Laserfiche WebLink
NOV CV-200]-007 was issued on April 20, 2001 for failure to construct the light use road to <br />control or prevent erosion or siltation and for failure to segregate topsoil from other soil <br />materials in the construction of the light use road. The three abatement steps are to install <br />appropriate erosion control by May 15, 200}, submit a minor revision by May 3, 2001 that <br />details a plan for salvaging avai}able topsoil and implement the topsoil salvaging plan by Iuly 1, <br />2001. Oxbow requested and received an extension to May 9, 200! for the submittal of the minor <br />revision. Oxbow personnel met with Division personnel at the Division's office on May d, 2001 <br />to discuss the abatement steps. Minor Revision No. 58 was submitted on May 9, 2001 as <br />satisfaction of abatement step number 2. The Division has not reviewed MR-58 yet. <br />The second enforcement action during this inspection involved the three mud pits at the drill site. <br />Because of the sloping topography, the three mud pits were not complete excavations. Each of <br />the pits has a down gradient embankment approximately ten feet high. Alt three mud pits abut <br />each other, and are in a line down the hill. All three pits were full of drilling mud. No <br />impoundment designs had been submitted to the Division for the mud pit embankments prior to <br />their construction. It should be noted that the Division approved the revision that allowed the <br />construction of the mud pits. The revision text stated the mud pits would be excavated, the <br />revision submittal map plan view shows mud pit embankments, not just excavations. However, <br />this was not caught during the review process. <br />At present, there are no signs of geotechnical instability with the mud pit embankments. <br />However, embankment failure would cause a fair amount of localized environmental damage. <br />The sediment control system for the drill pad and mud pits was in place but would not be able to <br />contain the flow from a massive spill. During drilling operations, the operator had to breech the <br />top of the lowermost mud pit embankment because the drilling mud was in danger of <br />overtopping the embankment. The small amount of channeled overflow was contained within the <br />sediment control system. <br />NOV CV-2001-008 was issued on Apri120, 2QU1 for failure to submit, for Division approval, <br />designs for the temporary impoundments that were used for the three de-gas drill hole mud pits. <br />The two abatement steps aze to properly dispose of the drilling mud by June 15, 2001 and <br />reclaim the mud pits by July 1, 2001. The operator has not performed any abatement steps for <br />this NOV as of the date of this memo. <br />The deadline for the operator to submit comments concerning these two NOVs was May 5, 2001. <br />The Division did not receive any such comments. However, the operator did request, in the MR- <br />58 submittal dated May 9, 2001, that the Division consider the information contained in the <br />minor revision submittal when you determine the proposed civil penalty. <br />Attached to this memo are the two NOV files. Included with each NOV file are the relevant <br />photographic slides and the inspection report. Tn the £ile for NOV CV-2001-007,1 have put a <br />copy of the MR-58 submittal, which the operator requested you read, The service of the <br />proposed civil penalty is due May 20, 2001. Thanks for your assistance. <br />Attachments c:\ms97\Sanborn\civiipenalty 1 <br />