2014-12-15_INSPECTION - C1981022

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The Team notes several instances where the location of straw wattle use is appropriate; however, many locations that were chosen for this type of BMP are either implemented incorrectly or should be used in conjunction with some other BMP (See pictures 1, 2, and 3). Furthermore, the Team notes that certain well pad locations have straw wattles that are not functioning as designed and need replacement. Topsoil (Rule 4.06) The Team evaluated topsoil salvage and protection measures at GVB locations to determine compliance with Rule 4.06 and applicable permit requirements. Additionally, Section 2.05 -38 of the approved permits, states in part, where soil salvage is operationally feasible, soil salvage and handling will involve the following general activities in compliance with applicable provisions of Rule 4.06: Establish temporary drainage and sediment control to control runoff and sediment during soil removal operations. This may involve the use of ditches, berms, silt fences, straw bales, or other temporary control measures. Conduct clearing operations to remove any large trees or shrubs ( >4 -inch diameter) prior to soil removal. These materials are placed in slash piles on the perimeter of the disturbance areas that either remain as small mammal habitat or are disposed of. Smaller vegetation is removed during soil salvage and incorporated into the soil material as mulch and to maintain plant propagules. Soil stockpiles are located away from active operations to the extent possible and are located and configured to minimize potential for loss, erosion, or contamination of the stockpiled soil resource. Soil stockpile areas which will be inactive for six months or more are seeded with a quick - growing cover crop to stabilize the soil surface and minimize erosion and soil loss. As a result, the Team notes that Oxbow's effort to comply with this rule is not considered adequate at most locations. Specifically, the Team found that there was either a lack of BMPs used, there are no BMPs present, the topsoil has been salvaged incorrectly (did not segregate trees >4" in diameter prior to soil removal) or there is a combination of each as it relates to topsoil protection from wind and water erosion. The following GVB pads are not in compliance with the approved permit or rule 4.06: GVB -LW -1908- Topsoil pile has no protection from wind and water erosion (picture 4). Topsoil pile has not been salvaged according to the approved permit (picture 5) 2. GVB -LW -1809- Topsoil pile has not been salvaged according to the approved permit (picture 6) M