2001-11-30_INSPECTION - C1981022

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Elk Creek C-1981-022 26 November 2007 pg 4/5 Drilling Operations: - On the afternoon of 20 November 200 the Division received an a-mail from Ryan Taylor of the US Forest Service regarding the condition of the drill pads and the associated activities at one gob vent borehole site (GVB-10-01) and two coal exploration sites (05-24 and 06-30, under exploration license X-2006-223-03). Several concerns were raised, including the storage of equipment and materials on the pads, oil spills/stains, fencing of mud pits, barrels and containers on the pad berms, trash problems and basically poor housekeeping and general disorder. Based on this complaint, the Division conducted a site visit. - Pad GVB-10-01 -This site was actively being drilled (the drilling had been started recently as evidenced by the empty mud pit). On the site were several trailers, the drill rig and at least taro compressors. The site was, as Ryan had stated, generally cluttered and in disarray. There was pipe and other material (including barrels of grease and drilling fluid) stored all around the site. There were two areas on the pad and surrounding that were of major concern to the Division. First, there was an oil spill in the mud pit. The oil was spilled down the edge of the pit and was pooled at the bottom of the pit. The driller indicated that they hard changed the oil in a piece of equipment the previous week and, when they returned from the Thanksgiving holiday, the oil was in the pit. No one knows for sure how this happened but it was there, Based on stipulation 35 of the BLM Coal Exploration License, it is the responsibility of the operator to immediately contain and clean any and all spills of fuel, oil or any other hazardous waste immediately as per the SPCC. Additionally, the stipulation requires that the contaminated soil be removed from USFS lands. At the time of the inspection OMLLC was mobilizing a backhoe to the site to clean the spill. OMLLC will be required to provide written and photographic documentation to both the USFS and the Division upon completion of the remediation as well as documentation that the contaminated soil was hauled off site. The second problem was the storage of some material on and very close to the stockpiled topsoil. This material was not hazardous in nature (mostly pipe) but the Rules clf~arly state that the topsoil resource must be protected. The use of the topsoil stockpiles for storage is strictly prohibited. **See the pictures at the end of this report regarding the Division's inspection. - Exploration Hole 06-30 -This site was also in a great deal of disarray in the pictures the Division received from USFS. The operator had moved off of this site at the time of the inspection and the site was cleaned up. Similar problems existed at this site (as with GVB- 10-01), as detailed by Ryan Taylor in his pictures and a-mail. These problems include minor oil spills/staining, barrels on the pad berm and general clutter of the site. Additionally, there was a concern that the mud pit, now inactive, had not been fenced as required by stipulation 31 of the BLM Coal Exploration License. As stated above, at the time of the Division's inspection on the morning of 2~ November 200, the site had been cleaned up, including the oil spills/stains, and the mud pit had been fenced, as required. **See the pictures at the end of this report regarding the Division's inspection. - Exploration Hole 05-24 -This site was being actively drilled at the time of the inspection on the morning of 2~ November 200. Again, the issues raised by Ryan Taylor had, to some degree, been taken care of at this site. The same problems existed at this site, including tr<3sh problems, oil spills/staining and general clutter. The operator has cleaned the site but there is still the general clutter and unorganized appearance to the site. There are two mud pits on the site lone from a failed hole that has been sealed).