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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the <br />inspection and the facts or evidence supporting the enforcement action. <br />This was a joint inspection of the de-gas hole disturbances, including the drill hole pads <br />and associated roads, by the Colorado Division of Minerals and Geology and the Bureau <br />of Land Management. The Division conducted a partial inspection, represented by Joe <br />Dudash. Mark Milner represented the operator. The Bureau of Land Management was <br />represented by Lynn Lewis and Desty Dyer of the Montrose office. <br />De-Gas Access Roads <br />The operator has not begun erosion control measures yet on the road disturbance. When <br />the road material was side cast, there was a layer of snow on top of it. This snow has <br />mixed in with the side cast soil and is now melting, producing an unworkable material. <br />However, no erosional problems were observed. The roads themselves were dry and <br />passable. <br />Oxbow has submitted a plan for erosion control. The Division has requested more <br />information. Oxbow has proposed to BLM that certain sections of the road to the drill <br />pads be closed off to the public. Some of the road cuts may need to be sloped back for <br />greater slope stability. <br />De-Gas Drill Pads <br />The operator was just beginning to drill a fourth de-gas hole on the pad that had been <br />constructed for de-gas holes CBM-1, 2 and 3. The mud pit for this fourth hole was <br />completely excavated. The west topsoil stockpile was moved in order to put in this new <br />mud pit. The water for the fourth drill hole is being piped from the creek above. Overflow <br />from the water storage tank is flowing to the east, through a ditch and straw bales. <br />Although the water is cleaz, the straw bales should be keyed in better. <br />The operator was in the process of finishing maintenance work at the pad for CBM-1, 2, <br />3 and 4. Collection ditches were cleaned up. Two rows of straw bales, backed up by silt <br />fence, were being installed at the lowest point of the pad's drainage system. Straw bales <br />were installed in the embankment notch of the lowest of the first three mud pits. The mud <br />in the first three mud pits has not dried out yet. Only the surface of the mud has dried out. <br />The operator is still planning on leaving the mud onsite for reclamation. The operator is <br />also planning on recutting the upland diversion ditch so that it drains to the east. <br />