January 2, 2006
Project Team Leader
Redbird Ranger District
91 Peabody Road
Big Creek, Kentucky 40914
Re: B and B Resources, Inc.
Tollgate Wells #96-99
Dear Mr. Huebner:
These comments are submitted in response to the solicitation of public comment on the proposal to approve construction and drilling of 4 oil or gas wells on tract R-975 that B&B Resources, Inc. has leased on the Redbird Ranger District.
I have reviewed the scoping form and in response to your request for comments, offer the following:
1. All disturbed areas should be immediately mulched with straw or other materials to minimize erosion, and the areas at the perimeter of the well pad should be mulched as well as seeded immediately after well drilling.
2. Specific sediment and erosion control measures should be required in advance of any site disturbance, including:
a. Placement of hay bales or fabric filter fences below the disturbed areas prior to any new road construction and drill pad construction.
b. Control measures whenever the road crosses a stream channel or drainage channel and a filter strip cannot be maintained.
c. Sediment control measures, including straw dikes and fabric filter fences, for all other areas disturbed for the exploration and production activity, including drill pad and support facility areas.
d. All drilling and storage areas are bermed in advance of drilling in order to assure that any produced oil, brine or other fluids will be controlled.
3. The revegetation plan should require concurrent and immediate stabilization of the surface areas that are disturbed. The essence of controlling sediment transport from disturbed areas is to provide immediate mulching or other interim cover, as well as check dams, filter fences, or straw bales, to control loss of topsoil and sedimentation of receiving streams.
The mixture of species in the revegetation plan should be those that are most compatible with native vegetation in the area and are suitable for wildlife forage. Damage to any forest cover should be offset through replanting of trees.
4. Field surveys for archeological resources should be conducted in advance of any site disturbance. This much is mandated by the National Historic Preservation Act.
5. A survey of the proposed site and associated disturbances for significant terrestrial and aquatic species should be conducted by qualified personnel, with appropriate mitigation for any potentially adverse impacts;
6. All drilling rigs should be properly fitted with blow-out preventers, and the fittings checked daily, in order to prevent a recurrence of the Teges Creek spill.
7. Construction of drilling fluid storage or disposal pits must conform to the requirements of the state Division of Water regulations, including use of a synthetic liner.
8. Condensate release to the ground should be prohibited.
9. A plan for management of all fluids should be provided, to assure that any fluids used for well completion and stimulation, and any produced fluids, are properly managed to prevent releases to the environment.
Thank you in advance for your consideration of these comments.