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z <br />III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations <br />made during the inspection. Comments also describe any enforcement actions taken during <br />the inspection and the }acts or evidence supporting the enforcement action. <br />This was a partial inspection conducted by Joe Dudash of the Colorado Division of Minerals and <br />Geology. Mark Milner represented the operator. The focus of the inspection was the methane de- <br />gas pad for wells CBM-1, CBM-2 and CBM-3 and the associated roads. <br />The light use road up to the drill pad was on private land and BLM land. The operator was <br />experiencing a lot of difficulty with wet roads. Earthmoving equipment was getting stuck in the <br />deep mud. The operator decided to remove the saturated mud down to dry subsoil or bedrock. In <br />doing this, a lot of soil was windrowed alongside the road. <br />No sediment control structures were in place to contain any erosion of the windrowed material, <br />although no such erosion was evident at the time of the inspection. Also, in the construction of <br />the light use road, the topsoil had not been segregated from the subsoil material. Therefore, NOV <br />CV-2001-007 was issued for failure to construct the light use road to control or prevent erosion <br />or siltation and for failure to segregate topsoil from other soil materials in the construction of the <br />light use road. <br />The final road configuration appeared to be stable and passable. Some culverts have been <br />installed. These culverts are all 12 inches in diameter. The operator may have to install larger <br />diameter road culverts in Coal Creek. <br />The drilling of CBM-1, 2 and 3 has been completed. The drill rig has moved offsite to do some <br />drilling at West Elk. There is one methane de-gas pump onsite, on well CBM-1. One more pump <br />may be added. <br />The pad upland diversion ditch is functional, although the east side has some low spots. The <br />water that has collected in these low spots may have saturated the slope below the diversion ditch <br />and made the east side of the drill pad very muddy. The upland diversion ditch needs to be recut <br />on the east side to eliminate the low spots. <br />The ditch that drains the east side of the pad runs perpendicular into the east side collection ditch. <br />This junction of the two ditches is silting up. The pad ditch could be recut so that it joins the east <br />side collection ditch at an angle, thereby reducing sedimentation at the juncture of the two <br />ditches. The east side collection ditch is also silting up where the slope gradient flattens out. <br />This area will need cleaning out soon. <br />The south side collection ditch is also silting up. In addition, more straw bales need to be placed <br />on the south side, and at the lowest point of the south collection ditch. <br />