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HomeMy WebLinkAbout15 SPCCr SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN O\OLSSON ASSOCIATES Colorado Operations 792 Buckhorn Dr. Rifle, CO 81650 Ursa m;P.M Site Specific SPCC/Containment Plan BMC A Pad SPCC Plan Garfield County, Colorado April 2017 Revision #: 0 Ursa Operating Company LLC Site Specific SPCC/Containment Plan Contents Introduction 3 Facility Purpose 3 Directions to the Facility 3 Tables 4 Table 1. Facility Detail Summary 4 Table 2. Tank Summary Details 7 Table 3. Secondary Containment Summary 9 Table 4. Secondary Containment Calculations 10 Table 5. Site Deficiencies 12 Table 6. Proximity to Navigable Waters 12 Table 7. Site Specific Plan Amendments 13 SPCC/Containment Site Detail Map 14 i Introduction This site specific SPCC/Containment Plan (Plan) provides the pertinent information with regards to the environmental and equipment information associated with the respective facility, as required to ensure procedures and protocol implemented by Ursa to meet all applicable federal regulations included in Spill Prevention Control and Countermeasure (SPCC) as described in CFR 40 §112. This site specific plan also contains the relevant information required to meet all state and local containment -related requirements. The protocol and procedures as provided in Ursa's Field Wide SPCC/Containment Plan will be applied to the respective facility. Facility Purpose The BMC A Pad is a new facility which facilitates the extraction of natural gas for use in the surrounding area via pipeline infrastructure. Produced water and condensate are considered by-products of the natural gas extraction process and are stored at the facility until their respective final use is determined Produced water may be recycled or treated at a water treatment facility, while condensate can be utilized as an additive to fuel refining processes. A facility detail summary is provided in Table 1. It should be noted that the well pad currently has working wellheads, flow lines, separators, condensate tanks, and produced water tanks which are subject to the SPCC regulations. Please see the Tables and Map included in the following portion of this Plan for additional information pertaining to the facility. In the event of a spill please contact the Incident Commander or Alternate Incident Commander. If there is a serious threat to life please call 911. Directions to the Facility From the town of Parachute, travel south towards Battlement Mesa (CR 215). Continue onto CR 300. There will be a slight left onto N. Battlement Parkway, travel 1.5 miles and turn right onto W Battlement Parkway. Turn right onto River Bluff Road and travel approx. 1 mile south to pad access road. 3 Tables Table 1. Facility Detail Summary LOCATION OF AND ACCESS TO FACILITY Facility Name: BMC A Pad Legal description: SESW, 13, T7S, R95W, 6th PM County, State: Garfield County, Colorado Latitude and Longitude: 39.433590, -108.049106 Land Ownership (e.g. Federal (BLM, BIA) or private) Private Land Is the facility secured by a gate and lock? No Type of facility (e.g. onshore oil and gas production facility, storage facility): Onshore oil and gas production facility Adjacent land is used for: Commercial, residential, and oil and gas production, public, recreational Describe the terrain surrounding the facility: Sage, grasslands What is the direction of surface flow of the facility? South Are there surface water features, or drainages visible within 500 feet? Yes —Colorado River within 700+ ft.. Distance to the nearest water well, type of well, status, and receipt #: 1200 feet to the southeast, domestic, active, 5517 Is there H2S Gas known at this facility? No INMENT OVERVIEW (see the Tables Section for specifics) How many containment areas are at this facility? One Are there any catch basins being utilized for secondary containment at this facility? No Is the facility within a COGCC 3 17B, or high density area? LUMA If the facility is within a 317B internal or intermediate zone, or high density area, does the containment meet 150% of the largest tanks volume and limit the number of tanks to two condensate tanks per containment? Not applicable Is there a stocked spill kit onsite? No TANKS, FLOWLINES, AND EQUIPMENT Total Oil Storage of Facility (bbl.) Above ground: 12 Below ground: 0 Are the tanks labeled in accordance with regulatory requirements pertinent to SPCC regulations? yes Not labeled at time of first inspection Are the tanks equipped with equalization lines? Yes Do load lines extend beyond the containment? No Are tanks equipped with ladders? Yes Are there any buried vessels No What are the flow lines constructed of? Steel Are flow lines above or below ground? Below ground How is oil transferred from the facility? By Truck Separators onsite? Properly labeled? 6 houses, 24 separators. Yes Wellheads onsite? Properly labeled? Yes, yes. 55 gallon drum storage? No Misc. chemical storage Corrosion inhibitor is stored onsite in the fenced area associated with the wellheads CONTAINMENT DETAILS Containment ID, as specified on site detail map Production Secondary Containment Containment # 1 Production Facility Shape (e.g. rectangle, oval, or other shape) Ellipse Length (feet) 73.3 Width (feet) 43 Height (inches) Corrugated metal/poly liner containment height: 32 inches What is the containment constructed of? Corrugated metal Is the containment lined? Yes — poly liner Is there a rock substrate within the containment? No Containment # 2 Injection Facility Shape (e.g. rectangle, oval, or other shape) Ellipse Length (feet) 73.3 Width (feet) 43 Height (inches) Corrugated metal/poly liner containment height: 32 inches What is the containment constructed of? Corrugated metal Is the containment lined? Yes — poly liner Is there a rock substrate within the containment? No Table 2. Tank Summary Details / Injection Containment Container Fluid Materials of Construction Diameter and Height (ft.) Volume (bbl.) Secondary Containment Comments W1 Produced Water Coated Steel 15.6', 9' 300 Secondary Containment Injection Tank W2 Produced Water Coated Steel 15.6', 9' 300 Secondary Containment Injection Tank W3 Produced Water Coated Steel 15.6', 9' 300 Secondary Containment Injection Tank W4 Produced Water Coated Steel 15.6', 9' 300 Secondary Containment Injection Tank W5 Produced Water Coated Steel 15.6', 9' 300 Secondary Containment Injection Tank W6 Produced Water Coated Steel 15.6', 9' 300 Secondary Containment Injection Tank Catch Trap Tank' Produced water/condensate Coated Steel 2' 4' 2.3 Secondary Containment Propped up on legs — no displacement volume considerations. 1 The catch trap tank is utilized to capture liquids from the condensate and produced water tanks within the flare flow line infrastructure prior to the associated gas traveling to the flare for emissions control. 7 Table 2 (a) Tank Summary Details / Production Containment Container Fluid Materials of Construction Diameter and Height (ft.) Volume (bbl.) Secondary1 Containment Comments W1 Produced Water Coated Steel 15.6', 9' 300 Secondary Containment Production Tank W2 Produced Water Coated Steel 15.6', 9' 300 Secondary Containment Production Tank W3 Produced Water Coated Steel 15.6', 9' 300 Secondary Containment Production Tank W4 Produced Water Coated Steel 15.6', 9' 300 Secondary Containment Production Tank 01 Condensate Tank Coated Steel 15.6', 9' 300 Secondary Containment Production Tank 02 Condensate Tank Coated Steel 15.6', 9' 300 Secondary Containment Production Tank Catch Trap Tank2 Produced water/condensate Coated Steel 2' 4' 2.3 Secondary Containment Propped up on legs — no displacement volume considerations. 2 The catch trap tank is utilized to capture liquids from the condensate and produced water tanks within the flare flow line infrastructure prior to the associated gas traveling to the flare for emissions control. 8 Non -oil storage - Not subject to SPCC regulations. Storage Volume (bbl.) Corrosion Inhibitor Tank Corrosion Inhibitor Poly NA 130 gallons Tank comes equipped with appropriate secondary containment Marked on site map, found with wells. Table 3. Secondary Containment Summary Secondary Containment 1 Storage Volume (bbl.) Comments Secondary Containment - Corrugated Metal Containment 19 The produced water, condensate tanks contained within this containment. 9 Table 4. Containment Calculations / Production Containment DISPLACEMENT VOLUME: Vessel No. Diameter (ft.) Height (ft.) = Berm Height Cubic. Ft. WI 15.6 2.66 NA W2 15.6 2.66 508 W3 15.6 2.66 508 W4 15.6 2.66 508 W5 15.6 2.66 508 W6 15.6 2.66 508 0 Displacement Volume (Total volume taken up by vessels other than the largest vessel) (cubic feet) 2,540 1 SECONDARY CONTAINMENT VOLUME: Length (ft73.3 Width (ft.) Height t Unit Containment Dimensions 43.0 2.66 rl r2 pi 36.7 21.5 3.14 j Containment Surface Area (square feet) 2,474 Containment Volume (cubic feet) 6,581 Displacement Volume (cubic feet) 2,540 Containment Volume (cubic feet) - the Displacement Volume (cubic feet) 4,041 Largest Tank in Containment (barrels) 300 Largest Tank in Containment (gallons) 12,600 Largest Tank in Containment (cubic feet) 1,684 Precipitation of 24-hour, 25 -year event (inches) 2.10 Precipitation of 24-hour, 25 -year event (feet) 0.18 Precipitation of 24-hour, 25 -year event (cubic feet) 432.99 Containment Volume Required for Tank contents, and precipitation event (cubic feet) 2,117.48 Percentage of largest tank in the containment 239.92 Percentage of largest tank in the containment and precipitation 190.86 Is the Containment Sufficient? Yes 10 Table 4(a) Containment Calculations / Injection DISPLACEMENT VOLUME: I Vessel No. Diameter (ft.) Height (ft.) = Berm Height Cubic. Ft. W1 15.6 2.66 NA W2 15.6 2.66 508 W3 15.6 2.66 508 W4 15.6 2.66 508 01 15.6 2.66 508 02 15.6 2.66 508 0 Displacement Volume (Total volume taken up by vessels other than the largest vessel) (cubic feet) 2,540 SECONDARY CONTAINMENT VOLUME: Length Width (ft.) Height Unit Containment Dimensions 73.3 43.0 2.66 rl r2 pi 36.7 21.5 3.14 I Containment Surface Area (square feet) 2,474 Containment Volume (cubic feet) 6,581 Displacement Volume (cubic feet) 2,540 Containment Volume (cubic feet) - the Displacement Volume (cubic feet) 4,041 Largest Tank in Containment (barrels) 300 Largest Tank in Containment (gallons) 12,600 Largest Tank in Containment (cubic feet) 1,684 Precipitation of 24-hour, 25 -year event (inches) 2.10 Precipitation of 24-hour, 25 -year event (feet) 0.18 Precipitation of 24-hour, 25 -year event (cubic feet) 432.99 Containment Volume Required for Tank contents, and precipitation event (cubic feet) 2,117.48 Percentage of largest tank in the containment 239.92 Percentage of largest tank in the containment and precipitation 190.86 Is the Containment Sufficient? Yes 11 Table 5. Sitc Deficiencies Deficiency Correction Completion Date Table 6. Proximity to Navigable Waters Water ID Classification Distance From Facility (ft.) Direction from Facility Comments • Colorado River Perennial waters 700+ feet South Pad location out of 100 yr. flood plain zone and 317b zones 12 Table 7. Site Specific Plan Amendments Date Technical/Non- technical Section Affected Reason for Amendment 13 SPCC/Containment Site Detail Map a Proposed eep"'ter❑ Naos ie t ares a au,dd} El MC A Ps 2.74 ILC Detre- sue 91 at - ,17 wrI.40 at — regi or C24 r4,1 Ur. IMARMI1411 smannow Motor uC 11M -111041 red Pal Idarossoso doe.. xwar. Proposed. ar SrMc Sar In Fiat 1•- W Sins Calor, _ 171/71-1161 popes -MEL IMIZERMIL Wilms 1.1-0kL osis ItidP Min 414 143 Smell 11 Me b?Ursa Fenn 2A-Albehment J 1MV AP d FdlilyI$e' Draft IseemaTiorlIpTioalk.IrwMVOW fwtlwi Sklreei*Muds 9511414 14 Colorado Operations 792 Buckhorn Dr. Rifle, CO 81650 l ra COPS Asset -Wide Spill Prevention, Control, and Countermeasure (SPCC) and Containment Plan Colorado Operations Garfield County, Colorado July 2013 Rev #: 8 (April 2015) Colorado Operations 792 Bockhorn Dr. Rifle, CO 81650 Ursa OPERATUG COMPANY Asset -Wide Spill Prevention, Control, and Countermeasure (SPCC) and Containment Plan Colorado Operations July 2013 Rev #: 8 (April 2015) SI fti4 !RONMf h fAL CONSCL:IANIS Prepared by: HRL Compliance Solutions, Inc. 2385 F'/2 Road Grand Junction, CO 81505 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Contents Introduction 1 Regulatory Cross -Reference for an Onshore Production Facility 2 Overview of Regulatory Decision Matrix 9 Flow Chart 1 - BLM/BIA/USFS: Onshore Order 3 Applicability Matrix 10 Flow Chart 2 - 40 CFR §112 — SPCC - Applicability Decision Matrix 11 Flow Chart 3 - 40 CFR §112 - Facility Response Plan Applicability Decision Matrix 12 Flow Chart 4 - Regulation Matrix for Specific Facilities for Production Facilities- 40 CFR §112 13 Flow Chart 5 - COGCC 317B Series - 317B Location 14 Flow Chart 6 - COGCC 604 Series — Designated Setback Locations 15 Flow Chart 7 - Colorado Department of Public Health and Environment Regulatory Overview 16 1.0 SPCC PLAN APPROVALS AND CERTIFICATIONS 17 1.1 Management Approval and Review 17 1.2 Professional Engineer Certification 18 1.2.1 Battlement Mesa Substantial Harm Certifications 19 1.3.2 Castle Springs/Wolf Creek Substantial Harm Certifications 12 1.2.2 North Gravel Trend/Roan Substantial Harm Certifications 13 1.3.4 Gravel Trend Substantial Harm Certifications 14 1.3 Plan Review and Amendments 15 2.0 FACILITIES, PROCEDURES, METHODS, OR EQUIPMENT NOT YET FULLY OPERATIONAL 18 3.0 SPCC PLAN POLICIES AND PROCEDURES 19 3.1 Owner Information 20 3.1.1 Facility Layout 20 3.1.2 Tanks, Piping and Equipment 20 3.1.3 Containment Structures 21 3.1.3.a Additional Regulatory Requirements: 22 3.1.4 Potential Discharge Volume and Direction of Flow 25 3.1.5 Proximity to Navigable Waters 26 3.1.6 Site Specific Facility Diagrams 26 3.1.7 SPCC Plan Development Tables 26 3.2 General Requirements 27 ii Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 3.2.1 Discovery, Response and Cleanup of Releases 27 3.2.2 Notification Contacts 27 3.2.3 Notification Forms 27 3.2.4 Response Plan 27 3.3 Routine Facility Operations, Inspections and Maintenance 28 3.3.1 Facility Operations 28 3.3.2 Facility Inspection Program 28 3.3.2.a Testing and Record Keeping Guidance 30 3.3.4 Maintenance Program 32 3.4 Response and Reporting Information 33 3.4.1 Spill Response 33 3.4.2 Spill Reporting 33 3.5 Spill Response Training 35 3.5.1 Annual Training 35 3.5.2 Discharge Prevention Briefings 35 3.5.3 Training Records 35 APPENDICES Appendix A Site Specific SPCC Plans Appendix B Appendix C Appendix D Appendix E Appendix F Oil Spill Contingency Plan and Emergency Response Plan Discharge Notification Forms SPCC Forms Summary of Operating Procedures and Flowline Maintenance Program Written Commitment of Manpower ATTACHMENTS Attachment 1 Onshore Order 3 ii Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Introduction This Asset -Wide SPCC/Containment Plan is organized to address the Ursa Onshore Production Facilities which store produced water and condensate and are subject to the EPA regulations as provided in 40 CFR 112, Subpart B. In addition to the Federal regulations provided in 40 CFR 112, this Plan specifies the regulatory requirements as outlined by the Bureau of Land Management (BLM). Please see the Regulatory Cross Reference and the Flow Charts for additional information. • Federal o 40 CFR §112, Subpart A and §112.9 — United States Environmental Protection Agency (EPA) o Onshore Order 3 — Bureau of Land Management (BLM) • State o Applicable Colorado Oil and Gas Conservation Commission (COGCC) Rules 1 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Regulatory Cross -Reference for an Onshore Production Facility Regulation r i Description 1 Section EPA — 40 CFR §112 — Onshore Production Facilities §112.3(b)(2) SPCC Plan prepared within six months after becoming operational (effective 11/10/2010) 1.3 §112.3(d)(1) Professional Engineer (PE) certification with five, or six (if applicable for produced water containers) elements 1.3 §112.5(a) Amendment of SPCC Plan 1.3 § 112.5(b) Review of Plan at least every 5 years with documentation (i.e. a log) 1.3 §112.6 Qualified Facilities: meets qualification criteria N/A § 112.7 General requirements for SPCC Plans for all facilities & all oil types 2.0 — 3.5 §112.7 Management approval of Plan 1.1 §112.7 Discussion of facilities, procedures, methods or equipment not yet fully operational with details of installation and operational start-up 2.0 § 112.7(a)(1) General requirements; discussion of facility's conformance with rule requirements 3.0 — 3.5 § 112.7(a)(2) Deviations from Plan requirements N/A § 112.7(a)(3) Facility description and diagram, type of oil and capacity of each container, transfer stations and piping, buried containers on diagram Site Specific Plan in Appendix A § 112.7(a)(3)(ii) Discharge prevention measures 3.2 — 3.3 2 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Regulation Description Section 1 EPA 40 CFR §112 — Onshore Production Facilities IL § 112.7(a)(3)(iii) Discharge drainage controls 3.2 — 3.3 § 112.7(a)(3)(iv) Countermeasures for discharge discovery, response and cleanup 3.4 and Appendix B 112.7(a)(3)(v) Methods of disposal of recovered materials in accordance with legal requirements 3.4 §112.7(a)(3)(vi) Contact list and phone numbers for facility Incident Commander, National Response Center, cleanup contractors, all Federal, State, and local agencies who must be contacted in case of a discharge 3.4 and 3.5 §112.7(a)(4) Spill reporting information 3.4 §112.7(a)(5) Discharge procedures Appendix A §112.7(b) Failure prediction (sources, quantities, rates, and directions) 3.1.4 and Appendix A Tables and Diagrams § 112.7(c) Secondary containment for all areas from which a discharge of oil could occur (i.e. mobile refuelers, loading/unloading areas, transformers, oil filled operational equipment, etc.) other than bulk containers 3.1.3 and Appendix A Tables Diagrams § 112.7(d) Explanation of impracticability of secondary containment N/A § 112.7(a)(3)(ii) Discharge prevention measures 3.2 — 3.3 § 112.7(a)(3)(iii) Discharge drainage controls 3.2 — 3.3 §112.7(a)(3)(iv) Countermeasures for discharge discovery, response and cleanup 3.4 and Appendix B 3 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Regulation Description Section EPA — 40 CFR §112 — Onshore Production Facilities § 112.7(a)(3)(v) Methods of disposal of recovered materials in accordance with legal requirements 3.4 § 112.7(a)(3)(ii) Discharge prevention measures 3.3 and Appendix E § 112.7(a)(3)(iii) Discharge drainage controls 3.3, Appendix A Tables § 112.7(a)(3)(iv) Countermeasures for discharge discovery, response and cleanup 3.4 and Appendix B § 112.7(a)(3)(v) Methods of disposal of recovered materials in accordance with legal requirements 3.4 § 112.7(a)(3)(vi) Contact list and phone numbers for facility response coordinator, National Response Center, cleanup contractors, all Federal, State, and local agencies who must be contacted in case of a discharge 3.4 and Appendix B § 112.7(a)(4) Spill reporting information 3.4 and Appendix B § 112.7(a)(5) Discharge procedures Appendix A § 112.7(b) Failure prediction (sources, quantities, rates, and directions) 3.1.4 and Appendix A Tables and Diagrams § 112.7(c) Secondary containment for all areas from which a discharge of oil could occur (i.e. mobile refuelers, loading/unloading areas, transformers, oil filled operational equipment, etc.) other than bulk containers 3.1.1, Appendix A Tables and Diagrams § 112.7(d) Explanation of impracticability of secondary containment N/A §112.7(d)(1) Oil spill contingency plan per part 109 3.1.4 and Appendix B § 112.7(d)(2) Commitment of manpower, equipment & materials to remove a discharge Appendix F § 112.7(e) Written procedures for inspections and tests 3.3 . §1127e () inspections and tests signed and kept 3 ears Records of p y 3.3.2 and Appendix D § 112.7(f)(1) Employee training 3.5 and Appendix D 4 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Regulation Description Section EPA — 40 CFR §112 — Onshore Production Facilities § 112.7(f)(2) Designated individual accountable for discharge prevention 3.1, 3.2.2, 3.4 §112.7(f)(3) Discharge prevention briefings scheduled and conducted annually 3.4 and Appendix D § 112.7(h) Loading/unloading rack (excluding offshore facilities) N/A §112.7(h)(1) Containment for contents of largest compartment Appendix A Tables § 112.7(h)(2) Warning light/sign, barrier system, wheel chocks, or break interlock system to prevent departure with connected lines Appendix E §112.7(h)(3) Inspect drains and outlets of vehicles Appendix E §112.7(i) Brittle fracture or catastrophic failure evaluation requirements NA — no field constructed tanks to be utilized §112.7(j) Conformance with State requirements 3.0, 3.2.1, and Appendix A §112.3(k)(1) Qualified Oil -Filled Operational Equipment: meets criteria N/A § 112.7(k)(2)(i) Inspection procedures or monitoring program 3.3 § 112.7(k)(2)(ii)(A) Oil spill contingency plan per part 109 Appendix B § 112.7(k)(2)(ii)(B) Written commitment of resources Appendix B and Appendix F § 112.8 Spill Prevention, Control, and Countermeasure Plan requirements for onshore facilities (excluding production facilities) N/A § 112.9 Spill Prevention, Control, and Countermeasure Plan Requirements for onshore oil production facilities (excluding drilling and workover facilities). All § 112.9(a) Meet general and specific requirements All § 112.9(b)(1) Oil production facility drainage: Restrain drainage from diked areas; remove accumulated oil 3.3 § 112.9(b)(2) Oil production facility drainage: Inspect field drainages, oil traps, sumps or skimmers for accumulations of oil, remove oil 3.3 § 112.9(c) Oil production facility bulk storage containers: 2.0 5 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Regulation Description Section EPA — 40 CFR §112 — Onshore Production Facilities § 112.9(c)(1) Containers compatible with material and conditions of storage 3.1 § 112.9(c)(2) Secondary containment for tank battery, separation and treating units with capacity of largest container & freeboard for precipitation Appendix A § 112.9(c)(2) Drainage from undiked areas with potential to discharge oil directed to catchment basin or holding pond N/A § 112.9(c)(3) Visually inspect containers, foundations and supports 3.3 § 112.9(c)(4) Engineered to prevent discharges Appendix A § 112.9(c)(5) Flow-through Process Vessel Alternative in lieu of compliance with 112.9(c)(2) and (3) N/A § 112.9(c)(6) Produced Water Containers comply with §112.9(c)(1) and (c)(4); and §112.9(c)(2) and (c)(3), 2.0 § 112.9(d) Facility transfer operations, oil production facilities 3.3 § 112.9(d)(1) Inspect aboveground valves, piping, drip pans, supports, pumping, and etc. 3.3 § 112.9(d)(2) Inspect salt water disposal facilities N/A § 112.9(d)(3) Flowlines and intra -facility gathering lines are provided with secondary containment per 112.7(c) Appendix A § 112.9(d)(3)(i) For flowlines and intra -facility gathering lines that are not provided with secondary containment, a Contingency Plan following the provisions of Part 109 is included Appendix B § 112.9(d)(3) For flowlines and intra -facility gathering lines that are not provided with secondary containment, a written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that might be harmful is provided Appendix B and Appendix F 6 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Regulation Description Section i A — 40 CFR §112 — Onshore Production Facilities § 112.9(d)(4) A written program of flowline/intra-facility gathering line maintenance has been prepared and implemented Appendix E § 112.9(d)(4)(i) Flowlines and intra -facility gathering lines and associated valves and equipment are compatible with the type of production fluids, their potential corrosivity, volume, and pressure, and other conditions expected in the operational environment 3.1 § 112.9(d)(4)(ii) Procedures to visually inspect and/or test flowlines and intra -facility gathering lines and associated appurtenances on a periodic and regular schedule for leaks, oil discharges, corrosion, or other conditions that could lead to a discharge are included. For flowlines and intra -facility gathering lines that are not provided with secondary containment in accordance with § 112.7(c), the frequency and type of testing must allow for the implementation of a contingency plan as described under Part 109 3.3 and Appendix E § 112.9(d)(4)(iii) Take corrective action or make repairs to any flowlines and intra -facility gathering lines and associated appurtenances as indicated by regularly scheduled visual inspections, tests, or evidence of a discharge. 3.3 § 112.9(d)(4)(iii) Procedures to promptly remove or initiate actions to stabilize and remediate any accumulations of oil discharges associated with flowlines, intra -facility gathering lines, and associated appurtenances 3.3 and Appendix B § 112.10 Spill Prevention, Control, and Countermeasure Plan requirements for onshore oil drilling and workover facilities. N/A §112.20(e) Completed and signed certification of substantial harm form. 1.3 § 112.11 Spill Prevention, Control, and Countermeasure Plan requirements for offshore oil drilling, production, or workover facilities. N/A 7 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Regulation Description Section COGCC Rules COGCC 317B.d Requirements for DCPS Operations at New Oil and Gas Locations in the Intermediate Buffer Zone: 3.1 and Appendix A COGCC 604. Oil and Gas Facilities Building specs for crude oil and condensate tanks, tank location/distance requirements, berm construction requirements, tank labeling requirements. 3.1 and Appendix A COGCC 605.a Crude Oil and Condensate Tanks. 3.1 and Appendix A COGCC 906 Series Rules Protocol specified for spills and releases in association with O&G operations. 3.4 and Appendix C COGCC 1101.e Pressure testing of flowlines Appendix E BLM Regulation For all oil and gas operations on Federal and Indian leases (except Osage), Onshore Order 3 specifies requirements pertaining to site security. Appendix A, Attachment 1 Onshore Order 3 8 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Overview of Regulatory Decision Matrix BLM - Onshore Order 3 EPA -40 CFR§112 Subpart A and §112.9 COGCC Series Rules CDPHE All Locations r 1 210.b.(2) Tank Battery Label Requirementsi< 210.d Tank and Container Label Requirements 210.e General Sign Requirements V l 605.a Crude Oil and Condensate Tanks 906.e Secondary Containment Requirements i y 1101.e. Pressure testing of flowlines 317B Facilities EPA - 40 CFR §112, FRP 7 C.C.R. 1101-14, (non -E&P) r 604 Series - Setback Locations. COGCC Form 2A COA's Landowner COA's 605.a.(1) Tank Standards 605.a.(2),(3),(5),(6), (7),(8),(11) Tank Placement Distances from other equipment 605.a.(4) Berm Construction 605.a.(10) Vent Lines 9 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Flow Chart 1 - BLM/BIA/USFS: Onshore Order 3 Applicability §112.7(j) Is the pad on federal land? No Does the facility or wells have access to federal minerals, OR part of a unit/ communitization that includes federal minerals? Yes Facility is not subject to Onshore Order 3 requirements No Does the facility have a salable volume of condensate or crude oil? Yes W Facility is subject to Onshore Order 3 site security measures with regards to measurement and sales of condensate and/or crude oil. Attachment A of this document. Please note that applicability to the Onshore Order 3 requirements is dynamic. For example, if a produced water tank starts holding enough condensate that it becomes a salable volume, the respective tank(s) will become subject to the regulations. Conversely, when there is no longer a salable volume of oil, the respective facility/wells would no longer be subject to the requirements. 10 The facility is not subject to 40 CFR §112. NO Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Flow Chart 2 - 40 CFR §112 — SPCC - Applicability - 40 CFR §112 Is the facility or part of the facility (e.g., complex) considered non- transportation-related? on- transportation-related? 1 YES Is the facility engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming oil? f YES Could the facility reasonably be expected to discharge oil in quantities that may be harmful into navigable waters or adjoining shorelines? 2 YES Is the total aggregate capacity of aboveground storage greater than 1,320 U.S. gallons of oil? (Do not include the capacities of: - less than 55 -gallon containers, - permanently closed containers, - motive power containers, - hot -mix asphalt and hot -mix asphalt containers, - single-family residence heating oil containers, - pesticide application equipment and related mix containers, or - containers used exclusively for treating wastewater) NO NO NO— OR Is the total aggregate capacity of completely buried storage greater than 42,000 U.S. gallons of oil? (Do not include the capacities of: - completely buried tanks and connected underground piping, ancillary equipment, and containment systems subject to all of the technical requirements of 40 CFR part 280 or 281, - nuclear power generation facility underground emergency diesel generator tanks deferred under 40 CFR part 280 and licensed by and subject to any design and quality criteria of the Nuclear Regulatory Commission, - permanently closed containers, or - containers used exclusively for treating wastewater) YE 5 The facility j2. subject to SPCC Rule Is the facility subject to SPCC requirements? Yes No If Yes, continue to the following page to assess the Facility Response Plan Applicability 11 Is the facility located at a distance1 such that a discharge from the facility would shut Yes down a public drinking water intake3? Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Flow Chart 3 - 40 CFR §112 - Facility Response Plan Applicability - 40 CFR §112 Flowchart of Criteria for Substantial Harm Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? No • Does the facility have a total oil storage capacity greater than or equal to 1 million gallons? Yes Yes Submit Response Plan Within any aboveground storage tank area, does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation? Yes 0 Is the facility located at a distance1 such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments2? No Yes No Has the facility experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last 5 years? No Submittal of Response Plan Except at RA Discretion Calculated using the appropriate formulas in 40 CFR 112 or a comparable formula. 2 For further description of fish and wildlife and sensitive environments, see Appendices I, II, and III to DOCINOAA's "Guidance for Facility and Vessel Response Plans: Fish and Wildlife and Sensitive Environments" (59 FR 14713, March 29, 1994) and the applicable Area Contingency Plan. 3 Public drinking water intakes are analogous to public water systems as described at 40 CFR 143.2(c). Is the facility subject to the Facility Response Plan Requirements? Yes No 12 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Flow Chart 4 - Regulation Matrix for Specific Facilities for Production Facilities - 40 CFR §112 11 Bulk Storage Containers §112.9(c)(2) Applies to containers in the tank battery, separation. Arid treating facility installations Loading/Unloading Rack §112.70)(1) Onshore 011 Production Facility §112.7(c) Flow -Through Process Vessels §112.9(c)(2) OR §112.7(c) and §112.9(c)(5 ) r Qualified Oil -Filled Operational Equipment §)12.7(c) OR §112.7(k) • 1 rmprncrlcc bfe} • • §112.7(d) Impracticability Determination For bulk storage containers, conduct both periodic integrity testing of the containers and periodic integrity and teak testing of the valves and piping Prepare a part 109 contingency plan Provide a written commitment of manpower, equipment, and materials T Flowlines and intra - Facility Gathering Lines §112.7(c) OR §112.9(d)(3) T Produced Water Containers §112.99(c)(2) OR §112.7(c) and §112.9(c)(6) 5 Other areas" with potential for discharge §112.7(c) only "` Examples of areas with potential for discharge may ir+ctude: piping— including flowtirxes. Christmas trees, pumpjac1s, balk storage containers (riot part of a tank battery), oil -filled operating and rnanufactunng equipment, and oil equipment associated with transfer areas 13 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Flow Chart 5 - COGCC 317B Series - 317B Location §112.7(j) New Oil and Gas Locations 317B.c. \7) Form 2A COAs Intermediate Buffer Zone (301 — 500') rNew Oil and Gas Locations Existing Oil and Gas Locations 317B.f. 317B.d. New Oil and • Gas Locations Form 2A COAs 14 605.a.4 and 906.e.1 Form 2A COAs 317B.e. Form 2A COAs Ursa Operating Company LLC Flow Chart 6 - COGCC 604 Series — Designated Setback Locations §112.7(j) Existing Location, (built prior to August 1, 2013) Are additional wells proposed for drilling? [604.b.(1) Existing oil and gas locations Yes 604.b.(2) Surface Use Agreement or Site Specific Development Plan (SSDP) 604.b.(3) Surface Development after August 1, 2013 Pursuant to a SUA or SSDP 604.b.(4) Hearing if exception for variance is not granted r The facility may be subject to setback requirements for future drilling events. y7k No 1 604.c.(1) Provisions for future encroaching development Containment /Tank Requirements for All Designated Setback Locations 604.c Mitigation Measures — (information to be incorporated into the Form 2 or Form 2A) 604.c.(2). F — Leak Detection Plan 604.c.(2). G — Berm Construction 1 604.c.(2). R — Tank Specifications Yes Yes Yes < Yes Yes Oil Production Facility SPCC/Containment Plan Is the facility classified as being within a: 604.a.(1) Exception Zone No W 604.a.(1).A Urban Mitigation Area No No W 604.a.(3) Within 1,000 feet of a High Density Building No W 604.a.(4)Designated Outside Activity Area No E-- Yes 604.a.(4)Designated Outside Activity Area No W If location does not fit into the above classifications, it is not subject to the 604 Setback Rules. Additional provisions for Exceptions Zone Locations 15 604.c.(3) Location Specific Requirements Ursa Operating Company LLC Flow Chart 7 - CDPHE Regulatory Overview §112.7(j) 7 CCR 1101-14 Underground Storage Tanks and Above Ground Storage Tanks Article 3 - ASTs 1 Article 4 — Release Identification and Reporting 3-1 AST Program Scope and Applicability ‘44.101 Article 5 — Release Response Article 6 — Enforcement Guidance Documents 3-1(a) Zoning Requirements 3-1(b) Exclusions 4-1 Suspected Releases 5-1 Response 1 Oil Production Facility SPCC/Containment Plan 3-2 AST Design, Construction Locations and Installation r 1 3-2(a) Tank Design and Materials of Construction 3-2(b) Vent Piping Y 3-2(c) Normal Venting inffts 6-1 Enforcement 4-2 Response to Suspected Release 5-2 Initial Site Risk Assessment 1 4-3 Confirmed Release 5-3 Monitoring 5-4 Program Characterization 5-6 No Further Action Request http://www.colorado.gov/cs/Satellite/CDLE-OilPublicSafety/CDLE/ 1248095303296 16 5-5 Corrective Action J Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 1.0 SPCC PLAN APPROVALS AND CERTIFICATIONS 1.1 Management Approval and Review §112.3, §112.7 Ursa Operating Company LLC is committed to the implementation of the procedures outlined in this SPCC Plan and to the prevention of any release of oil to navigable waters of the United States of America. A copy of this Plan shall be maintained at the Ursa Operating Company LLC Rifle, Colorado office and will be made available to the EPA Regional Administrator for on-site review during normal working hours. Authorized Management Representative Signature: Name: Dwayne Knudson Title: Senior Environmental Specialist — Piceance 17 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 1.2 Professional Engineer Certification §112.3 By means of this certification, I attest that: I am familiar with the requirements of the SPCC rule (40 CFR 112); - The facility has been visited and examined by myself or my agent; This Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of the SPCC rule; Procedures for required inspections and testing have been established; and, - This Plan is adequate for the facility. Signature of Professional Engineer Date State Registration No. State Note: The PE's certification does not relieve the owner/operator of the facility of the duty of fully implementing the SPCC Plan in accordance with all applicable requirements. 18 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 1.2 Professional Engineer Certification §112.3 By means of this certification, I attest that: - I am familiar with the requirements of the SPCC rule (40 CFR 112); - The facility has been visited and examined by myself or my agent; - This Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of the SPCC rule; Procedures for required inspections and testing have been established; and, This Plan is adequate for the facility. 1 -Z6 -2V(5 Signature s P .fessional Engineer Date 2.810z2 - State Registration No. State Note: The PE's certification does not relieve the owner/operator of the facility of the duty of fully implementing the SPCC Plan in accordance with all applicable requirements. Ursa Operating Company LLC Oil Production Facility SPCC Nan 1.2 Professional Engineer Certification Date of Most Recent Plan Technical Review/PE Certification: By means of this certification, I attest that: I am familiar with the requirements of the SPCC rule (40 CFR 112); The facility has been visited and examined by myself or my agent; This Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of the SPCC rule; - Procedures for required inspections and testing have been established; and, - This Plan is adequate for the facility. Signature f ' ofessional Engineer 486 u D ate State Registration No. State Note: The PE's certification does not relieve the owner/operator of the facility of the duty of fully implementing the SPCC Plan in accordance with all applicable requirements. 10 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 1.2 Professional Engineer Certification By means of this certification, I attest that: I am familiar with the requirements of the SPCC rule (40 CFR 112); - The facility has been visited and examined by myself or my agent; This Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of the SPCC rule; - Procedures for required inspections and testing have been established; and, This Plan is adequate for the facility. S gnature • f rofessional Engineer ate State Registration No. State Note: The PE's certification does not relieve the owner/operator of the facility of the duty of fully implementing the SPCC Plan in accordance with all applicable requirements. 10 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 1.2.1 Battlement Mesa Substantial Harm Certifications — Appendix C to Part 112 • Monument Ridge • Monument Ridge Watson Ranch Receiving Station • Speakman A • Watson Ranch 19 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 1.3.2 Castle Springs/Wolf Creek Substantial Harm Certifications — Appendix C to Part 112 • Castle Springs A • Castle Springs B • Castle Springs D • Castle Springs E • Castle Springs Q • Castle Springs T • Castle Springs U • Castle Springs V • Castle Springs W 12 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 1.2.2 North Gravel Trend/Roan Substantial Harm Certifications Appendix C to Part 112 • Currently there are no facilities with tanks subject to the specified regulations. 13 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 1.3.4 Gravel Trend Substantial Harm Certifications - Appendix C to Part 112 • Burkle A • Coloroso A • Dever A • Dever C • Dixon A • Dixon B • Frei A • Gentry B • Gentry C • Gentry E • Gypsum Ranch A • Gypsum Ranch B • Hangs A • Hangs B • Hunter Mesa CS • Island Park B • Left Hand A • McLin A • McLin B • McLin C • McPherson A • Norcross A • North Bank A • North Bank B • North Bank C • North Bank E • O'Toole • River Ranch A • River Ranch B • River Ranch C • Robinson A • Robison C • Snyder A • Synder C • Valley Farms B • Valley Farms C • Valley Farms D • Valley Farms E • Valley Farms F • Valley Farms G • Valley Farms H • Valley Farms I • Valley Farms J • Valley Farms L • Valley Farms • Wasatch Bench • Weinreise A 14 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 1.3 Plan Review and Amendments §112.3 and §112.5 LOG OF PLAN REVIEW AND AMENDMENTS NON TECHNICAL AMENDMENTS • Non-technical amendments are not certified by a Professional Engineer. • Examples of changes include, but are not limited to phone numbers, name changes, or any non- technical text change(s). TECHNICAL AMENDMENTS • Technical amendments are certified by a Professional Engineer. • Examples of changes include, but are not limited to, commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or addition/deletion of standard operation or maintenance procedures related to discharge prevention measures. It is the responsibility of the facility to determine, and confirm with the regulatory authority as necessary, what constitutes a technical amendment. The preamble of the rule states that an amendment is required only "when there is a change that materially affects the facility's potential to discharge oil" (67 FR 47091). • An amendment made under this section will be prepared within six (6) months of the change and implemented as soon as possible but not later than six (6) months following preparation of the amendment. • Technical Amendments affecting various pages within the plan can be P.E. certified on those pages, certifying those amendments only, and will be documented on the log form below. MANAGEMENT REVIEW 1. Management will review and amend this SPCC Plan at least each five (5) years or when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge. The review will be documented on the form below. 2. Management will review and amend this SPCC whenever there is a discharge of more than 1000 gallons of oil into or upon navigable waters in a single discharge or a discharge of more than 42 gallons of oil in each of two discharges occurring within any twelve month period. The Plan will be submitted to the Regional Administrator within 60 days. REVIEW AND AMENDMENT LOO Reidewt Arnemu Dale Sigesture (prcirv) October 20I 3 l Cc.einber 2013 Amsad Flan [ i14`wilJ Rrview 4nrcndrneni not) RrserJptioii of Afir,csed ragesor Sodium Cert.; I1ca[i& r ddili.ca of Sae Specific. •FOC Flan (Dever• and s A, 4at1b within the Gravel. Trend Fie]d) dilutivo d Sift Sp i& CC Plan, Caine Springs Compressor Station 15 .Appendix A AppGJ di x A Yes Yes Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan REVIEW AND AMENDMENT LOG Continued Review/ Amend Date Signature * (Specify) Amend Plan (will/will not) Description of Review Amendment Affected Pages or Sections PE Certification (Y /N) February 2014 _ Will Addition of Site Specific SPCC Plans, Speakman A, McLin B, McLin C, non-technical amendments Appendix A, Certification of Harm pages, Updated notification numbers, reporting table, inspection form, 3.1.3.a., Yes March 2014 l ,..'''-'4".4updates Will Addition of a Site Specific Plan — Monument Ridge, to Frei A storage volume Appendix A, Certification of Harm Pages. Yes August 2014 I Will Technical amendment (Castle Springs B and E) Non-technical text amendments/formatting for all plans within Appendix A Appendix A — All facilities Yes October 2014 �. Will Non-technical update to provide serial numbers on injection well tanks for Speakman A facility Appendix A No January 2015 I Will Inclusion of Monument Ridge/Watson Ranch Receiving Station, McLin A, and Valley Farms J — changing contact name from Rob Bleil to Dwayne Knudson Section 1.0, Section 3.1, Section 3.2, Section 3.4.1, Certification of Harm Pages, Appendix A, Appendix B, Appendix F, Attachment 1 — pg. 17 Yes *Typically signed by Manager, Professional Engineer or plan reviewer. 16 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan REVIEW AND AMENDMENT LOG Continued Review/ Amend Date t Signature * (Specify) Amend Plan (will/will not) Description of Review Amendment Affected Pages or Sections PE Certification (Y /N) February 2015 -- Will Addition of Valley Farms L Facility, amendment to McLin B Facility, non-technical amendments Appendix A, Section 1.3.4 Y April 2015 Will Technical Amendment to: Dever A, Dever C, Dixon A, Dixon B, Gentry B, Gentry C, Gentry E, Left Hand A, McLin C, McPherson A, North Bank E, O'Toole, Robinson C, VFC, VFD, VFE, VFI, and Weinreis A Appendix A Y *Typically signed by Manager, Professional Engineer or plan reviewer. 17 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 2.0 FACILITIES, PROCEDURES, METHODS, OR EQUIPMENT NOT YET FULLY OPERATIONAL §112.7 This Asset -Wide SPCC / Containment Plan is drafted in accordance with Federal, State and local regulatory requirements. 18 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 3.0 SPCC PLAN POLICIES AND PROCEDURES §112.7 This Asset -Wide SPCC / Containment Plan, hereinafter referred to as 'the plan', is a carefully conceived document prepared to address onshore production facilities in Colorado operated by Ursa Operating Company LLC (Ursa) which are subject to the federal SPCC and containment regulations. There are several additional State of Colorado SPCC -related requirements which are supplemental to the EPA oil pollution prevention regulations (40 CFR 112). The applicability of these regulations will be discussed in the site specific SPCC plans contained in Appendix A. This plan was developed to satisfy the applicable state and federal requirements. Specifically, this plan was developed to: • Communicate pollution prevention requirements to Ursa employees. • Document Ursa's SPCC and containment procedures and measures. • Enable Ursa employees to report a spill and provide all the necessary information in the event of a release. • Assist Ursa in contacting and reporting pertinent information to the appropriate agencies. • Provide site-specific information in a simple way. Based on the type of respective operating facilities, the plan addresses both the general plan regulatory requirements specified in 40 CFR 112.7 and those specific to onshore production facilities 40 CFR 112.9. To ensure coverage of applicable regulations, a Regulatory Cross Reference was provided at the beginning of this plan. It identifies salient sections of the regulation in accordance with the plan section in which it is addressed. General requirements applicable to each facility and to the overall management of SPCC -related activities are included in the main text portion of the plan. Appendix A provides site specific information for each individual facility covered by this plan. This information includes a site layout, description of equipment, volume and type of material stored, surface water flow directions, and spill prevention controls. Technical amendments, such as addition of hydrocarbon storage containers, to this plan will be issued within 6 months as mandated by 40 CFR 112.5. Such amendments will be certified by a professional engineer if the amendment is considered to be technical. In accordance with pertinent regulations, non-technical Plan amendments/reviews and revisions will also be issued on a timely basis by personnel with the appropriate level of authority. This plan conforms to the SPCC Regulations and was developed in accordance with sound engineering practices. Any deviations from regulatory requirements that were noted during the development of this plan are noted on Table 2. A complete copy of the SPCC Plan is maintained at the Rifle Field Office and at the Denver Corporate Office. 19 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 3.1 Owner Information §1 1 2.7(a)(3) Name: Ursa Operating Company LLC Address: U.S. Operations 950 17th Street, Suite 2200 Denver, CO 80202 Company Contacts: Facility Location: Regional Address: 792 Buckhorn Drive Rifle CO, 81650 Dwayne Knudson, Piceance - Senior Environmental Specialist Robert Bleil, Regulatory and Environmental Manager This Asset -Wide SPCC / Containment Plan is applicable to onshore production facilities operated by Ursa in Colorado. Site specific information is located within the Appendix A of this plan. 3.1.1 Facility Layout §112.7(a)(3) Details for each facility covered by this plan are provided in Appendix A of this plan. In general, the physical layout of an onshore production facility is associated most often with a well pad. Equipment associated with the well pad includes, but is not limited to, separators, dehydrators, wellheads, above/below ground piping, produced water tanks, condensate tanks, methanol tanks, production pits, and miscellaneous storage. The equipment on the well pad is typically organized in a manner which facilitates safe and efficient automobile navigation. The valves associated with tanks, holding either oil or other chemicals are kept in the closed and locked position to help ensure unintentional flow does not occur when the tank is not being actively used. The area around the tanks is kept free and clear of debris that could pose a safety hazard (e.g. fire, traffic). Stormwater which flows across uncontained portions of the site is not anticipated to come into contact with hydrocarbons. Visual inspections of the entire location are performed by designated personnel or third party contractors as described in Section 3.3 of this plan with regards to SPCC/containment requirements and the Stormwater Management Plan with regards to stormwater management. 3.1.2 Tanks, Piping and Equipment §112.7(a)(3) The condensate and produced water tanks (tanks) are considered bulk storage tanks/containers under the SPCC regulation. All tanks were built in accordance with API Specification 12F Shop Welded Tanks for Storage of Production Liquids design. All enclosed tanks are equipped with gas vents to relieve any pressure that might build up inside the tank, and are also equipped with vacuum protection that prevent over or under pressuring of the tanks. All tanks are equipped with hatchways for venting, gauging and/or access. All tanks should have stairways and hand railings 20 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan to facilitate worker safety when the gauging operations are underway. The tanks have been sized to provide sufficient capacity to prevent overfilling. Tanks are gauged periodically to monitor the oil level to ensure that sufficient tank capacity is available for storage of produced water or condensate. It should be noted that separator units are also considered to be bulk storage containers and are subject to sized secondary containment and periodic inspection. As described in Section 3.3, tanks are visually inspected on a regular basis for leaks, corrosion, and any other malfunctions or deterioration. The tanks are also integrity tested prior to placement at the facility. The equipment and associated hose is compatible with the fluids stored and storage conditions such as pressure and temperature. Any flowlines are to be compatible with the materials being transferred through them. Flowlines shall be powder coated and/or painted. 3.1.3 Containment Structures §112.7(c), §112.7(h)(1) Corrugated steel containment structures or earthen berms are present to provide containment for bulk storage structures. The storage volume of the respective containment is large enough to contain the entire capacity of the largest single container in the secondary containment plus sufficient freeboard to allow for precipitation taking into account for displacement as applicable. Additional storage volume may be required in the event the facility is located in a Colorado Oil and Gas Conservation Commission (COGCC) high density area or the intermediate or internal 317B buffer zone. Locations located within setback areas are also subject to additional containment requirements. Section 3.1.3.a provides the respective information. In addition, many of the facilities have a perimeter earthen berm around the well pad which can provide containment for separators, and condensate and produced water loading and unloading activities. Should a release occur, the earthen berm will prevent migration of the spilled material away from the site and allow Ursa to control and mitigate the release in a timely and efficient manner. If a site perimeter berm is utilized as secondary containment, a drive -over berm should be installed at the pad's entrance, and any stormwater diversion features should drain to a catchment basin. These structures help to ensure releases of produced water (i.e. oil) at facility on the surface are contained. In some areas, there may be additional secondary containment requirements. Please see below for additional requirements which may be applicable to facilities subject to this plan. 21 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 3.1.3.a Additional Regulatory Requirements § 112.7(j) COGCC: For facilities located in a Colorado Oil and Gas Conservation Commission (COGCC) high density area, and/or a 317B Area, additional stipulations pertaining to SPCC requirements will apply as provided below: COGCC 317B.d Requirements for Drilling Completions Production and Storage Operations at New Oil and Gas Locations in the Intermediate Buffer Zone: The following shall be required for all DCPS Operations at New Oil and Gas Locations within a Surface Water Supply Area and in the Intermediate Buffer Zone as defined in Table 1. (1) Pitless drilling systems; (2) Flowback and stimulation fluids contained within tanks that are placed on a well pad or in an area with down gradient perimeter berming; (3) Berms or other containment devices shall be constructed in compliance with Rule 603.e.(12) 605.a.(4)1 and 906.e.(1)1 around crude oil, condensate, and produced water storage tanks COGCC 604. Setback and Mitigation Measures for Oil and Gas Facilities, Drilling, and Well Servicing Operations Exception Zone Setback. No Well or Production Facility shall be located five hundred (500) feet or less from a Building Unit except as provided in Rules 604.a.(1) A and B, and 604.b. Buffer Zone Setback. No Well or Production Facility shall be located one thousand (1,000) feet or less from a Building Unit until the Operator certifies it has complied with Rule 306.e. and the Form 2A or Form 2 contains conditions of approval related to site specific mitigation measures as necessary to eliminate, minimize or mitigate potential adverse impacts to public health, safety, welfare, the environment, and wildlife. High Occupancy Buildings. No Well or Production Facility shall be located one thousand (1,000) feet or less from a High Occupancy Building Unit without Commission approval following Application and Hearing. Exception Zone Setback mitigation measures pursuant to Rule 604.c. shall be required for Oil and Gas Locations within one thousand (1,000) feet of a High Occupancy Building, unless the Commission determines otherwise. Designated Outside Activity Areas. No Well or Production Facility shall be located three hundred fifty (350) feet or less from the boundary of a Designated Outside Activity. The Commission, in its discretion, may establish a setback of greater than three hundred fifty (350) feet based on the totality of circumstances. Buffer Zone Setback mitigation measures pursuant to Rule 604.c. shall be required ' The regulatory references are not currently finalized. Upon finalization, the text will be updated as applicable. 22 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan for Oil and Gas Locations within one thousand (1,000) feet of a Designated Outside Activity Area, unless the Commission determines otherwise. Maximum Achievable Setback. If the applicable setback would extend beyond the area on which the Operator has a legal right to locate the Well or Production Facilities, the Operator may seek a variance under Rule 502.b. to reduce the setback to the maximum achievable distance. Mitigation Measures. The following requirements apply to an Oil and Gas Location within a Designated Setback Location and such requirements shall be incorporated into the Form 2A or associated Form 2 as Conditions of Approval. Leak Detection Plan. The Operator shall develop a plan to monitor Production Facilities on a regular schedule to identify fluid leaks. Berm construction. Berms or other secondary containment devices in Designated Setback Locations shall be constructed around crude oil, condensate, and produced water storage tanks and shall enclose an area sufficient to contain and provide secondary containment for one -hundred fifty percent (150%) of the largest single tank. Berms or other secondary containment devices shall be sufficiently impervious to contain any spilled or released material. All berms and containment devices shall be inspected at regular intervals and maintained in good condition. No potential ignition sources shall be installed inside the secondary containment area unless the containment area encloses a fired vessel. Refer to American Petroleum Institute Recommended Practices, API RP - D16. Tank specifications. All newly installed or replaced crude oil and condensate storage tanks shall be designed, constructed, and maintained in accordance with National Fire Protection Association (NFPA) Code 30 (2008 version). The operator shall maintain written records verifying proper design, construction, and maintenance, and shall make these records available for inspection by the Director. Only the 2008 version of NFPA Code 30 applies to this rule. This rule does not include later amendments to, or editions of, the NFPA Code 30. NFPA Code 30 may be examined at any state publication depository library. Upon request, the Public Room Administrator at the office of the Commission, 1120 Lincoln Street, Suite 801, Denver, Colorado 80203, will provide information about the publisher and the citation to the material. Exception Zone Setback. Within the Exception Zone Setback, the following mitigation measures will be mandatory: All mitigation measures required pursuant to subsection 604.c.(2), above, and Berm Construction: i. Containment berms shall be constructed of steel rings, designed and installed to prevent leakage and resist degradation from erosion or routine operation. ii. Secondary containment areas for tanks shall be constructed with a synthetic or engineered liner that contains all primary containment vessels and flowlines and is mechanically connected to the steel ring to prevent leakage. iii. For locations within five hundred (500) feet and upgradient of a surface water body, tertiary containment, such as an earthen berm, is required around Production Facilities. iv. In an Urban Mitigation Area Exception Zone Setback, no more than two (2) crude oil or condensate storage tanks shall be located within a single berm. 23 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan COGCC 605. Oil and Gas Facilities Atmospheric tanks used for crude oil storage shall be built in accordance with the standards specified with the respective regulation. (2) Tanks shall be located at least two (2) diameters or three hundred fifty (350) feet, whichever is smaller, from the boundary of the property on which it is built. Where the property line is a public way the tanks shall be two thirds (2/3) of the diameter from the nearest side of the public way or easement. A. Tanks less than three thousand (3,000) barrels capacity shall be located at least three (3) feet apart. B. Tanks three thousand (3,000) or more barrels capacity shall be located at least one-sixth (1/6) the sum of the diameters apart. When the diameter of one tank is less than one-half (1/2) the diameter of the adjacent tank, tanks shall be located at least one-half (1/2) the diameter of the smaller tank apart. (3) At the time of installation, tanks shall be a minimum of two hundred (200) feet from any building unit.(4) Berms or other secondary containment devices shall be constructed around crude oil, condensate, and produced water tanks to provide secondary containment for the largest single tank and sufficient freeboard to contain precipitation. Berms and secondary containment devices and all containment areas shall be sufficiently impervious to contain any spilled or released material. Berms and secondary containment devices shall be inspected at regular intervals and maintained in good condition. No potential ignition sources shall be installed inside the secondary containment area unless the containment area encloses a fired vessel.(5) Tanks shall be a minimum of seventy-five (75) feet from a fired vessel or heater treater.(6) Tanks shall be a minimum of fifty (50) feet from a separator, well test unit, or other non -fired equipment.(7) Tanks shall be a minimum of seventy-five (75) feet from a compressor with a rating of 200 horsepower, or more.(8) Tanks shall be a minimum of seventy-five (75) feet from a wellhead.(9) Gauge hatches on atmospheric tanks used for crude oil storage shall be closed at all times when not in use.(10) Vent lines from individual tanks shall be joined and ultimate discharge shall be directed away from the loading racks and fired vessels in accord with API RP 12R-1, 5th Edition (August 1997, reaffirmed April 2, 2008). Only the 5th Edition of the API standard applies to this rule; later amendments do not apply. The API standard is available for public inspection during normal business hours from the Public Room Administrator at the office of the Commission, 1120 Lincoln Street, Suite 801, Denver, Colorado 80203. In addition, these materials may be examined at any state publication depository library. (11) During hot oil treatments on tanks containing thirty-five (35) degree or higher API gravity oil, hot oil units shall be located a minimum of one hundred (100) feet from any tank being serviced. COGCC 906.e.(1) Spill/Release Prevention Secondary containment. Secondary containment that was constructed before May 1, 2009 on federal land, or before April 1, 2009 on other land, shall comply with the rules in effect at the time of construction. Secondary containment constructed on or after May 1, 2009 on 24 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan federal land, or on or after April 1, 2009 on other land shall be constructed or installed around all tanks containing oil, condensate, or produced water with greater than 3,500 milligrams per liter (mg/1) total dissolved solids (TDS) and shall be sufficient to contain the contents of the largest single tank and sufficient freeboard to contain precipitation. Secondary containment structures shall be sufficiently impervious to contain discharged material. Operators are also subject to tank and containment requirements under Rules 603. and 604. This requirement shall not apply to water tanks with a capacity of fifty (50) barrels or less. COGCC 1101.e. Pressure testing of flowlines (1) Before operating a segment of flowline it shall be tested to maximum anticipated operating pressure. In conducting tests, each operator shall 1100-1 As of September 30, 2014ensure that reasonable precautions are taken to protect its employees and the general public. The testing may be conducted using well head pressure sources and well bore fluids, including natural gas. Such pressure tests shall be repeated once each calendar year to maximum anticipated operating pressure, and operators shall maintain records of such testing for Commission inspection for at least three (3) years. (2) Flowline segments operating at less than fifteen (15) psig are excepted from pressure testing requirements. Federal Leases Onshore Order 3 For facilities which are subject to Onshore Order 3 (i.e. assets located on Federal leases, or wells and facilities on State or privately -owned mineral lands committed to a unit or communitization agreement that affects Federal or Indian interests), valves and other points which oil could be loaded out of will require a unique identifier called a seal to ensure oil (i.e. condensate) is not unloaded from the equipment without the volume being documented and provided to the respective federal agent (i.e. bureau of Land Management official, or Bureau of Indian Affairs official). For additional information pertaining to the requirements of this regulation please see Attachment 1. 3.1.4 Potential Discharge Volume and Direction of Flow §112.7(b) The direction of flow will be specific to the respective location the facility is associated with, and is noted within the site specific plan(s) included within Appendix A. Please see below for examples of potential discharge volumes and causes. One scenario for release of oil is the loss of containment of the largest tank at any particular facility due to rupture (300 bbl. example tank size). This could result in the release of up to 12,600 gallons of oil within one hour. Oil would spill into the containment. In this scenario, oil would be contained within the secondary containment. Another possible scenario would be the release of oil outside the containment during truck loading/unloading activities; such as a ruptured hose connection on water truck. This could result in the release of approximately 150 gallons of oil per minute, until the attendant could access the shutoff valve. The volume of oil released during this scenario is variable. A third possible scenario would be the rupture of a flowline outside of secondary containment due to equipment failure. This could result in the release of approximately 150 gallons of oil per 25 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan hour, until the failure is noticed during routine inspections. The volume of oil released during this scenario is variable. In all instances, the spill response and notification procedures provided in Ursa's Spill Prevention and Management Plan would be implemented in an orderly and efficient manner. In addition to the Spill Prevention and Management Plan, an Oil Spill Contingency Plan is included with this plan. 3.1.5 Proximity to Navigable Waters - § 112.1(d), §112 .4(a)(6) All facilities are located within the Colorado River watershed. The surface water proximity is illustrated within maps and tables contained in Appendix A. In the event of an uncontrolled discharge from a facility, oil would follow the natural topography of the landscape. Additionally, each facility diagram within the site specific plan depicts the anticipated direction of runoff from the facility and the distance relative to the potentially impacted navigable waterway. 3.1.6 Site Specific Facility Diagrams §112.4 Site specific facility maps and diagrams are included in Appendix A with the following detail and location information as applicable: • Process equipment. • Fixed aboveground storage tanks. • Direction of surface water runoff. • Completely buried and bunkered tanks (including USTs covered under 40 CFR 280 or 281). • Drum and portable container storage areas. • The type of oil and storage capacity. • Material of construction for all containers. • Connecting pipes including intra -facility gathering lines. 3.1.7 SPCC Plan Development Tables Site specific SPCC detail tables were drafted for each facility included in this plan. Details from the development tables such as the number of tanks, capacity, contents, and containment descriptions are provided in Tables 2, 3 and 4 of the respective site specific plans. The development tables were created to standardize SPCC/containment site inspections and maintain a database of information including but not limited to: • General facility information. • Tank information. • Processing equipment. • Containment/loadout information. • Failure information outside of containment. • Facility property information. • Surrounding drainage. • Comments. 26 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 3.2 General Requirements § 112.7 3.2.1 Discovery, Response and Cleanup of Releases § 112.7(a)(c)(iii) The respective facilities are inspected routinely as described in Section 3.3.2. In the event a release is discovered, the protocol provided in the Spill Prevention and Management Plan will be implemented. Section 3.5.1 of this plan provides guidance with regards to annual training requirements. It is recommended that oil handling personnel obtain and maintain the appropriate Hazwoper training for their position. All recovered materials will be handled in accordance with all applicable federal, state and local laws and regulations as described in the Spill Prevention and Management Plan and Section 3.4 of this plan. 3.2.2 Notification Contacts § 112.7(a)(c)(iii) Dwayne Knudson or Robert Bleil: - 970-625-9922 — Rifle Office Number - 970-456-3335 — Dwayne Mobile - 970-425-0303 — Rob Mobile - 720-508-8350 — Denver Office Please see the flowcharts included in Appendix B if the above personnel cannot be contacted, should a release occur, additional information is provided in the Spill Prevention and Management Plan. Prior to any notification to agencies, the Spill Prevention and Management Plan will be utilized to determine the agency notification requirements. 3.2.3 Notification Forms §112.7(a)(4) The appropriate forms which must be completed prior to reporting a spill are included in this plan as Appendix D. For additional information, please refer to the Spill Prevention and Response Plan and Appendix B of this plan. 3.2.4 Response Plan §112.7(d)(1) General information on the response to, and reporting of, oil discharges can be found in the Spill Prevention and Response Plan. Additional information is located within Section 3.4 of this plan and the attached Oil Spill Contingency Plan, a copy of which is provided in Appendix B. The Oil Spill Contingency Plan describes procedures that will be implemented under various emergency scenarios, including when an oil discharge occurs. The plan is also designed to address releases from areas such as flowlines where secondary containment is not practical. 27 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 3.3 Routine Facility Operations, Inspections and Maintenance §1 12.7(e) Ursa's oil spill prevention program is described in this section of the SPCC plan and includes routine facility operations, periodic inspections and maintenance activities. It addresses all routine activities associated with the oil production facilities as required by 40 CFR 112.7 and 112.9. 3.3.1 Facility Operations §112.7(h) All equipment is operated and positioned in a way which is designed to prevent and contain releases. Load line and drain valves are maintained in a closed position when not in use. The facility is visited periodically by Ursa personnel. The volume of liquid is gauged and the fluid level in each tank is assessed prior to loading or offloading oil2 when the inventory approaches the tank capacity. The designated personnel also performs a visual inspection of all above ground vessels, tank hatches, valves, and containment features to ensure issues are promptly identified as described in Section 3.3.2. Tank truck loading/unloading occurs at all the facilities covered in this plan. However, the facilities will not have a loading/unloading rack as defined by 40 CFR 112.2. The tanks may be connected to each other via piping, or each tank may be self-contained within the respective containment area. Trucks used to offload oil are positioned adjacent to the containment structures and are attended by the personnel during all loading and unloading activities. All loading and unloading activities are conducted by qualified contract personnel who are trained in proper loading and spill prevention techniques and procedures. Pumper truck personnel inspect tank truck and transfer lines including drains and outlets on the tank trucks prior to filling and before departure to ensure that there are no leaks or discharges. If necessary, truck personnel tighten, adjust, or replace equipment that is leaking. Premature vehicular departures are prevented with a manual air brake system and oversight. A Summary of Operating Procedures (SOP) can be found in Appendix E. 3.3.2 Facility Inspection Program §112.7(e) Tanks containing oil are inspected periodically. Designated personnel are trained to identify and report any leaks or other deficiencies (e.g. compromised containment). Inspections are conducted on a monthly basis and include review of equipment, tanks, valves, hatches, and lines; the site drainage system; and the entire tank battery, including the area within the containment structures and earthen berms. Specifically, each storage vessel, separator, and miscellaneous equipment is visually inspected for deterioration and maintenance needs, including the foundation and support of each tank/container located on or above the ground surface. The inspection also includes visual check of facility transfer equipment including transfer piping and valves, drip pans, pumping well polish rod stuffing boxes, tanks, separators, heater -treaters, valve glands and bodies, pipe supports, and bleeder and gauge valves. Inspection of conditions associated with buried flowlines is accomplished by observing the ground surface above the lines for evidence of leaks on a routine basis. Please see the inspection form included as Appendix D. It should be z Oil means oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil. 28 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan noted that some locations will have additional inspection requirements in accordance with the respective location's COGCC Form 2A conditions of approval. The approved Form 2A has been included for reference within the respective site specific plans for locations it was available for. In the event additional Form 2A documents are approved, the document shall be included within the site specific plans as soon as practical. During the field inspection, the site drainage systems such as drainage ditches, road ditches, and intermittent creeks in the vicinity of the facility are inspected for accumulations of oil. Rainwater and other precipitation that accumulates within the berm is either allowed to evaporate, infiltrate into underlying soil, or is removed using a vacuum truck. Excess rainwater removed by the vacuum truck is either returned to storage or transported for offsite disposal at a permitted non- hazardous disposal facility. No drains are present in the containment structures or earthen berms. A discharge of rainwater from the containment structures cannot occur unless the structure fails or is breached. Observations made by the SPCC inspector are recorded on SPCC/Containment inspection, which are stored at the Rifle Field Office and the corporate office in Denver. A copy of the SPCC/Containment inspection form is provided in Appendix D. Mechanical integrity and spill - related issues are addressed as they are identified. During the inspection, the site drainage systems such as drainage ditches, road ditches, and intermittent creeks in the vicinity of the facility are inspected for accumulations of oil. Rainwater and other precipitation that accumulates within the berm is either allowed to evaporate, infiltrate into underlying soil, or is removed using a vacuum truck. Excess rainwater removed by the vacuum truck is either returned to storage for use in storage or transported for offsite disposal at a permitted non -hazardous disposal facility. No drains are present in the containment structures or earthen berms. A discharge of rainwater from the containment structures cannot occur unless the structure fails or is breached. Oil accumulating within the containment area is removed using absorbent pads or is removed with excess rainwater using a vacuum truck as described above. Accumulated oil is not discharged outside of the containment area. Evidence of hydrocarbon spills are noted and remediated as appropriate as described in Section 2.4. Please see below for a table which provides guidance with regards to inspection and testing recommendations: 29 Ursa Operating Company LLC 3.3.2.a Testing and Record Keeping Guidance §112.7 Oil Production Facility SPCC/Containment Plan — General Requirements Applicable to All Facilities Bulk storage with no secondary containment and for which an impracticability determination has been made 112.7(d) Test Integrity testing. Periodically. However, because there is no secondary containment, good engineering practice may suggest more frequent testing than would otherwise be scheduled. Valves and piping associated with bulk p p g storage containers with no secondary containment and for which an impracticability determination has been made 112.7(d) Test Integrity and leak testing of valves andi in associated p p g with containers that have no secondary containment as described in § 112.7(c). Periodically. Recordkeeping requirement 112.7(e) Record Keep written procedures and a signed record of inspections and tests for a period of three years. Records kept under usual and customary business practices will suffice, for all actions. Lowermost drain and all outlets of tank car or tank truck 112.7(h)(3) Inspect Visually inspect. Prior to filling and departure of tank car or tank truck. Field -constructed aboveground container 112.7(1) Evaluate Evaluate potential for brittle fracture or other catastrophic failure. When the container undergoes a repair, alteration, reconstruction or a change in service that might affect the risk of a discharge or failure due to brittle fracture or other catastrophe, or has discharged oil or failed due to brittle fracture failure or other catastrophe. Based on the results of this evaluation, take appropriate action. 30 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan Requirements for Onshore Production Facilities Diked area 112.9(b)(1) Inspect Visually inspect content. Prior to draining. You must remove accumulated oil on the rainwater and return it to storage or dispose of it in accordance with legally approved methods. Field drainage systems, oil traps, sumps, and skimmers 112.9(b)(2) Inspect Detect accumulation of oil that may have resulted from any small discharge. Inspect at regularly scheduled intervals. You must promptly remove any accumulations of oil. Aboveground containers 112.9(c)(3) Inspect Visually inspect to assess deterioration and maintenance needs. Periodically and on a regular schedule. Foundations or supports of each container that is on or above the surface of the ground 112.9(c)(3) Inspect Visually inspect to assess deterioration and maintenance needs. Periodically and on a regular schedule. All aboveground valves and piping associated with transfer operations 112.9(d)(1) Inspect During the inspection, assess general condition of flange joints, valve glands and bodies, drip pans, pipe supports, pumping well polish rod stuffing boxes, bleeder and gauge valves, and other such items. Periodically and on a regular schedule. Saltwater disposal facilities 112.9(d)(2) Inspect Inspect to detect possible system upsets capable of causing a discharge. Often, particularly following a sudden change in atmospheric temperature. Flowlines 112.9(d)(3) Inspect Have a program of flowline maintenance to prevent discharges from each flowline. Each program may have its own specific and individual inspection, testing, and/or evaluation requirements and frequencies as determined by the PE. 31 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 3.3.4 Maintenance Program §1 12.5 Ursa has a robust maintenance program aimed at eliminating releases of oil and minimizing unplanned downtime. Preventative maintenance on mechanical equipment (e.g. pumps) is completed in accordance with manufacturer recommendations to ensure proper operation. Any equipment requiring maintenance that is identified by visual inspections of the facilities are addressed by either Ursa mechanical staff or third party contractors. Equipment repairs are made in accordance with the relevant codes and industry standards. 32 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 3.4 Response and Reporting Information § 112.7(f)(3) Detailed spill reporting and response procedures are provided in the Spill Prevention and Response Plan in addition to the information contained within this section. The specific response protocol utilized will depend on the size and nature of the release. 3.4.1 Spill Response §112.7(f)(2) The Incident Commander (IC) (Dwayne Knudson) and/or Alternate Incident Commander (AIC) (Robert Bleil) are responsible for implementing response procedures in the event of an oil spill or discharge emergency. These personnel have the authority to commit the resources necessary to carry out a response. However, all oil handling personnel of Ursa receive training to familiarize themselves with all aspects of the SPCC Plan, facility operations, the location and characteristics of materials handled at the facility, the locations of all records within the facility; and are responsible for proper implementation of response procedures should the IC or AIC be unavailable. 1. Assess the basic situation; 2. If the incident poses an immediate threat of fire, explosion, or other impact to safety, health, or the environment, the local fire department will be contacted at 911 or relay information to dispatch via radio; 3. Call the company personnel; 4. If it is safe to enter the area and the personnel are properly trained and certified, they can protect themselves with personal protective equipment (PPE); 5. Eliminate ignition sources; 6. Restrict access; 7. Stop the source of the release if safe to do so; 8. Contain the spill if possible to safely to so with available spill response inventory items; 9. Report the release to the appropriate authorities listed in Section 8.0; 10. If the spill involves a minor amount of oil, it will be cleaned up by Ursa personnel provided that: a. They have current and appropriate HAZWOPER and applicable OSHA training; b. Appropriate Material Safety Data Sheets (MSDS sheets) are available for the material spilled; and c. Appropriate PPE is available and used. In general, recovered fluids are either returned to an uncompromised tank for storage, or transported offsite for disposal at a permitted commercial disposal facility. Hydrocarbon impacted soil is segregated onsite and is tested to assess the contamination of concern identified in the COGCC Table 910-1. Please see the flowcharts in Appendix B for streamlined spill response protocol. 3.4.2 Spill Reporting §112.7(a)(4) As described in the Spill Prevention and Response Plan, Emergency Response Plan and the Oil Spill Contingency Plan, the Incident Commander will be notified in the event of a release. Notification forms are provided in Appendix C. The forms will document the event concisely by identifying information that needs to be obtained. Depending on the size and environmental conditions associated with the spill, the Incident Commander may have to report the release to 33 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan various state and federal regulatory agencies. For specific reporting information please see the Colorado and Federal Verbal Notification & Written Reporting Protocol Table located in Appendix B in addition to the Spill Prevention and Response Plan. 34 Ursa Operating Company LLC Oil Production Facility SPCC/Containment Plan 3.5 Spill Response Training § 112.7(0 3.5.1 Annual Training §112.7(0(2) Ursa and its contractors provide the following minimum training to oil -handling personnel: • Operation and maintenance of equipment to prevent oil discharges; • Oil discharge procedure protocols; • Applicable oil spill prevention (State & Federal) laws, rules, and regulations; • General facility operations; and • The contents of the facility SPCC Plan. Training is conducted prior to assignment of job responsibilities and then again annually. Training includes oil spill prevention, SPCC Plan requirements, and federal and state pollution prevention and spill reporting/response requirements. 3.5.2 Discharge Prevention Briefings §112.7(0(2)) The facility conducts discharge prevention briefings for oil -handling personnel at least once a year to assure adequate understanding of the SPCC Plan for the facility. At a minimum, this is conducted via annual SPCC and spill response refresher training describing the contents of the SPCC regulations and plans, spill response techniques, and a review of federal and state spill reporting requirements. These briefings also include discussion of potential discharges or component failures and precautionary measures. If a spill has occurred, Ursa will also summarize the spill events and the measures implemented to prevent future releases. 3.5.3 Training Records § 1 12.7(e) Copies of training and discharge prevention logs can be found in Appendix D. Training records and Discharge Prevention Briefing logs are maintained for a minimum period of three (3) years at the Rifle Field Office. Each contractor organization providing oil -handling personnel maintains training records for its employees. 35 Ursa Operating Company LLC Appendix A APPENDIX A SITE SPECIFIC SPCC PLANS — See Refer to the Field Specific Binder Ursa Operating Company LLC Appendix B APPENDIX B OIL SPILL CONTINGENCY PLAN AND EMERGENCY RESPONSE PLAN Ursa Operating Company LLC Appendix B Oil Spill Contingency Plan This Oil Spill Contingency Plan (Plan) was prepared in accordance with 40 CFR 112.7(a)(5) to address discharges of oil from the facilities covered by the Spill Prevention Control and Countermeasure (SPCC) Plan. It also addresses oil discharges from field operations where secondary containment is impracticable, per 40 CFR 112.7(d). This Plan complements the prevention and control measures presented in the SPCC Plan by defining procedures and tactics for reporting and responding to discharges of oil. The Plan is intended to protect the public and minimize damage to the environment by providing a timely, efficient, coordinated and effective action plan to respond to oil discharges. The plan is consistent with the National Oil and Hazardous Materials Pollution Contingency Plan and follows the guidelines provided in 40 CFR 109. 40 CFR 109.5 (a) Definition of the authorities, responsibilities and duties of all persons. Ursa Management is responsible for: ❑ Ensuring the necessary resources for control and cleanup are available ❑ Ensuring that personnel are adequately trained to notice, report and respond to oil discharges Ursa's Field Superintendent (or designate), serving as the Incident Commander, is responsible for: ❑ Overall coordination of the control and cleanup of the oil discharge ❑ Committing the necessary resources (including monetary) ❑ Requesting additional assistance from outside contractors and/or the Federal authorities if necessary ❑ Ensuring repairs are made prior to putting equipment back in service ❑ Ensuring that proper notifications are made to Federal, State and Local agencies, including any follow up documentation ❑ Providing site safety plan if necessary ❑ Coordinating disposal of contaminated material ❑ Being familiar with the SPCC and Oil Spill Contingency Plans ❑ Being alert for oil discharges and responding to them as appropriate ❑ Assisting, as required, in the control and cleanup of the oil discharge 40 CFR 109.5(b) Establishment of notification procedures. Ursa Operating Company LLC Appendix B Ursa owns and operates a number of oil production facilities located in Garfield County, Colorado. Personnel are trained to look for and report any oil discharge. The following is a list of emergency contact numbers. Depending on the size and nature of the oil discharge some or all of these contacts will be notified. Please refer to the flow charts and tables on the following pages for spill response and notification protocol. Ursa-PERATING CiMPAigY Colorado Operations SPILL NOTIFICATION & MANAGEMENT PROTOCOL (SPILLS, ENVIRONMENTAL INCIDENTS/THREATS) Appendix B SPILL DISCOVERY - VERBAL NOTIFICATION MAJOR INCIDENT "Reportable Spm ',NOV ver Potential Rnes "Release OR$Ite "Spill to L lve Water "Property Damage REPORT IMMEDIATELY TO URSA - DENVER T Contain J Corrtrol Release (If safe to do so) ■ Notify On -Site 5uperviaor IMMEDIATELY ■ Contact Ursa Operations Lead Matt Honeycutt - Operations/Construction - 970.812-2195 Hans Wychgram - Drilling - 303-884-9079 Shane Vaughn - Production - 970-623-9539 Peke Younger - Cornpletlons - 970-260-2423 Dave Hayes - Wasatch & Water Lines - 970-250-2590 ■ Environmental Dwayne Knudson 970-456-3335 Health and Safety Tara Mali 970-618-2155 If no supervisor is present, 41 contact your company supervisor 4 lMoblme InIUN Clean -Up Procedures Unless Delegated by Ursa Lead to another Ursa representative (pumper, contractor, etc) Environmental Back-up's Rob Biell 720-425-0303 Kris Rowe 970-261-2015 Land & Property Jeff Powers 970-309-9359 John Doose 970-379-0008 WRITTEN NOTIFICATION Verify Volumes - Inform Ursa Loads of any volume changes On-Slte Supervisor to Complete Ursa Incident Investigation Form (Shaded area within 12 hours of discovery) Environmental Dwayne Knudson 970-456-3335 Include Spill on Ursa Daily Report T Pr ride Copy tO KrIS Rowe with HCSI ■ Complete Remaining Sections of Incident Investigation Farm URSA SPILL MANAGEMENT PROTOCOL (Appendix B) Ursa Operating Company LLC Appendix B COLORADO AND FEDERAL VERBAL NOTIFCATION & WRITTEN REPORTING PROTOCOL Chemical Media Affected Minimum Amount to Report P COGCC CDPHE BLM NRC/EPA LEPC / Fire Chief Verbal Written Verbal Written Verbal Written Verbal Written Verbal Written Notification Reporting Notification Reporting Notification Reporting Notification Reporting Notification Reporting E&P Surface water / Groundwater Any Immediately 10 Days Immediately 5 Days Immediately 15 days Immediately Upon Request Immediately Upon Request Soil -Outside Containment 1 bbl or greater 24 hrs Initial Report - 72 hrs Form 19 - 10 Days N/A N/A 24 hrs 15 days N/A N/A None Emergency E-mail Within 24 hours Soil -Inside Containment 5 bbls. or greater 24 hrs Initial Report - 72 hrs Form 19 - 10 Days N/A N/A 24 hrs 15 days N/A N/A >100 bbls 24 hrs Initial Report - 72 hrs Form 19 - 10 Days N/A N/A 24 hrs 15 days N/A N/A Non E&P Hydrocarbon Based Surface water / Groundwater Any Immediately Upon Request Immediately 5 days Immediately 15 days Immediately Upon Request Immediately Upon Request Soil gallons N/A N/A 24 hours 5 Days5 N/A 72 hrs N/A N/A N/A N/A > 420 gal (10 bbls.) N/A N/A 24 hrs 5 days N/A N/A N/A N/A N/A N/A > 4,200 gal (100 bbl) N/A N/A 24 hours 5 days 24 hrs 15 days N/A N/A N/A N/A Non E&P Other Surface water / Groundwater Any N/A N/A Immediately 5 days5 Immediately 15 days Upon Request Upon Request Immediately Upon Request Soil Reportable Quantity (RQ) N/A N/A 24 hrs 5 days5 N/A 72 hr (email) 15 days (NTL - 3A) Request st Requ st 72 hr email Request <RQ but >10 bbls. N/A N/A 24 hrs 5 days5 N/A 72 hr (email) 15 days (NTL- 3A) N/A N/A 72 hr email Upon Request <RQ but >100 bbls. N/A N/A 24 hrs 5 days5 24 hrs 15 days N/A N/A 24 hr Upon Request Footnote: 1. Notification and reporting requirements that are listed above are for the most common chemicals encountered in day to day Ursa operations. 2. For chemicals not listed, consult the MSDS for the chemical of concern or call an Ursa environmental team lead. 3. Reportable quantities that are reported by weight need to be converted to a barrel or gallon equivalent for Federal reporting and notification requirements. 4. Notify the State Highway Patrol for transportation related spills involving hazardous materials. 5. Notify the Bureau of Land Management for spills on federal lands as applicable above. Ursa Operating Company LLC Appendix B Spill response shall be completed in accordance with the Ursa Spill Response Plan. Contractors Company Name C D CM P Company Representative Phone No. A & W Transport X X X Jimmy Snoden (970) 625-8270 Basin Western X Erick Brown C (970) 985-6152 BGS Mudlogging X Tarin Boxberger C (970) 623-6626 BOS Solutions X Matt Tremblay C (970) 712-0338 Capstar Drilling X Cory Anderson (307) 315-0813 Corrosion Control Technology X Dorothea Oldaker (970) 245-3433 Craig's Energy X Eric Kay C (435) 828-6278 Elder Trucking X X X Jared Elder (970) 625-4189 Elite BOP Testing X X Bill Karp C (970) 210-5887 FMC Wireline X Ike Apolinar 970-812-7580 GVPS X Matt Maten 970-712-2639 Halliburton X Trevor Courtney C (970) 628-5928 Howcroft Trucking X Derrick Howcroft C (435) 828-4694 JPPS X X Jason Hauck C (970) 618-4468 Kahuna Ventures X Paul Stockebrand 720-889-9946 Kenny's Welding X Kenny Till C (970-589-9444) LEC Services X Eric Moore C (970) 985-9200 LCM Solutions X Ben Williams (970) 261-2145 Master Petroleum X Glenn McPherson C (970) 230-0744 MCS X X X Bob Swim (970) 640-2494 Mesa Production X Pam Keesbery 307-277-0579 Mesa Wireline X X X Steve Hash 970-589-4233 Mesa Wireline - Cutters Wireline X Steve Hash 970-589-4233 Monument Wells Services X Mark Vandehi C (970) 257-6169 Nalco Champion NOV X Anthony Valenti C (303) 573-6827 NOV Drilling Fluids X Jose Mora C (727) 612-1460 Pason X Frank Preuss C (970) 986-9714 Porta Can - Redi Services X X X X Mario Ramirez C (970) 456-7786 Premier Thru Tubing X Derik Winkler C (435) 621-3032 RMWS X X X Stallion X Bart Steele C (970) 274-6549 Stampfel Construction X Kip Costanza 970-379-27777 Stream Flo X X Cale Labrum (720) 724-5586 Triple A X Jed Murray (970) 640-3086 Tuboscope X Dub Haws C (307) 259-1057 Varel X Loren Williams C (970) 314-0324 Walker Inspection X Josh Henderson (970) 319-8874 Ursa Operating Company LLC Appendix B AGENCY CONTACT NUMBER E -Mail ADDRESS Local and State Agencies Parachute Fire Chief David Blair 970-285-9119 (o) 970-250-9851 (c) firechief@gvfpd.org 0124 Stone Quarry Rd. Parachute, CO 81635 Rifle Fire Chief 970-625-1243 (o) 1850 Railroad Ave. Silt Fire Chief Chad Harris 970-379-9681 (c) Chad.Harris@crfs.us Rifle, CO 81650 Bob Peterson 970-248-7151(Bob) Robert.Peterson@dphe.state.co.us 4300 Cherry Creek Drive South CDPHE John O'Rourke 719-269-5327 (John) 1-877-518-5608 [24 -hr] or John.Orourke@state.co.us Denver, CO 80246 CDNR Assigned at call 1-800-536-5308 Assigned at time of call 1313 Sherman Street, Room 718 Denver, CO 80203 CO Dept. of 222 South 6th St. Room 100 Transportation Mike Verkitus 970-216-0577 Mike.Verketis@dot.state.co.us Grand Junction, CO 81501 COGCC Carlos Lujan (970)-625-2497 or (303) 894-2100 Carlos.Lujan@state.co.us 1120 Lincoln Street, Suite 801 Denver, CO 80203 Garfield County Kirby Wynn OEM (LEPC) Kirby Wynn (970) 945-0453 kwynn@garfield-county.com 107 8th Street Rifle, CO 80751 Garfield County (970) 625-5200 ext 8106 195 W. 14th Street Health Agency Morgan Hill 970-379-3826 mhill@garfield-couny.com Rifle, CO 81650 Cindy Mohat Alex Burchetta Emergency Management Cord. Pitkin County OEM or 970-920-5037 alex.burchetta@pitkinsheriff.com Pitkin County sheriff's Office Cindy Mohat 506 E. Main Aspen, CO 81611 Silt Public Water Jack Castle 970-876-2353 ext 817 231 N. 7th Street Intake Or Gerry Pace 970-876-5444 970-876-0460 jackc@townofsilt.org PO Box 70 Silt, CO 81652 Rifle Public Water 202 W. Railroad Av. Intake Dick Deussen 970-665-6590 ddeussen@rifleco.org Rifle, CO 81650 Parachute Public 970-285-7630 (office) 222 Grand Valley Way Water Intake Mark King 970-986-1821 (cell) raking@parachutecolorado.com PO Box 100 Parachute, CO 81635 Ursa Operating Company LLC Appendix B Federal Agencies National Response Assigned @ 1-800-424-8802 2703 Martin Luther King Jr Ave. Center Call Available 24 hours HQS-DG-lst-NRCINFO@uscg.mil SE, STOP 7713 Washington, DC 20593-7713 US Dept. of Assigned @ 1200 New Jersey Avenue, SE Transportation Call (202) 366-4000 N/A Washington, D.C. 20590 Environmental Assigned @ Ariel Rios Building Protection Agency Call (202) 272-0167 N/A 1200 Pennsylvania Ave., NW Washington, DC 20460 Bureau of Land 970-876-9056 (o) 2850 Youngfield Street Management Jim Byers 970-319-2532 (c) jbyers@blm.gov Lakewood, CO 80215 40 CFR 109.5(c) Provisions to assure that full resource capability is known. All field operation personnel are familiar with the location of spill response equipment and response strategies, and with the SPCC and Oil Spill Contingency Plans. They receive annual training in the deployment of response material and handling of hazardous waste (HAZWOPER). Sufficient equipment to respond to the majority of oil discharges is kept at the Ursa Field Office and is accessible 24 -hours a day to field operation personnel. This equipment is verified on a monthly basis by designated personnel and is replenished as needed. Ursa Operating Company LLC Appendix B Identification and Inventory of Recommended Applicable Equipment 3 -Cases 17" x 19" x 3/8" Oil absorbent Pads 1 -Case 7" W x 15" L Oil Absorbent Pillows 1 -Case 3" x 4' Mini Booms 1 -Case 3" x 8" Oil Absorbent Booms 1 5" x 10' Oil Absorbent Boom 2 -Boxes 36" x 56" 3 mil Trash Can Liners 1 Large Tyvek Coverall 1 Extra Large Tyvek Coverall 1 -Bag Size 10 Green Nitrile Gloves 2 Round Point Blade Shovels 2 Square Point Blade Shovels 15 5-1/2 foot Steel Fence Posts 1 Fence Post Driver 1 -Roll 16 ga Tie Wire 1 -Bundle Wooden Stakes 1 Crescent 148 Piece Tool Set 6 28" Traffic Cones 2 -Rolls Duct Tape 2 -Rolls 6 mil 20' x 100' Plastic Sheeting 3 201b. Fire Extinguishers 1 Metal First Aid Kit 2 55 Gal. Poly Drums (Drums contain absorbent booms, pillows and pads) 1 55 Gal Steel Drum 40 CFR 109.5(d) Provisions for well-defined and specific action to be taken after discovery and notification of an oil discharge. Ursa has the primary responsibility to provide the initial response to oil discharge incidents originating from its operations. To accomplish this, Ursa has designated the Senior Environmental Specialist, Dwayne Knudson, as the qualified Incident Commander. Robert Bleil will serve as the Alternate Incident Commander. In addition, Ursa maintains an Emergency Response Team, some or all of which may be mobilized depending on the size and nature of the oil discharge. Upon the discovery of an oil discharge the Incident Commander will be notified so that appropriate action can be taken. The Incident Commander has the authority to direct and coordinate response operations and may request assistance from Federal authorities as necessary. Containment and clean-up operations will be managed out of the Ursa Field Office. Operations personnel are equipped with cellular phones to assist with communications. In the event of a discharge, the first priority is to stop the product flow and to shut off all ignition sources, followed by the containment, control, and mitigation of the discharge. Specifically, the following response procedures will be implemented in accordance with the respective personnel's level of training: Ursa Operating Company LLC Appendix B Response Procedures Please refer to the Spill Prevention and Response Plan for a definitive guide for response procedures. A. Detection: 1. Notify the Incident Commander that an oil spill has occurred (provide location, source, amount, nearby areas of concern, etc.). 2. Shut off ignition sources (motors, electrical circuits, open flames). 3. Turn off pumping unit that charges or provides flow to the flowlines. 4. Locate the source of flowline leak. 5. Attempt to stop the source of the leak, if it can be done safely. 6. Initiate containment. B. Assessment and Notifications: 1. Investigate the discharge to assess the actual or potential threat to human health or the environment. 2. Mobilize the Emergency Response Team if necessary. 3. Request outside assistance from local emergency responders, as needed. 4. Communicate with property owners regarding the discharge and actions taken to mitigate the damage. 5. Make appropriate notifications to Federal, State, and Local agencies. C. Control and Recovery 1. Prevent the spread of oil by deploying absorbents (i.e. booms), by building diversion structures (i.e. berms), or digging temporary containment pits. 2. Direct clean-up of the oil and oil contaminated material. 3. Arrange to have soil and/or water samples analyzed per COGCC Table 910-1 standards, and/or CDPHE water standards. If contaminants are below the affected agencies allowable concentrations cleanup is complete. 4. Containerize contaminated material (soil, water, absorbent material, etc.). D. Disposal of Recovered Product and Contaminated Response Material 1. Recovered product can either be added to another tank or disposed of at an appropriate disposal site. 2. Properly characterize, label and store all contaminated material. 3. Dispose of contaminated material in accordance with all applicable solid and hazardous waste regulations using a licensed waste hauler and disposal facility. E. Termination 1. Arrange for necessary repairs to equipment or flowlines. 2. Review circumstances that led to the discharge and take necessary precautions to prevent a recurrence. Ursa Operating Company LLC Appendix B 3. Submit any required follow-up reports to the authorities. 4. Update the SPCC and Oil Spill Contingency Plan as necessary. 40 CFR 109.5(e) Specific and Well Defined Procedures to Facilitate Recovery of Damages An Environmental Incident Report will be filled out by the Incident Commander and maintained on file at the Ursa Field Office. Any other documentation regarding the oil discharge will also be kept on file. Ursa Operating Company LLC Appendix C APPENDIX C DISCHARGE NOTIFICATION FORMS • COGCC Form 19 Spill/Release Report • Ursa's Environmental Incident Report • Submittal of Information to Regional Administrator for Reportable Discharge(s) Ursa Operating Company LLC FORM 19 Rev 6/99 Click here to reset form State of Colorado Oil and Gas Conservation Commission 1120 Lincoln Street, Sute 801, Denver, Colorado 80203 (303)894-2100 Fax:(303)894-2109 SPILL/RELEASE REPORT (This form is to be submitted by the party responsible for the oil and gas spill or release. Any spill or release which may impact waters of the State must be reported as soon as practicable; any spill over 20 bbls must be reported within 24 hours and all spills over fiv a bbls must be reported within ten days. Submit a Site Investigation and Remediation Workplan (Form 27) Mien requested by the Director. OPERATOR INFORMATION Form 19 FOR OGCC USE ONLY Spill report taken by FACILITY ID: Name of Operator: 0G CC Operator No: Address: City: State: Zip: Contact Person: No: Fax: E -Mail: Phone Numbers DESCRIPTION OF SPILL OR RELEASE Date of Incident: Facility Name &No.: County: Type of Facility (well, tank battery, flow line, pit): QtrQtr: Well Name and Number: _ Township: API Number: Meridian: Specify volume spilled and recovered Qn bbls) for he following materials: Oil spilled: Oil record: _ Water spilled: Water recoVd: Other spilled: Other recoVd: Ground Water impacted? ❑ Yes ❑ No Surface Water impacted? ❑ Yes ❑ No Contained within berm? ❑ Yes ❑ No Area and vertical extent of spill: x Current land use: Weather conditions: Section: Range: Soil/geology description: IF LESS THAN A MILE, repot distance IN FEET to nearest.... Surface water: wetlands: buildings: Livestock: water wells: Depth to shallowest ground water: Cause of spill (e.g., equipment failure, human error, etc.): Detailed description of the spilllrelease incident: CORRECTIVE ACTION Describe immediate response (how stopped, contained and recovered): Describe any emergency pits constructed: How was the extent of contamination determined: Further remediation activities proposed (attach separate sheet if needed): Describe measures taken to prevent problem from reoccurring: OTHER NOTIFICATIONS List the parties and agencies notified (County, BLM, EPA, DOT, Local Emergency Planning Coordinator or other). Die Agency Contact Phone Response SpiIIiRelease Tracking No: UrsaOPERATING COMPANY Pad/Location: Report Date: ENVIRONMENTAL SPILL/RELEASE INVESTIGATION Responsible Party URSA OP's PHASE CONTRACTOR: *Attach Billing Info Initial Repotting (personnel that discovered release) Occurred: Time: Discovered By: Est. Volume: Material Released Spill Contained on Location () NO ( ) Yes SIGNIFICANT THREAT TO HUMANS OR ENVIRONMENT Company: Ph: Within 317B Area? ( ) NO ( ) YES Live Water Impacted? () NO ( ) YES Within Secondary Containment? ( ) NO ( ) YES ( ) NO ( ) YES - Implement Emergency Response Plan Follow Up (for Ursa Offical Use) INCIDENT LOCATION RELEASE TYPE Written Reporting Required LANDS AFFECTED MEDIA AFFECTED No 317B AREA ( ) Well Pad ( ) Facility ( ) Transportation (DOT) ( ) E&P waste ( ) Non- E&P ( ( ( ) ) ) Private Federal Split Estate ( ) ( ) ( ) ( ) Land/Soil Waters (U.S) Wetland/Riperian Ground Water ( ( ( ) ) ) Buffer Zone Water Impacted N/A ( ) Other: ( ) Other: ( ( ) ) On -Lease Off- Lease INCIDENT DESCRIPTION (How incident occurred, type of effluent, emissions, chemical, etc.): FED-BLM Yes VOLUME RECOVERED: No Date: Yes ROOT CAUSE: CDP HE Yes PLANS TO IMPLEMENT ADDITIONAL TRAINING (DESCRIBE): DATE TRAINING COMPLETE: Date: Yes No Waste Management (Requires Ursa Approval) FINAL DISPOSITION OF WASTE (STORAGE, TREATMENT, DISPOSAL): DISPOSAL LOCATION: Ursa Approval: ( ) NO ( ) YES DATE: Manifesting Required: ( ) NO ( ) YES NOTIFICATION/REPORTING ACTIONS (to be completed by Ursa Spill Program Support - KKRowe HRL) Agency/Owner Verbal Notification Required Written Reporting Required Landowner Yes No Date: Yes No COGCC Yes No Date: Yes No FED-BLM Yes No Date: Yes No CDP HE Yes No Date: Yes No LEPC Yes No Date: Yes No NRC Yes No Date: Yes No FIRE CHIEF Yes No Date: Yes No THIS REPORT MUST BE FILED AND SUBMITTED IMMEDIATELY OF THE INCIDENT TO THE URSA SPILL COORDINATOR Ursa Operating Company LLC EPA Reportable Discharge Notification Form Submittal of Information to Regional Administrator for Reportable Discharges In the event of a reportable discharge or discharges, this page can be utilized to provide official notification to the Regional Administrator. If the Facility has had a discharge or discharges which meet one of the following two criteria, then this report must be submitted to the Regional Administrator within 60 days. ❑ This Facility has experienced a reportable spill as referenced in 40 CFR Part 112.1(b) of 1,000 gallons or more. ❑ This Facility has experienced two (2) reportable spills (as referenced in 40 CFR Part 112.1(b) of greater than 42 gallons each within a 12 -month period. Facility Name and Location: Facility contact (Name, Address, Phone Number): Facility maximum storage or handling capacity: Facility normal daily throughput: Describe the corrective action and countermeasures taken (include description of equipment repairs and replacements): Describe the Facility (maps, flow diagrams and topographical maps attached as necessary): Describe the cause of discharge(as referenced in 40 CFR Part 112.1(b)) including failure analysis of the system: Describe the preventative measures taken or contemplated to be taken to minimize the possibility of recurrence: Other pertinent information: Ursa Operating Company LLC Appendix D APPENDIX D SPCC FORMS • SPCC/Containment Field Inspection • Personnel Training Log UrsaCOMPANY SPCC/Containment Inspection LOCATION 1 1 FIELD 1 1 DATE 1 I Federal 40 CFR 112 — SPCC Criteria TANKS/PIPING/EQUIPMENT Y N SECONDARY CONTAINMENT Y N Tanks - Evidence of leaks on tanks, seams, connections? Evidence of damage to containment infrastructure? Tanks - NFPA labels absent or damaged? Evidence of containment not being functional? Piping - Evidence of leaks on pipes, connections, valves fittings? Evidence of tank product within c ontainment? Loading/Unloading - Evidence of improperly secured connections? Evidence of snowmelt / rainwater within c ontainment? Other - Evidence of leaks/spills from other equipiiient? Evidence of trash / debris within containment? SPILLS & RELEASES Y N Tanks - Evidence of spills or releases to the environment? Piping - Evidence of spills or releases to environment? Loading / Unloading - Evidence of spills or releases to environment? Produced Water and Condensate Tank Information Miscellaneous Equipment and Chemicals Tank ID Tank Contents Tank Volume (bbl.) Miscellaneous Quantity Volume Separators Oil (gallons) Fuel (gallons) Frac Tanks Dehydrators' Other Chemicals': COGCC Rule Criteria 300 Series Rules Y N Regulation Is the location within a 317B area? NA Per 01.17.2014 correspondence with COGCC, refer to the specified regulations until notification that rules have been finalized is provided. COGCC — 605.a.(4), 906 .e .(1) 600 Series Rules Y N Regulation Is the facility within a setback zone? NA For Exception Zone Setback locations within 500 feet and up gradient of a surface water body, tertiary containment is required around production facilities. If applicable, is the site in compliance? COGCC — 604.c.(3),B.iii. For Urban Mitigation Area Exception Zones, no more than two crude oil or condensate tanks can be within a single berm. Is the site in compliance? COGCC — 604.c.(3).B.iv. All Locations - Are secondary containment features impervious? COGCC — 605.a.(4) All Locations - Is the synthetic or engineered liner beneath each above ground storage tank? COGCC — 605.a.(4) 900 Series Rules2 Y N Regulation All Locations - Is the containment sufficient to hold the contents of the largest tank and precipitation? COGCC - 906.e.(1) BLMIUSFSIBIA Criteria Onshore Order 3 Y N Comments Do the wells on site access federal minerals? Regulation not applicable to private leases. If applicable, are the seals properly placed on valves? Comments Inspector Name Inspector Signature Material is riot regulated under 40 CFR 112 2 Secondary containment that was constructed before May 1, 2009 on federal land, or before April 1, 2009 on other land, shall comply with the rules in effect at the time of construction. Secondary containment constructed on or after May 1, 2009 on federal land, or on or after April 1, 2009 on other land shall be constructed or installed around all tanks containing oil, condensate, or produced water. Ursa Operating Company LLC SPCC Training and Briefing Log Form Appendix D SPCC Training/Briefing Log Trainer: Date: Subjects Discussed: Name and Signature: Please note: briefings are to take place on an annual basis at a minimum. All oil handing personnel shall be training in accordance with the criteria specified in 40 CFR 112.7(f)(1). At a minimum, training is to include: a. the operation and maintenance of equipment to prevent discharges; b. discharge procedure protocols; - (addressed during the Ursa Spill Response portion of this training) c. applicable pollution control laws, rules, and regulations; general facility operations; and, d. the contents of the facility SPCC Plan. Ursa Operating Company LLC Appendix E APPENDIX E SUMMARY OF OPERATING PROCEDURES AND FLOWLINE MAINTENANCE PROGRAM Ursa Operating Company LLC Appendix E SUMMARY OF OPERATING PROCEDURES Before any pumper is on location, gas meters must be on and properly calibrated. The following (however not limited to) need to be checked in addition to regular pumper's responsibility to ensure a safe and normal operation by the production operators/pumpers during their routine checks: 1. Water/oil dump valve and water flow meter malfunction: A. Physically check every separator when appropriate by isolation/bleed-off method. B. If there is any leak through the dump valve and if it is large, replace the trim or valve immediately, if not, try to fix the problem on site as soon as possible and plan to replace the trim/valve at the earliest opportunity. C. Monitoring SCADA for gas & water flow rate can be used in conjunction with physical check. 2. High/low setting trim troubleshooting: A. Physically check Kimray valve for leak (by listening noise, feeling temperature change on both sides of the valve and looking for frost for high differential minor leaks). B. If leak is suspected, confirm by physically checking separator by blowing separator down, then opening up to flowline to see if any gas is flowing back into separator. C. If leak is identified, replace high/low trim immediately. 3. Water/oil trim hanging open A. Physically check every separator when on a pad by listening for gas blowing through water/oil dump and visually check trim set position, then rectify problem. B. Periodically monitor separator pressures throughout day using SCADA to detect discrepancies, then rectify problem. C. Physically check by-pass valves for leaks by feeling temperature difference on both sides of valve, look for, frost or noise. D. If valves are leaking, take necessary actions and inform Ursa about its replacement. 4. Water Skid Pressures at different areas in the field A. Identify skid pressures that are higher than normal operating range on a daily basis (use best judgment) and report to Ursa. B. Purge gas from water headers to lower skid pressures. Ursa Operating Company LLC Appendix E 5. Operation of Water Network during hydraulic fracturing & flowback using the same system A. When the field lines are being utilized for hydraulic fracturing (frac) & flowback operations, the pump will be operated exclusively by the frac & flowback personnel. If you need to utilize any section of the network for pumping into injection pads or pumping out from any pad to injection pads, communicate this first to the frac/flow back personnel. For your water needs at injection pads, coordinate this with frac/flowback personnel. B. When there is no special operation, the network should be operated at regular regime. C. All operations (operation/cleaning and water pumping etc.) must be carried out with the designated personnel and appropriate controls in place. D. Finally, and most importantly, for any safety/environmental issues (e.g., spillage or leakages) immediately contact your immediate supervisor who in turn shall contact Ursa and offer your best assistance to minimize the impact from the incident to people, environment and assets. If your immediate supervisor or Ursa personnel cannot be reached, please refer to the Emergency Contacts list in Section 3.4.1 of this SPCC Plan for alternate contacts. PLEASE DO NOT LEAVE A VOICEMAIL, talk to the contact directly. *Note: All of the above situations can also be identified through manually shutting water skid off, and seeing if any gas is blowing to the production tanks Ursa Operating Company LLC Appendix E STANDARD OPERATING PROCEDURE FOR REMOVING PRODUCTION WATER FROM TANKS 1.0 SCOPE • This document is to assure competency in operators that they can safely perform the task of pulling liquids form a production and properly disposing of the liquids. 2.0 REQUIREMENTS • Review and understand Ursa' s SOP along with the water hauling companies SOP on pulling liquids form a production tank and proper disposal. • Review and understand all Ursa' s requirements for being on location 3.0 APPLICABLE DOCUMENTS • Ursa Spill Notification & Management Protocol 4.0 MATERIALS AND EQUIPMENT • Gas monitor that is up to date on calibration. • Tank Strap • Color Kut 5.0 SAFETY AND ENVIRONMENT • Proper PPE — FRC' s, hard hat, safety glasses, steel -toed boots, gloves. 6.0 PROCEDURE • Pull onto location - Stop at entrance and observe for any unusual conditions, report anything to supervisor immediately! Proceed onto location to containment ring or tank farm if conditions allow. • Strap/Gauge tank- Use of color kut is required to know exactly what the interface is. Do not pull any condensate out of the tank unless instructed to do so. • Back truck to containment ring or berm -Stay 10 feet away to prevent damage to containment ring or berm! • Hook up process — Follow water hauling company's SOP on hooking up/disconnecting hoses. • Pull liquids from tank- Pull the calculated liquids from the tank. • Observe- Inspect truck, connections, fittings, valves, containment ring for holes in the liner and note on the field ticket. If it is a major issue call supervisor immediately. • Strap/Gauge tank- After liquids have been pulled strap tank again for accuracy, using color kut once again to make sure no condensate had been pulled. • Record- Record all information on field ticket (Tank #, 1St and 2nd straps, seal #'s and any other notes. Leave ticket in mail box or bull plug. • Transport- Transport any liquids pulled to the facility instructed by your supervisor. • Disposal- On arrival at any disposal facility, stop and observe any unusual conditions, report to supervisor immediately. Follow all rules and SOP's of that facility and water hauling companies SOP on unloading, proceed with caution. (Follow any instructions given by the facility operator). • Departing- When ready to depart from facility inspect truck and surroundings for leaks, open valves, or anything unusual. Report to supervisor for next destination. End of procedure Ursa Operating Company LLC Appendix E STANDARD OPERATING PROCEDURE FOR PRODUCED FLUID TRANSFERS TO TANKS 1. Initial Tank Inspection — Valves and Overflow (Gooseneck) Caps A. Prior to any fluid transfers, the water handling contractor will perform an initial inspection of the tanks to confirm that all valves on tanks are closed and that the overflows (gooseneck) have caps. B. Initial inspection includes the valve which is located at the back of the tank in front of the wheel axles. C. All man hatches will be inspected to confirm that they are tight. 2. Initial Tank Inspection to Confirm Tank Fluid Levels A. Prior to any fluid transfers, identify the full tanks and the empty tanks. B. Tanks with closed thief hatches located at the top of the stairs are considered full. These tanks can't accept produced fluids. All tanks with produced water should have a closed thief hatch and locked. C. Fluid Gauges Don't Work — Check tank status prior to pumping or transferring fluids. D. Make sure that your tank has room before you begin unloading! 3. Visual Tank Inspection after Fluid Transfer Begins A. Visually check each tank for leaks (valves, overflow/gooseneck caps) immediately after tank filling begins. B. Continue watching the tank until your truck is completely unloaded. C. Tank fluid transfers are immediately stopped if a leak is found or tank is overfilled. 4. Spill Reporting and Cleanup A. If a spill occurs the contractor/driver will contact their immediate supervisor. B. Contractor will stop all fluid transfers during a spill event. C. Truck driver will reverse his pump and begin vacuuming up the free liquids that spilled if transfer by truck. 5. Final Inspection after Fluid Transfer is Completed A. Confirm that tank flex hose is drained of fluids prior to disconnecting the hose from the tanks — Do Not Drain Liquids on the Ground. B. For pipeline fluid transfers, flex hoses must be left connected to the manifold in front of the frac tanks — Flex hoses should not be disconnected. C. Contractor will close the tank thief hatches on the tanks that are full to prevent overfilling. Ursa Operating Company LLC Appendix E FLOWLINE MAINTENANCE PROGRAM Flowlines and piping at production facilities can be sources of releases. The quantity and rates of such events will vary according to failure mode, operating pressures, current production rates, and duration of the release. Flowlines and intra -facility gathering lines and associated valves and equipment are compatible with the type of production fluids, their potential corrosivity, volume and pressure, and other conditions expected in the operational environment. The majority of the piping in the field is constructed of steel and was installed in 2009 or later. Flowlines are powder coated and/or painted. The steel lines all have cathodic protection. The pressure lines operate between 0 to 600 pounds per square inch (psig), they were designed for 0 to 1440 psig. Flowline construction materials are corrosion resistant to condensate, crude oil, and produced water. Flowlines are sized appropriately for the flow volumes expected at the facility. Aboveground flowlines and associated appurtenances are visually inspected during the pumper's regularly scheduled site visits for leaks, oil discharges, corrosion, or other conditions that could lead to a discharge as described in 40 CFR 112.1(b). Inspection of conditions associated with buried flowlines is accomplished by observing the ground surface above the lines for evidence of leaks on a monthly basis. Records of the inspections are stored at the Rifle Field Office and the corporate office in Denver. Buried flowlines are also inspected whenever they are exposed. Metallic lines have a cathodic protection system which is monitored as deemed necessary. High density polyethylene (HDPE) lines are operated at or below the recommended pressure and pressure tested on a regular basis to check their integrity. Per COGCC Rule 1101.e. "...Pressure tests shall be repeated once each calander year to maximum anticipated operating pressure, and operators shall keep records for at least 3 years...flowlines operating at less than 15 psig are exempted from testing." Appropriate corrective actions or repairs are made to any flowline, intra -facility gathering line, or associated appurtenances if evidence of a discharge is present. Evidence of a discharge includes product that has surfaced above the flowline. Suspected releases, including significant loss of pressure in the line or significant reduction in product recovered in the production tanks will be investigated. In the event a leak is discovered, the lines will be replaced with pipe constructed of appropriate materials. All repaired or replaced flowlines are pressure tested prior to being put into operation. Actions are initiated promptly to stabilize and remediate any accumulations of oil discharges associated with flowlines, intra -facility gathering lines, and associated appurtenances. Ursa Operating Company LLC Appendix E Releases are reported to the appropriate supervisor and cleanup personnel upon discovery. Oil and impacted media are removed or remediated as soon as practicable. Ursa Operating Company LLC Appendix F APPENDIX F WRITTEN COMMITMENT OF MANPOWER Written Commitment to Manpower, Equipment, and Materials In addition to implementing the preventive measures described in this Plan, Ursa will also specifically: • In the event of a discharge: i_ Make available all trained personnel and contractors to perform response actions ii. Collaborate fully with local, state, and federal authorities on response and cleanup operations • Maintain on-site oil spill control equipment. • Maintain all communications equipment in operating condition at all times. • Ensure that facilities are accessible. • Review the adequacy of on-site and third -party response capacity with pre- established response/cleanup contractors on an annual basis and update response/cleanup contractor list as necessary. • Maintain formal agreements/contracts with response and cleanup contractors who will provide assistance in responding to an oil discharge and/or completing cleanup. Dwayne Knudson, Senior Environmental Specialist th Name and Title; Signature: ),- IZ -tS Date: