a hearing shall also comment upon all issues of fact or law presented in the petition, and any party to this action requesting a hearing may indicate a desired hearing site. If no request for a hearing is filed within 30 days after service thereof, the Decision and Order will become final and must be posted by the operator on the mine bulletin board at the mine.
GRANTED, for plugging of gas wells and the mining through of plugged gas wells at the Boone No. 1 Mine, conditioned upon compliance with the following terms and conditions:
I. Boone Resources, Inc. shall provide to the MSHA District Manager, at least 30 days prior to any mining within 300 feet of a gas well in preparation of mining through of any gas well, written certification that the gas well was plugged using methods that meet or exceed the technique and procedures set out in paragraphs (a), (b) or (c) below:
a) Cleaning out and preparing oil and gas wells. Prior to plugging an oil or gas well, the following procedure shall be followed:
(1) A diligent effort shall be made to clean the borehole to the original total depth. If this depth cannot be reached, the borehole shall be cleaned out to a depth which would permit the placement of at least 200 feet of expanding cement below the base of the lowest minable coalbed.
(2) When cleaning the borehole, a diligent effort shall be made to remove all the casing in the borehole except surface casing. If it is not possible to remove all casing, the casing which remains shall be perforated, or ripped, at intervals spaced close enough to permit expanding cement slurry to infiltrate the annulus between the casing and the borehole wall for a distance of at least 200 feet below the base of the lowest minable coalbed.
(3) If the cleanedout borehole produces gas, a mechanical bridge plug shall be placed in the borehole in a competent stratum at least 200 feet below the base of the lowest minable coalbed, but above the top of the uppermost hydrocarbonproducing stratum. If it is not possible to set a mechanical bridge plug a substantial brush plug may be used in place of the mechanical bridge plug.
(4) A suite of logs that is suitable for deter mining the top and bottom of the lowest min able coalbed and potential hydrocarbon-producing strata shall be made available.
(5) If the uppermost hydrocarbon-producing stratum is within 200 feet of the base of the lowest minable coalbed, properly placed mechanical bridge plugs or a suitable brush plug as described in subparagraph (a)(3), shall be used to isolate the hydrocarbon-producing stratum from the expanding cement plug. Nevertheless, a minimum of 200 feet of expanding cement shall be placed below the lowest minable coalbed.
(6) The wellbore shall be completely filled and circulated with a gel that inhibits any flow of gas, supports the walls of the borehole, and densifies the expanding cement. This gel shall be pumped through openend tubing run to a point approximately 20 feet above the bottom of the cleanedout area of the borehole or bridge plug.
(b) Plugging oil and gas wells to the surface. The following procedures shall be utilized when plugging oil and gas wells to the surface:
(1) A cement plug shall be set in the wellbore by pumping an expanding cement slurry down the tubing to displace the gel and fill the bore hole to the surface. (As an alternative, the cement slurry may be pumped down the tubing so that the borehole is filled with, Portland cement, or a Portland cement-fly ash mixture, from a point approximately 200 feet above the top of the lowest minable coalbed to the surface, with a expanding cement plug extending from at least 200 feet below the lowest minable coalbed to the bottom of the Portland cement. There shall be at least 200 feet of expanding cement below the base of the lowest minable coalbed.
(2) A surface casing or a small quantity of steel turnings, or other small magnetic particles, shall be embedded in the top of the cement near the surface to serve as a permanent magnetic monument of the borehole, if a steel surface casing is not present. Where state law or regulation requires removal of surface casing and placement of a steel plate bearing identification of the well, such practice shall be a suitable permanent magnetic monument of the borehole.
(c) Plugging oil and gas wells using the vent pipe method. The following procedures shall be utilized when using the vent pipe method for plugging oil and gas wells:
(1) A 4 1/2inch or larger vent pipe shall be run into the wellbore to a depth of 200 feet below the lowest minable coalbed and swedged to a smaller diameter pipe, if desired, which will extend to a point approximately 20 feet above the bottom of the cleanedout area of the borehole or bridge plug.
(2) A cement plug shall be set in the wellbore by pumping an expanding cement slurry, Portland cement, or a Portland cement-fly ash mixture down the tubing to displace the gel so that the borehole is filled with cement. The borehole and the vent pipe shall be filled with expanding cement for a minimum of 200 feet below the base of the lowest minable coalbed. The top of the expanding cement shall extend upward to a point approximately 200 above the top of the lowest minable coal bed.
(3) All fluid shall be evacuated from the vent pipe to facilitate testing for gases. During the evacuation of fluid, the expanding cement shall not be disturbed.
(4) The top of the vent pipe shall be protected to prevent liquids or solids from entering the wellbore, but permit ready access to the full internal diameter of the vent pipe when necessary.
(d) Plugging gas wells of the McKenzie Coal Beds
(1) The petitioner shall identify the lowest and highest coal seam exposed in each well. All exposed coal seams shall be plugged using methods that meet or exceed the procedures in paragraphs (a), (b) or (c) outlined above without regard to present or future mineability of the exposed seam.
(2) The petitioner shall give special attention to assuring that the coal seams immediately above and below the Gholson Seam being worked at the Boone No. 1 Mine are plugged in accordance with this modification and shall confirm the accuracy and completeness of existing records for each gas well as a part of the well plugging design utilized.
(e) The certification required in this item I. shall reference the Docket Number of this Proposed Decision and Order (PDO, Docket No. M96074C) and include a detailed report of the specific methods used in plugging the gas well. This plugging report shall identify the location, name and number of the well(s), the depth at which bridge plug(s) are placed, the interval of perforation of casing, the type and length of column of cements injected and all other pertinent information necessary to show the plugging method meets or ex ceeds the above provisions of paragraphs (a), (b) or (c).
II. The following procedures shall apply to mining-through a plugged oil and gas well:
(a) The operator shall notify the District Manager or designee:
(1) Prior to mining within 300 feet of the well; and,
(2) When a specific plan is developed for mining through each well.
(b) The MSHA District Manager or designee shall conduct a conference prior to mining-through the plugged well to review the specific procedures for mining-through the well as set forth in this Proposed Decision and Order. Representatives of the miners, miners on the section, and the appropriate State agency shall be informed, within a reason able time prior to the conference, and all persons who will be present during the mining through shall attend and participate. This meeting may be called by the operator.
(c) mining-through a plugged well shall be done on a shift approved by the District Manager or designee.
(d) The District Manager or designee, representatives of the miners, the miners on the section, and the appropriate State agency shall be notified by the operator in sufficient time prior to the mining through operation in order to have an opportunity to have representatives present.
(e) When using continuous mining or conventional mining methods, drivage sights shall be installed at the last open crosscut near the place to be mined to assure intersection of the well. The drivage sights shall not be more than 50 feet from the well. When using longwall mining methods, drivage sights shall be installed on 10-foot centers for a distance of 50 feet in advance of the wellbore. The drivage sights shall be installed in the head gate and tailgate.
(f) Firefighting equipment, including fire extinguishers, rock dust, and sufficient fire hose to reach the working face area shall be available. The fire hose shall be located near the working face. When the longwall mining method is implemented, the fire hose shall be extended to the face area of the mine-through . All fire hoses shall be ready for operation during the mining-through .
(g) Sufficient supplies of roof support and ventilation materials shall be available and located not more than two crosscuts outby the mining-through location on intake air. In addition, an emergency plug and/or plugs, shall be available within the immediate area of the mine-through.
(h) During the mine-through operation, the quantity of air required by the ventilation plan, but not less than 9,000 cubic feet per minute (cfm) shall reach each working face where coal is being cut, mined or loaded by continuous mining or conventional mining methods being employed during a mining-through of a plugged well. The quantity of air required by the ventilation plan, but not less than 30,000 cfm, shall reach the working face of the longwall during the mine-through operation.
(i) Equipment shall be checked for permissibility and serviced on the maintenance shift prior to mining-through the well and the water line maintained up to the tail piece with a sufficient amount of fire hose to reach the farthest point of penetration on the section.
(j) The methane monitor(s) on the continuous mining machine, cutting machine and loading machine or longwall shall be calibrated on the maintenance shift prior to mining-through the well.
(k) When mining is in progress, tests for methane shall be made with a handheld methane detector at least every 10 minutes from the time that mining is within 30 feet of the well until the well is intersected and immediately prior to mining-through . During the actual cutting through process, no individual shall be allowed on the return side until mining-through has been completed and the area has been examined and declared safe.
(l) When using continuous or conventional mining methods, the working place shall be free of accumulations of coal dust and coal spillages, and rock dusting shall be conducted and placed on the roof, rib, and floor to within 20 feet of the face when mining through the well. On longwall sections, rock dusting shall be conducted and placed on the roof, rib and floor up to both the headgate and tailgate gob.
(m) When the wellbore is intersected, all equipment shall be deenergized and the place thoroughly examined and determined safe before mining is resumed. Any well casing shall be removed and no open flame shall be permitted in the area until adequate ventilation has been established around the wellbore.
(n) After a well has been intersected and the working place determined safe, mining shall continue inby the well a sufficient distance to permit adequate ventilation around the area of the wellbore.
(o) No person shall be permitted in the area of the well mining-through operation except those actually engaged in the operation, company personnel, representatives of the miners, personnel from MSHA, and personnel from the appropriate State agency.
(p) The mining-through operation shall be under the direct supervision of a certified individual. Instructions concerning the mining-through operation shall be issued only by the certified individual in charge.
(q) MSHA personnel may interrupt or halt the mining-through operation when it is necessary for the safety of the miners.
(r) A copy of this Proposed Decision and Order shall be maintained at the mine office and be available to the Secretary's representatives, miners' rep resentatives, and miners.
III. Within 60 days after this Proposed Decision and Order becomes final, the Petitioner shall submit proposed revisions for their approved 30 CFR Part 48 training plan to the Coal Mine Safety and Health District Manager. These proposed revisions shall include the initial and refresher training regarding compliance with the terms and conditions stated in the Proposed Decision and Order.
Any party to this action desiring a hearing on this matter must file in accordance with 30 CFR 44.14, within 30 days. The request for hearing must be filed with the Administrator for Coal Mine Safety and Health, 4015 Wilson Boulevard, Arlington, Virginia 22203.
If a hearing is requested, the request shall contain a concise summary of position on the issues of fact or law desired to be raised by the party requesting the hearing, including specific objections to the proposed decision.
A party other than Petitioner who has requested a hearing shall also comment upon all issues of fact or law presented in the petition, and any party to this action requesting a hearing may indicate a desired hearing site. If no request for a hearing is filed within 30 days after service thereof, the Decision and Order will become final and must be posted by the operator on the mine bulletin board at the mine.
_________________________________
Robert A. Elam
Deputy Administrator
for Coal Mine Safety and Health
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