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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 facts or evidence supporting the enforcement action. <br />There are four topsoil stockpiles associated with the drill pad disturbance. Only one stockpile has <br />a topsoil sign, although the operator had the other signs ready to install. One of the topsoil <br />stockpiles is at the outer edge of the pad and is right next to other soil material. This stockpile <br />should be protected better. <br />There are three mud pits down gradient of the drill pad, all within the sediment collection <br />system. Rather than being total excavations, the pits have large down gradient embankments that <br />were formed when the pits were scooped out. The lowest pit embankment is almost 10 feet high <br />at the down gradient side. All three pits are filled with drilling mud. The lowest pit had to be <br />expanded to accommodate a larger than anticipated volume of material. In addition, the <br />embankment of the lowest pit was breeched to allow some drilling mud to overflow the pit. The <br />overflow was caught by the south collection ditch and straw bales. These embankments do not <br />have impoundment designs. Therefore, NOV CV-2001-008 was issued for failure to submit, for <br />Division approval, designs for the temporary impoundments before the impoundments were <br />built. <br />The operator has a considerable amount of maintenance to do. This work should be done soon. <br />What is learned from this first drill pad conswction should be applied to future drill pad <br />construction. <br />c: \m s 97\s a n b o m \i n s p040 I <br />