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Elk Creek C-1981-022 <br />26 November 2007 <br />pg 5/5 <br />Drilling Operations (cont.): The inactive mud pit has been fenced as required. The operator has <br />also placed plastic under the drill rig to help contain any oil spills that may result from the <br />equipment. There is also a concern at this site with materials (again, non-hazardous) being <br />stored on/close to the topsoil stockpiles. Topsoil stockpiles must be protected in order to <br />conserve the resource. Finally, the driller has an approximately 100 gallon fuel tank at the site. <br />This tank was observed by Ryan Taylor (and documented in a picture) being stored on a road. <br />This is a practice that must be immediately stopped. At the time of the inspection the fuel tank <br />was on the pad and was placed on what looked like a pallet covered with plastic. This tank <br />must, in some way, be contained in the event of a leak and/or fuel spill. **See the pictures at <br />the end of this report regarding the Division's inspection. <br />Basically, the Division feels that there was a general lack of oversight and control of the drilling <br />operations by OMLLC, which lead to the problems observed on the USFS and Division inspections. <br />Stipulation 6 of the BLM Coal Exploration License states that all disturbance activities must be <br />overseen by an authorized representative of the licensee. Although OMLLC is not directly <br />performing the drilling operations, they are the ones who are ultimately responsible that all <br />provisions of the BLM Coal Exploration License and the Rules are adhered to. On their respective <br />inspections, representatives from the USFS and the Division observed several items that need to <br />be corrected. OMLLC is solely responsible for the actions of the contractors working on its <br />behalf and that any further issues at their drill sites of the nature outlined above may result in <br />enforcement actions being taken. The Division recommends that a representative of OMLLC visit <br />each active drill site on a regular basis (daily, if possible) to ensure that the terms of the BLM <br />Coal Exploration License and the Rules are adhered to. <br />Finally, the Division is requiring that OMLLC provide a report documenting the clean-up of the oil <br />spill at the drill pad for GVB-10-01 upon its completion. The report needs to include <br />photographic evidence of the clean-up as well as documentation that the contaminated soils were <br />removed from USFS lands, as required in stipulation 35 of the BLM Coal Exploration License. This <br />reporl~ should also be forwarded to the USFS. <br />