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HomeMy WebLinkAbout3.3.11 Spill Prevention Control, Countermeasures & Response PlanParachute Integrated Spill Prevention, Control, And Countermeasures Plan Prepared for: Valley Business Unit Williams Production RMT Company 1058 County Road 215 Parachute, Colorado 81635 Date: September 2009 Prepared By: Fox Engineering Solutions LLC 670 Canyon Creek Drive, Grand Junction, CO 81507 •—G _ r Ph: (970) 250-5505 / Fax: (626) 784-0667 Email: coloradofox@bresnan.net Williams Production RMT Company Parachute Integrated SPCC Plan Table of Contents Table of Contents MANAGEMENT APPROVAL PROFESSIONAL ENGINEER CERTIFICATION 2 4 5 Part 112.1 General Applicability & Introduction 6 Part 112.3 Requirement to Prepare and Implement a SPCC Plan 8 Part 112.4 Amendment of SPCC Plan by the Regional Administrator 8 Part 112.5 Amendment of SPCC Plan by the Owner or Operator 9 Part 112.6 Qualified Facilities Plan Requirements 10 Part 112.7 General Requirements for SPCC Plans 10 Part 112.7(a)(1) & (a)(2) SPCC Plan Conformance 12 Part 112.7(a)(3) Facility Layout 12 Part 112.7(a)(3)(i) 011 Storage Capacity 12 Part 112.7(a)(3)(ii) Discharge Prevention Measures 13 Part 112.7(a)(3)(iii) Discharge and Drainage Controls 13 Part 112.7(a)(3)(iv) Countermeasures for Discharge Discovery, Response & Cleanup 14 Part 112.7(a)(3)(v) Disposal of Recovered Material 15 Part 112.7(a)(3)(vi) Contact List and Phone Numbers 15 Part 112.7(a)(4) 011 Discharge Information and Procedures 16 Part 112.7(a)(5) Oil Discharge Information and Procedures 16 Part 112.7(b) Prediction of Oil Discharge Quantity and Direction 16 Part 112.7(c) Discharge Containment and Diversionary Structures 16 Part 112.7(d) Practicality of Structures 17 Part 112.7(e) Inspections, Test, and Records 18 Part 112.7(f) Personnel Training and Discharge Prevention Procedures 18 Part 112.7(g) Security 18 Part 112.7(h) Facility Tank Car Loading/Unloading Rack 18 Part 112.7(i) Brittle Facture Analysis 19 Part 112.7(j) State Requirements 19 Part 112.7(k) Qualified Oil Filled Operational Equipment i9 Part 112.8 SPCC Requirements for Onshore Non -Production Facilities 20 ' Part 112.9(a) Onshore Oil Production SPCC Requirements 20 Part 112.9(b) 011 Production Facility Drainage 20 Part 112.9(c) Onshore Oil Production Facility Bulk Storage Containers 21 Part 112.9 (d) Facility Transfer Operations 23 Part 112.10 Drilling and Workover Facilities 23 Fox Engineering Solutions LLC September 2009 Page 2 Williams Production RMT Company Parachute Integrated SPCC Plan Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Plan Review and Documentation SPCC Plan Revisions Log Five -Year Documentation Review Oil Spill Response Procedures Spill Prevention and Response Plan, dated Dec. 2007 Inspection Records and Procedures Procedures and Responsibilities Annual Flowline Inspection Checklist Annual Facility Data and Inspection Checklist Containment Release Documentation Annual SPCC Inspection Facility List Records of Annual Discharge Prevention Briefings and Training Oil Handling Personnel Training Documentation General Training Outline Facility Specific Data Facility Name SPCC Facility Specific Details Facility Substantial Harm Determination Form Facility Location Map SPCC Facility Plot Plan Secondary Containment Details Prediction of Discharge Quantity and Direction Storm Water Management Plan Reference Fox Engineering Solutions LLC September 2009 Page 3 Williams Production RMT Company Parachute Integrated SPCC Plan MANAGEMENT APPROVAL The Parachute Integrated Spill Prevention Control and Countermeasures Plan is fully supported by the management of Williams Production RMT Company and will be implemented as described herein; reviewed at least once every five years, as required by 40 CFR Part 112.5 (b); and will be amended, as required by 40 CFR Part 112.5 (a), when there is a change in the facility design, construction, operation or maintenance that materially affects its ability to discharge oil. The SPCC Management Representative is the Designated Person accountable for Oil Spill Prevention at the facilities included in this integrated SPCC Plan and has the authority to commit the necessary resources to implement this Plan. Management will, as part of this Plan, incorporate the requirements outline below in the referenced plan sections. Authorized Facility SPCC Management Representative and Facility Response Coordinator: z�f - %4, /3/e,'/ r/Y. Management Signature Date Mr. Robert Bleil, Valley Business Unit, Principal Regulatory Specialist Management Review: Date: Name: Signature: Date: Name: Signature: Date: Name: Signature: Fox Engineering Solutions LLC September 2009 Page 4 Williams Production RMT Company Parachute Integrated SPCC Plan PROFESSIONAL ENGINEER CERTIFICATION The undersigned Registered Professional Engineer attests that he is familiar with the requirements of Part 112 of Title 40 of the Code of Federal Regulations (40 CFR Part 112) and has visited and examined the facility, or has supervised examination of the facility by appropriately qualified personnel. The undersigned Registered Professional Engineer attests that this Spill Prevention, Control, and Countermeasure Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards and the requirements of 40 CFR Part 112; that procedures for required inspections and testing have been established; and that this Plan is adequate for the facility. [40 CFR Part 112.3(d)] This certification in no way relieves the owner or operator of the facility of his/her duty to prepare and fully implement this SPCC Plan in accordance with the requirements of 40 CFR Part 112. This Plan is valid only to the extent that the facility owner or operator maintains, tests, and inspects equipment, containment, and other devices as prescribed in this Plan. David J. Fox, PE Fox Engineering Solutions LLC David J. Fox, P.E. Professional Engineer, State of Colorado Registration No. 25420 Date September 2009 Page 5 Williams Production RMT Company Parachute Integrated SPCC Plan Title 40 Code of Federal Regulations Part 112 Spill Prevention, Control and Countermeasures Plan Part 112.1 General Applicability & Introduction The Valley Business Unit of Williams Production RMT Company develops, operates and manages a number of oil and produced water storage sites associated with natural gas and oil resources activities in Garfield County of western Colorado. As part of the natural gas extraction process, oil and produced water are separated from the gas and stored aboveground at individual well pad sites in aggregate quantities greater than 1,320 gallons (excluding containers of less than 55 -gallons). These storage sites are considered non - transportation related onshore oil production facilities. Consequently, Williams Production RMT is required to develop, implement and maintain a Spill Prevention, Control and Countermeasure Plan (SPCC) under Title 40, Code of Federal Regulations, Part 112 (40 CFR Part 112) administered by the U.S. Environmental Protection Agency. These oil storage sites are generally located on well pads and although geographically separated, have common development and operational configurations; and similar equipment including, but not limited to; temporary drill rigs with completions and support operations; oil/water separators, oil and/or produced water storage tanks and pits, and transfer flowlines. For the purposes of this SPCC plan, an oil storage site at an individual well pad, as described above, is defined as a "facility", pursuant to 40 CFR Part 112.2 — Definitions. Numerous facilities are included as part of, and under the Parachute Integrated Spill Prevention Control and Countermeasures Plan. Individual facilities are defined and included in this Plan along with their locations, site diagrams, equipment and tanks, Substantial Harm Determinations, and speck information in Appendix E. Additional facilities will be added to this Plan as deemed applicable and as they become operational subject to certification by a professional engineer. The Valley Business Unit of Williams Production RMT Company also operations several compressor stations, gas processing plants and water management facilities. These facilities have implemented SPCC plans independent of the Parachute Integrated SPCC Plan and are not included in the integrated SPCC Plan. In addition, independent drilling, completion and workover contractors are required by Williams to implement SPCC plans, if applicable, specific to their contractor operations. The purpose of this integrated SPCC Plan is to describe measures implemented by Williams Production RMT Company to prevent oil discharges from occurring and to prepare Williams to respond in a safe, effective, and timely manner to mitigate the impacts of a potential discharge. This Plan addresses relevant spill prevention, control, and countermeasures necessary and common to each facility. This Plan has been prepared to meet the requirements of 40 CFR Part 112, and including amendments to the regulations published in the Federal Register on July 17, 2002, and Fox Engineering Solutions LLC September 2009 Page 6 Williams Production RMT Company Parachute Integrated SPCC Plan December 26, 2006. Paragraph citations referenced in the plan refer to Title 40 Code of Federal Regulations Part 112. In addition to fulfilling requirements of 40 CFR Part 112, this SPCC Plan is used as a reference for oil storage information and inspection records, as a tool to communicate practices on preventing and responding to discharges with employees as a guide to facility inspections, and as a resource during emergency response. Williams Production RMT Company management has determined that each facility, under the Parachute Integrated SPCC Plan, does not meet the substantial harm criteria specified in 40 CFR Part 112.20. Completed "Substantial Harm Determination" forms are included for each facility in Appendix E of this Pian. This Plan provides guidance on key actions Williams must perform to comply with the SPCC rule: D Complete annual site inspections as outlined in the Inspection Records and Procedure section of this Plan using the inspection checklists included in Appendix C. D Perform preventive maintenance of equipment, secondary containment systems, and discharge prevention systems described in this Plan as needed to keep them in proper operating conditions. D Conduct annual employee training as outlined in the Records of Annual Discharge Prevention Briefings and Training of this Plan and documentation included in Appendix D. D If either of the following occurs, submit the SPCC Plan to the EPA Region 8 Regional Administrator (RA) along with other information as detailed in the Oil Spill Response Procedure of Appendix C of this Plan: • The individual facility discharges more than 1,000 gallons of oil into or upon the navigable waters of the U.S. or adjoining shorelines in a single spill event; or • The individual facility discharges oil in quantity greater than 42 gallons in each of two spill events within any 12 -month period. D Review the SPCC Plan at least once every five (5) years and amend it to include more effective prevention and control technology, if such technology will significantly reduce the likelihood of a spill event and has been proven effective in the field at the time of the review. Five-year reviews will be documented Five -Year Review Documentation form in Appendix A. D Amend the SPCC Plan within six (6) months whenever where is a change in an individual facility design, construction, operation, or maintenance that materially affects the facility's spill potential. Technical changes will be documented in the Plan Review Fox Engineering Solutions LLC September 2009 Page 7 Williams Production RMT Company Parachute Integrated SPCC Plan Log in Appendix A of this Plan. Technical changes to the Plan wIl be recertified by a Professional Engineer (PE) and the certification inserted into the Plan. D Review the Plan on an annual basis. Update the Plan to reflect any "administrative changes" that are applicable, such as personnel changes or revisions to contact information, such as phone numbers. Administrative changes will be documented in the Plan review log of Section of this Plan, but do not have to be certified by a PE. Part 112.3 Requirement to Prepare and Implement a SPCC Plan The Parachute Integrated SPCC Plan has been prepared in accordance with the provisions of 40 CFR Part 112 as amended in the Federal Register on July 17, 2002 and December 26, 2006. The plan has been reviewed and certified by a registered professional engineer per the provisions of Part 112.3(d). This certification in no way relieves the owner or operator of the facility of his/her duty to prepare and fully implement this SPCC Plan in accordance with the requirements of 40 CFR Part 112. This Plan is valid only to the extent that the facility owner or operator maintains, tests, and inspects equipment, containment, and other devices as prescribed in this Plan. The facilities included in this integrated plan are not normally attended, except during drilling activities, for more than four hours per day, therefore complete copies of this plan are maintained at the Williams Production RMT Company field offices located in Parachute, Colorado. During drilling activities, copies of the SPCC Plan will be located at the facility. Drilling, completion and workover services are provided to Williams through independent contractors. As part of their master services agreements with Williams, independent contractors are required to comply with local, state and federal regulations. This includes preparation of SPCC plans and spill response training, as applicable, specific to contractor operations at each facility. The plan is available to the EPA Regional Administrator and others during regular business hours. The individual facilities included in the Parachute Integrated SPCC Plan do not meet the criteria of a "Qualified Facility" as defined in Part 112.3(g) and will not be self -certified. Part 112.4 Amendment of SPCC Plan by the Regional Administrator Pursuant to Part 112.4(a), Williams shall notify the Regional Administrator of individual facility discharges greater than 1000 U.S. gallons of oil in a single discharge or more than 42 U.S gallons in two incidents occurring within any 12 month period. Notifications to the Regional administrator shall include; • Name of Facility. • Owner or Operator of Plan. Fox Engineering Solutions LLC September 2009 Page 8 Williams Production RMT Company Parachute Integrated SPCC Plan • Location of the Facility. • Maximum storage and handling capacity of the facility and daily throughput. • Corrective actions and countermeasures taken including a description of equipment repairs and replacements. • An adequate description of the facility, including maps, flow diagrams, and topographical maps as necessary. • The cause of such discharge as described in Part 112.1(b), including a failure analysis of the system or subsystem in which the failure occurred. • Additional preventative measures taken or contemplated to minimize the possibility of reoccurrence. • Other information as the Regional Administrator may reasonably require pertinent to the plan or discharge. Discharge notifications shall be made in accordance with the Oil Spill Response and Procedures included in Appendix B. Part 112.5 Amendment of SPCC Plan by the Owner or Operator Williams Production .RMT will amend this Plan in accordance with the general requirements of Part 112.7, when there is a change to an individual facility design, construction, operation, or maintenance that materially affects its potential for a discharge. Examples of technical changes that may require an amendment include, but are not limited to • commissioning or de -commissioning of storage containers • replacement, reconstruction, or movement of storage containers • reconstruction, replacement, or installation of piping systems • construction or demolition of that might alter secondary containment structures • changes of product or service • revision of standard operation and maintenance procedures Non-technical amendments include the following: • changes in the name or contact information (i.e., telephone numbers) of individuals responsible for the implementation of this Pian; or • changes in the name or contact information of spill response or cleanup contractors. Williams will amend this Plan within 6 months of individual facility changes that affect its potential for discharge and will implement any amendments as soon as possible, but not later than six months following preparation of any amendment. Williams will complete a review and evaluation of this Plan at least once every five years. As a result of this review and evaluation, the plan will be amended within six months of the review to include more effective prevention and control technology, if the technology has been field -proven at the time of the review and will significantly reduce the likelihood of a discharge from the facility, as described in Part 112.1(b). Williams will implement any amendment as soon as possible, but not later than six months following preparation of any Fox Engineering Solutions LLC September 2009 Page 9 Williams Production RMT Company Parachute Integrated SPCC Plan amendment. The review and evaluation will be documented and signed along with a statement as to whether the plan will be amended and will be documented Five Year Review form in Appendix A. All amendments, both technical and non-technical, shall be documented in the SPCC Plan Revision Log in Appendix A. A Professional Engineer shall certify any technical amendments to this Plan in accordance with Part 112.3(d). The amendments will be documented in Appendix A and a new Professional Engineer certification page shall be inserted into the Plan document. Part 112.6 Qualified Facilities Plan Requirements The individual facilities within the Parachute Integrated SPCC Plan do not meet the criteria of a "Qualified Facility" as defined in Part 112.3(g). Williams Production RMT Company is not self -certifying this Plan. Part 112.7 General Requirements for SPCC Plans This Plan has been prepared in accordance with good engineering practices with full approval by Williams' management at a level of authority to commit the necessary resources to fully implement this plan. Management Approval & Commitment and Professional Engineer's certifications are provided in this plan. Name and Address of Operator: Williams' Primary Contact & SPCC Representative: Williams' District Manager: Valley Business Unit Williams Production RMT Company Parachute District Field Office 1058 County Road 215 Parachute, CO 81635 Robert Bleil Principal Regulatory Specialist Valley Environmental Team Lead 1058 County Road 215 Parachute, CO 81635 Phone: (970) 263-9377 Cell: (970) 210-2050 Steve Soychak District Manager 1058 County Road 215 Parachute, CO 81635 Phone: (970) 263-9377 Cell: (970) 216-0922 Fox Engineering Solutions LLC September 2009 Page 10 Williams Production RMT Company Parachute Integrated SPCC Plan This section of the Plan complies with and follows the sequence of Part 112.7 and does not deviate from those requirements. No supplemental cross-references are necessary. The individual facilities included in this Plan are situated in Garfield County of Colorado. Individual facilities location maps are attached in Appendix E. Additional facilities will be added to this Plan as deemed applicable and as they become operational subject to certification by a professional engineer through the provisions of Part 112.5 - Amendment of SPCC Plan by the Owner or Operator. These facilities store natural gas liquids commonly referred to as oil or condensate and produced water. For the purposes of this Plan only, untreated produced water is considered an oil because it may contain an oil/produced water mixture. Individual facilities generally consists of natural gas well heads; flowlines and piping; three-phase separators also referred to as production units; piping systems; dehydrators; American Petroleum Institute (API) shop -fabricated steel above ground tanks, meters and cathodic protection equipment. In some cases, individual facilities may also store produced water in pits, lined with impervious synthetic materials, compatible with produced water and suitable for site climatic factors. During the drilling, workover and completion phases of natural gas well development, temporary oil/water/sand separators, hydraulic fracturing water tanks and bulk storage containers are placed at the facilities. Individual facilities and their specific characteristics are indentified in Appendix E. The individual facilities within the Parachute Integrated SPCC Plan are located in the valley area of the Colorado River or the adjacent slopes at elevations varying from approximately 5000 ft. to 7000 ft., mean sea level. The Colorado River along with perennial, intermittent streams and ephemeral drainages predominate the area. Individual facility oil storage tanks and equipment are typical constructed at level grade with the adjacent terrain varying considerably. There are a wide variety of soil types and slopes found in the Parachute field. The Natural Resources Conservation Service rates erosion potential on a scale of 0.02 (low erodiblity) to 0.69 (extremely erodible). Predominant soil types within the Parachute Field include: Soil Types Slopes Erosion Potential Arvada loam 1-20% .37 Bucklon-Inchau loams 25-50% .24 Cochetopa loam 9-50%. .20 Ildefonso stony loam 6-45% .28 Potts-Ildefonso complex 3-45% .28 Potts loam 6-12% .28 Parachute -Rhone loams 5-30% .20 Torriorthents, Camborthids, steep to very steep Null Fox Engineering Solutions LLC September 2009 Page 11 Williams Production RMT Company Parachute Integrated SPCC Plan The Parachute Field includes a variety of vegetative cover types. Prominent vegetation includes pinyon and juniper woodlands with understory grasses and desert shrub communities, with minor areas of irrigated agriculture hayfields of alfalfa and smooth brome. NRCS describes flooding frequency and ponding potential as "none" to 'occasional" for the area. Annual precipitation averages 17 inches. Floodplains are located within the area of these facilities. Part 112.7(a)(1) & (a)(2) SPCC Plan Conformance This section of the Plan complies with and follows the sequence of Part 112.7 and does not deviate from those requirements. These facilities are also considered onshore oil production facilities and meet the requirements of Part 112.9 — SPCC Plan Requirements for Onshore Oil Production Facilities. Part 112.7(a)(3) Facility Layout The individual facilities within the Parachute Integrated SPCC Plan are located in portions of Garfield County in western Colorado. Facilities are shown on their location maps attached in Appendix E. Typically at each facility, underground flowlines convey a 3-phase fluid consisting of natural gas, oil/condensate and produced water, from the wellheads to three-phase separators. Condensate and produced water are separated at this point into their individual components and piped underground to their respective aboveground condensate or produced water tanks or lined pits. Variations to this typical facility description can occur at each individual facility. Specific individual facility layouts or schematics and container descriptions within the Parachute Integrated SPCC Plan are provided in Appendix E. During the drilling, workover and completion phases of natural gas well development, ,temporary oil/water/sand separators, hydraulic fracturing water tanks and bulk storage containers are placed at the facilities. These operations typically take 3 to 12 months. Layout diagrams will be provided for each facility in Appendix E during active drilling and completion phases of development along with locations of the secondary containment berms. Provisions for drilling, workover and completion development are provided in Parts 112.7, 112.9 and 112.10. Part 112.7(a)(3)(i) Oil Storage Capacity Detailed descriptions of each individual facility oil storage location are provided, listing the type of oil present and capacity of each tank, in Appendix E. Fox Engineering Solutions LLC September 2009 Page 12 Williams Production RMT Company Parachute Integrated SPCC Plan Part 112.7(a)(3)(ii) Discharge Prevention Measures Discharge prevention is provided through a number of methods including training of oil field personnel, annual inspections, regular maintenance and repair, and observations by oil field personnel. Facility inspection and maintenance procedures are included in Appendix C. All storage tanks, piping systems, flow-through vessels, valves and appurtenances have been designed using best engineering practices to minimize discharge potential. The exterior of all underground piping is coated with a protective material to reduce corrosion potential. All oil and produced water storage tanks are steel, shop -built and meet industry standards such as the American Petroleum Institute (API) tank construction standard. Piping and container design and their construction are compatible with the oil they contain and the temperature and pressure conditions of storage. Each storage tank is inspected per the procedures provided in Appendix C for deterioration and maintenance needs, including the foundation and support of each storage tank. Storage tanks are provided with secondary containment and, in selected cases, equipped with high-level alarms that are connected to an integrated computer telemetry system. Exposed steel tanks, piping, and all associated components are painted to reduce corrosion. Steel tanks are cathodically protected. Produced water storage pits are lined with impervious synthetic materials compatible with produced water and suitable for site climatic factors. Pits are constructed and monitored to the standards required by the State of Colorado in the 900 Series Rules of the Colorado Oil and Gas Commission. Part 112.7(a)(3)(iii) Discharge and Drainage Controls Primary discharge controls for the individual facilities within this Plan are provided with secondary containment for condensate and produced water tanks, still -vent tanks whose capacity is 55 -gallons or greater, and with the use of drip buckets at truck loading/unloading conveyance hose locations. The secondary containment structures consist of both earthen berm and synthetically lined walled structures sized to accommodate the largest tank volume within the containment area and expected precipitation. For the purposes of this ,Plan, precipitation contributions are based upon the 25 -year 24-hour precipitation event as estimated by National Oceanic and Atmospheric Administration (NOAA). Secondary containment is adequate to protect against the release of oil to waters of the United States until cleanup can occur. Any deficiencies in required secondary containment will be corrected prior to the required SPCC implementation date, currently November 10, 2010. Discharges of precipitation from secondary containment structures are not anticipated in this Plan. Average net evaporation for this facility location, as estimated from National Oceanic and Atmospheric Administration (NOAA) data, is approximately 28 inches annually. The NOAA data also indicates that the 25 -year 24-hour precipitation event is 2.4 inches for the plan area. Based on these climatic factors, discharge releases from secondary containment are not expected. Fox Engineering Solutions LLC September 2009 Page 13 Williams Production RMT Company Parachute Integrated SPCC Plan All transfer operation of oil and produced water to tanker trucks are conducted under continuous manned supervision. Load buckets and drip pans minimize spill potential at each facility. Shut-off valves are accessible and can be activated in a matter of seconds. Tanker trucks are equipped with spill kits and shovels to contain spills until clean up can be initiated. Truck personnel are requested to follow, at a minimum, best management practice procedures outlined below. • Before pulling up to tank, turn off all lights, two-way radios, etc. • Extinguish all smoking materials. • Pull up to tank slowly, positioning truck correctly for tank loading. • Shut off motor. • Place ground -chocks between duels and place ground cable onto unit. • Place drip pans under all pump hose fittings prior to loading. • Check that a functioning fire extinguisher is in place. • Connect hoses and open valves. • Initiate unloading. • Observe the tank gauge to confirm its operation during loading. • Terminate unloading prior to overfilling the tanker. • Close valves, disconnect and stow hoses. • Empty the drip -pan's contents into the provided container. Return drip pans. • Remove and stow ground -chocks and disconnect and stow ground cable. • Confirm that all hoses and connections are removed and safely stowed. • Start motor and pull away slowly from the loading area. Site drainage runoff and runon are controlled with best management practices under a formalized Storm Water Management Plan permitted by the State of Colorado under Storm Water Management Plan, general conditions Permit #COR 38,541, issued by the Colorado Department of Public Health and Environment. These plans employ best management practices to reduce and eliminate both runoff from the site and runon to the site. Specific Storm Water Management Plans are referenced in Appendix F and incorporated into this Plan. Part 112.7(a)(3)(iv) Countermeasures for Discharge Discovery, Response & Cleanup Discovery of discharges at the individual facilities is expected through a number of means including routine site inspections, maintenance and operational activities. In selected cases, oil tank storage levels are also continuously monitored by remote telemetry at each site. Sudden drops in tank and produced water pit contents levels are monitored and investigated immediately. It is Williams' policy that its employees and contractors are trained in spill prevention and response plan implementation to avoid and minimize the potential for spills and releases in the exploration and development of natural gas resources, in accordance with Federal and state regulations. Williams' response personnel are trained and provided with equipment Fox Engineering Solutions LLC September 2009 Page 14 Williams Production RMT Company Parachute Integrated SPCC Plan and supplies to respond to oil discharges. Appendix B contains oil spill response procedures incorporated into this Plan. Williams maintains a Spill Response Station in the Parachute area equipped with materials such as absorbent pads, booms, plastic sheeting, tyvek overalls, shovels, 55 -gallons drums and a number of other supplies necessary for cleanup activities. The location and a detailed list of equipment and supplies maintained at the stations are provided in the Oil Spill Response and Procedures included in Appendix B. If additional manpower or equipment is needed for cleanup or mitigation activities, the Oil Spill Response and Procedures provides a list of contactors on retainer with Williams to provide service in emergencies. Cleanup activities are to be conducted in accordance with all state, local and federal requirements. Activities or mitigation involving waters of the United States, will adhere to the provisions of U.S. Army Corps of Engineers' Permit requirements. All drilling and completion phases are manned and continuously monitored. Spill kits are maintained onsite during these phases and all spills are cleaned and remediated immediately. Routine visual examinations are made of the perimeter berm by onsite personnel. Under the Storm Water Management Plans, formal documented inspections are conducted by third party compliance contractors every 14 days and after every significant precipitation event. After construction activities have ceased and interim reclamation established, Storni Water Management Plan inspections occur every 30 days for the duration or life with the natural gas wells. Work orders are issued by the storm water compliance personnel for inspection deficiencies and promptly rectified. Part 112.7(a)(3)(v) Disposal of Recovered Material Contaminated materials that are recovered during cleanup efforts will be disposed in accordance with all applicable regulations including on site remediation as directed by the Colorado Oil and Gas Conservation Commission and, if on federal properties, the U.S. Bureau of Land Management. Williams' EH&S department will provide further direction on specific disposal and treatment options. Recovered oil/condensate and produced water shall be placed in suitable storage containers, labeled for recycling or disposal in accordance with applicable regulations. Uncontaminated oil/condensate and produced water may be returned to the system. Part 112.7(a)(3)(vi) Contact List and Phone Numbers The contacts list for all spill response activities is located in Appendix B — Oil Spill Response Procedures. Fox Engineering Solutions LLC September 2009 Page 15 Williams Production RMT Company Parachute Integrated SPCC Plan Part 112.7(a)(4) Oil Discharge Information and Procedures 011 discharge reporting procedures and information required by a person reporting a discharge are provided in Appendix B — Oil Spill Response Procedures. Part 112.7(a)(5) Oil Discharge Information and Procedures Comprehensive oil and other fluid spill procedures, pursuant the SPCC rules, are provided in Appendix B. Part 112.7(b) Prediction of Oil Discharge Quantity and Direction Pursuant to the requirements of Part 112.7(b), potential equipment failures have been indentified within the Parachute Integrated SPCC Plan and may include; tank ruptures, leaks and overfilling; open or frozen tank valves; leakage, overtopping and breaching of secondary containment structures; piping leaks; and loading/unloading truck operations. Individual facility specific details are provided in Appendix E categorizing and predicting the direction of flow, rate of flow and total quantity of oil which could be discharged from individual facilities. Part 112.7(c) Discharge Containment and Diversionary Structures Secondary containment is provided for oil and produced water/oil mixtures storage tanks and separators at all facilities as discussed in paragraph Part 112.9(c) - Oil Production Facility Bulk Storage Containers. 011 and produced water secondary containment structures are sufficiently impervious to prevent oil escapement before cleanup occurs. Secondary containment structures include both earthen berm and lined walled structures. The secondary containment structures are configured with capacities to contain the largest tank volume plus at least a 25 -year 24-hour precipitation event. The NOAA data also indicates that the 25 -year 24-hour precipitation event is 2.4 inches for the Plan area. Soils shall be sufficiently compacted during construction at each facility to restrict ground seepage of discharges, until cleanup can occur. Any deficiencies in required secondary containment will be corrected prior to the required SPCC implementation date, currently November 10, 2010. Produced water pits are constructed to safely and structurally contain their fluids and precipitation associated with a 25 -year 24-hour event as estimated above. Containment is provided by installing competent synthetic liners resistant to chemicals, ultra -violet light and suitable for harsh environmental and climatic factors. The liners are installed per the manufacturer's installation and testing requirements. Pits are maintained with a minimum of two foot of freeboard at all times. Pits are also constructed and monitored to the standards required by the State of Colorado in the 900 Series Rules of the Colorado Oil and Gas Commission. Fox Engineering Solutions LLC September 2009 Page 16 Williams Production RMT Company Parachute Integrated SPCC Plan Flowlines at individual facilities within the Parachute Integrated SPCC Plan are protected from corrosion by pipe coatings and/or pipe wraps. Portions of the flowlines are buried on the site. After the third year of operations, flowline maintenance includes annual pressure tests, per industry standards, to insure structural integrity and prevent discharges. Regular inspections and testing outlined in Appendix C, are designed to prevent discharge escapement until cleanup can begin. During the drilling, completion and workover phases of natural gas well development, temporary oillwater/sand separators, hydraulic fracturing water tanks, bulk fuel containers and qualified oil -filled operational equipment are placed at the facilities. The largest container volume during this phase is 21,000 gallons. Secondary containment during these phases is provided with a well pad perimeter berm as part of a State Of Colorado's required Storm Water Management Plan. References to the Storm Water Management Plan are located in Appendix F and incorporated by reference into this Plan. Best management practices at each facility include a perimeter berm, as described below, to prevent escapement of all fluids from the facility and diversionary channels to prevent surface flows from entering the site. The temporary oil/water/sand separators, hydraulic fracturing water tanks, bulk fuel containers and qualified oil -filled operational equipment are located within the perimeter berms. These berms at each individual facility are, at minimum, one foot high and usually 18" to 24" high. Facility pad or operational area size varies, but at a minimum, is at least one acre in size. Utilizing one acre or 43,560 square feet times one foot of depth, the containment volume equates to 325,851 gallons. Based on largest separator/tank volume of 21,000 gallons and precipitation volume of 65,166 gallons, secondary containment is adequate to contain all of the water/oil from the separator/tank including other equipment's displacement volume and precipitation volume from a 25 -year 24-hour as estimated from NOAA Atlas 2, until cleanup can occur. Soils are compacted to be sufficiently impervious during construction at each site to restrict ground seepage of discharges until cleanup can occur. Perimeter berms are generally, but not in all cases, removed at the cessation of drilling, workover and completion operations. Drilling, completion and workover services are provided to Williams through independent contractors. As part of their master services agreements with Williams, independent contractors are required to comply with local, state and federal regulations. Contractors are required to implement SPCC plans, as applicable, specific to contractor operations at each facility. Part 112.7(d) Practicality of Structures This plan has deemed that the structures and pieces of equipment referenced in Part 112.7(d), and pertinent to this plan, are practical to this plan. Fox Engineering Solutions LLC September 2009 Page 17 Williams Production RMT Company Parachute Integrated SPCC Plan Part 112.7(e) Inspections, Test, and Records Annual inspections and testing outlines are provided in Appendix C for all oil storage tanks, separators, flowlines and produced water storage pits. Oil field handling personnel shall make routine visual examination of storage containers, equipment and piping during normal operational and maintenance visits. Visual examination deficiencies will be documented and reported on Annual Flowline Inspection Checklist in Appendix C. Signed and dated inspection records and other pertinent information including training shall be maintained and available for a period of a minimum of three years. Part 112.7(f) Personnel Training and Discharge Prevention Procedures All oil -handling field personnel will receive, at a minimum, annual training applicable to the operation and maintenance of equipment to prevent discharges, discharge procedures, applicable rules and regulations, general facility operations, and the contents of the SPCC Pian. The training shall include discharge prevention, the SPCC Plan, spills/discharges, malfunctions, failures, and other pertinent information. A training outline and attendance log are provided in Appendix D. The SPCC Plan Representative or designee reports to Williams Production RMT Company management and is accountable for discharge prevention; and conducting and scheduling discharge prevention training. The SPCC Representative or designee will make appropriate reports to the management Production Supervisor/EH&S Department upon discovery of a discharge at individual facilities. Part 112.7(g) Security Although this paragraph is not applicable to oil production facilities, the individual facilities are located in remote areas, accessible generally through private roads. Fences are constructed and maintained around well heads, production equipment and oil storage tanks. Individual facilities are evaluated by oil handling personnel for specific security measures. Part 112.7(h) Facility Tank Car Loading/Unloading Rack The facilities contained in this SPCC Plan do not have facility tank car loading/unloading racks, however transfer areas are present where oil/condensate and produced water is transferred from facility storage containers to tank trucks for transport. All truck transfer operations are manned. Spill kits and shovels are located in tanker trucks. Should a transfer hose or valve rupture or become disconnected, the spill potential volume has been calculated to be 112 gallons. This is based upon a discharge estimate of 675 gpm assuming the largest tank of 16,800 gallons is full with a head pressure of 20 feet. Details are provided in the "Prediction of Oil Spill Discharge Quantity and Direction" table in Appendix E for each facility. Spills will be retained onsite by the driver with the spill Fox Engineering Solutions LLC September 2009 Page 18 Williams Production RMT Company Parachute Integrated SPCC Plan kits/shovel until cleanup can occur. Appendix B contains oil spill response procedures incorporated into this Plan. Part 112.7(i) Brittle Facture Analysis The facilities in this plan do not utilize field -constructed aboveground containers and therefore, are not subject to this section of the SPCC rule. Part 112.7(j) State Requirements This SPCC Plan meets the State of Colorado, Division of Oil and Public Safety SPCC requirements; and conforms to the rules of the Colorado Oil and Gas Commission; and the conditions of the Storm Water Management Plans issued by the Colorado Department of Public Health and the Environment. Part 112.7(k) Qualified Oil Filled Operational Equipment During the drilling, workover and completion phases of natural gas well development, qualified oil -filled operational equipment may be temporarily located at individual facilities within the Parachute Integrated SPCC Plan. This equipment includes drilling and workover rigs, diesel -operated electrical generators, transformers, hydraulic fracturing pumping equipment and other pumping mechanisms. This equipment contains petroleum and oil, oily produced water, gear boxes, hydraulic fluids, lubricants, cooling system fluids, circuit breakers and electrical switches. Secondary containment for qualified oil -filled operational equipment is provided as part of the State Of Colorado's required Storm Water Management Plan for the site. A copy of the Storm Water Management Plans references are contained in Appendix F. Best management practices at each facility include a perimeter berm of the entire well pad to prevent escapement of all fluids from the facility and diversionary channels to prevent surface flows from entering the site. All oil -filled operation equipment is contained within the perimeter berms. These berms are a minimum of one foot high and usually 18" to 24" high. Well pad size varies, but at a minimum, is at least 1 acre in size. Utilizing 1 acre or 43,560 square feet times one foot of depth, the containment volume equates to 325,851 gallons. Based on familiarity with the drilling sites and the oil -filled equipment, the total amount of oil contained in all the oil -filled equipment does not exceed 25,000 gallons. Secondary containment is adequate to contain all of the oil from this equipment including the equipment's fluid displacement plus precipitation volume from a 25 -year 24-hour event estimated to be 65,166 gallons, until cleanup can occur. Fox Engineering Solutions LLC September 2009 Page 19 Williams Production RMT Company Parachute Integrated SPCC Plan All drilling and completion phases are manned and continuously monitored. Spill kits are maintained onsite during these phases and all spills are cleaned and remediated immediately. Under the Storm Water Management Plans, formal documented inspections are conducted by third party compliance contractors every 14 days and after every significant precipitation event. After construction activities have ceased and interim reclamation established, Storm Water Management Pian inspections occur every 30 days for the duration or life with the natural gas wells. Work orders are issued by the storm water compliance contractors for inspection deficiencies and promptly rectified. Daily visual examinations are made of the perimeter berm by onsite personnel. All qualified oil -filled equipment is removed after drilling and completion activities cease. Part 112.8 SPCC Requirements for Onshore Non -Production Facilities The individual facilities within the Parachute Integrated SPCC Plan are production facilities and therefore not subject to this section of the rule. Part 112.9(a) Onshore 011 Production SPCC Requirements This SPCC Plan meets the general requirements listed under section 40 CFR Part 112.7 and the specific discharge prevention and containment procedures of Part 112.9. Part 112.9(b) 011 Production Facility Drainage Discharges to the environment of precipitation from secondary containment structures are not anticipated in this Plan. Average net evaporation for this facility location, as estimated from National Oceanic and Atmospheric Administration (NOAA) data, is approximately 20 inches annually. The NOAA data also indicates that the 25 -year 24-hour precipitation event is 2.4 inches for the plan area. Based on these climatic factors, precipitation discharge releases from secondary containment is not expected. No penetrations, drain valves or permanent automatic pumps or ejector devices are present in secondary containment structures. If a secondary containment structures must be emptied, a vacuum truck is generally utilized. Prior to emptying the containment areas, accumulated precipitation shall be inspected by field personnel. If oil is noted on the accumulated precipitation it will be removed prior to draining the structure. Recovered product is to be placed back into appropriate storage container or disposed of in accordance with applicable local, state and federal regulation. All containment release events shall be recorded on the Containment Release Documentation form in Appendix C. Site drainage runoff and runon are controlled with best management practices under a formalized Storm Water Management Plan permitted by the State of Colorado under Storm Water Management Plan, general conditions Permit #COR 30,000, issued by the Colorado Fox Engineering Solutions LLC September 2009 Page 20 Williams Production RMT Company • Parachute Integrated SPCC Plan Department of Public Health and Environment. These plans employ best management practices to reduce and eliminate both runoff from the site and runon to the site. Specific Storm Water Management Plans are referenced in Appendix F and incorporated into this Plan. Under the Storm Water Management Plans, formal documented inspections are conducted at the facilities by third party compliance contractors every 14 days and after every significant precipitation event. After construction activities have ceased and interim reclamation established, Storm Water Management Plan inspections occur every 30 days for the duration or life with the natural gas wells. Work orders are issued by the storm water compliance contractors for inspection deficiencies and promptly rectified. All secondary containment structures are also inspected at annual intervals as outlined in Appendix C. Part 112.9(c) Onshore Oil Production Facility Bulk Storage Containers All tank batteries and separators are provided with secondary containment structures. Under the Storm Water Management Plans, formal documented inspections are conducted at the facilities by third party compliance contractors every 14 days and after every significant precipitation event. After construction activities have ceased and interim reclamation established, Storm Water Management Plan inspections occur every 30 days for the duration or life with the natural gas wells. Work orders are issued by the storm water compliance contractors for inspection deficiencies and promptly rectified. 011 and produced water storage tanks; three-phase separators and produced water storage pits have been designed and installed in accordance with good engineering practices. All oil storage tanks are shop -built and meet industry standards such as the American Petroleum Institute (API) tank construction standard. Their design and construction are compatible with the oil they contain and the temperature and pressure conditions of storage. Specific produced water storage pit details are also discussed in Part 112.7(c) and incorporated into this paragraph. Tank and pit capacities are adequate to assure that the oil storage containers will not overflow if the transportation truck is delayed in making regularly scheduled rounds. Oil and produced storage tanks and separators are enclosed within a secondary containment structure for the entire capacity of the largest tank and sufficient freeboard for precipitation. Secondary containment structures are field measured during each annual inspection. Calculated secondary containment requirements for individual facility are included in Appendix E. Deficiencies in required secondary containment will be corrected upon discovery. The secondary containment structures are constructed of either earthen materials or Tined walled structures to contain oil within the area until clean-up can occur. Earthen containment berms are composed of packed silty clay material, sufficiently compacted and, in some cases, completed with a gravel cover to provide protection from erosion. The secondary containment systems are maintained to prevent their integrity from being compromised by burrowing animals and vegetation. Any and all vegetation is removed Fox Engineering Solutions LLC September 2009 Page 21 Williams Production RMT Company Parachute Integrated SPCC Plan and deficiencies from burrows are promptly repaired. Specific secondary containment details are provided in Part 112.7(c) and incorporated by reference into this paragraph. Storage tanks and supporting foundations are visually inspected annually for deterioration and maintenance needs. Records of internal inspections are maintained as a part of the SPCC Plan, and included in Appendix C. Defective tanks are repaired or replaced. Secondary containment structures walls are elevated above grade to prevent surface drainage from entering the secondary containment areas. Oil storage containers will be periodically updated in accordance with accepted best engineering practices to prevent discharges. These improvements may include enhanced cathodic protection and non -corrosive tank liners. Pressure transducers, to monitor produced water storage pit levels, are being investigated for possible inclusion into future pit monitoring systems. Produced water pits are constructed to safely and structurally contain their fluids and precipitation associated with a 25 -year 24-hour event as estimated above. Containment is provided by installing competent synthetic liners resistant to chemicals, ultra -violet Tight and suitable for harsh environmental and climatic factors. The liners are installed per the manufacturer's installation and testing requirements. Pits are maintained with a minimum of two foot of freeboard at all times. Pits are constructed and monitored to the standards required by the State of Colorado in the 900 Series Rules of the Colorado Oil and Gas Commission. All facility oil and produced water storage sites are monitored through either telemetry system or gauging during routine operational visits. At selected sites, containers are equipped with high-level sensors actuated by a float switch or laser level indicators. Alarms are transmitted to the Williams Production RMT control system that notifies personnel that the tank must be emptied. Williams then dispatches a tanker truck to the facility. As a failsafe, the flowlines carrying oil liquids from the wellheads to the storage tanks can be closed remotely using the telemetry system. As a good engineering practice, tanks and pits capacities are sized to accommodate 90 days of oil/condensate and produced water volumes produced at the facilities. Flow production records and experience are used as the basis for scheduling routine visits to ensure that containers do not overflow. Skid -mounted bulk storage tanks are temporarily placed at facilities during drilling, workover and completion activities. These tanks are required to be shop -built to industry standards such as the American Petroleum Institute (API) tank construction standard. These tanks are temporary and are not cathodically protected. Their design and construction are compatible with the oil they contain and the temperature and pressure conditions of storage. Fox Engineering Solutions LLC September 2009 Page 22 Williams Production RMT Company Parachute Integrated SPCC Plan Part 112.9 (d) Facility Transfer Operations All aboveground valves, flange joints, drip pans, pipe supports, valve glands, appurtenances and piping associated with transfer operations shall be inspected semi-annually. Inspection forms are provided in Appendix C. When a pipe is not in service, for an extended period, the associated valves are to be kept closed and lines are bull plugged or blind flanged and marked as to the tie-in connection. There are no saltwater oil field brine disposal facilities within the Parachute natural gas field. Flowlines at individual facilities within the Parachute Integrated SPCC Plan are protected from corrosion by pipe coatings and/or pipe wraps. Portions of the flowlines are buried on the site. After the third operational year, flowline maintenance includes annual pressure tests to insure structural integrity and prevent discharges. An Inspection and testing form is provided in Appendix C. Non -recorded visual inspections and flowline diagnostics are performed several times weekly by field personnel to ensure structural integrity of the flowlines. Copies of all inspections and testing results shall be maintained for a period of three years. Defective flowlines are repaired or replaced. Part 112.10 Drilling and Workover Facilities Drilling and workover operations bulk storage containers meet the general requirements of Part 112.7 and as referenced in Part 112.9, and the specific discharge prevention and containment procedures listed under Part 112.7. Drilling and workover bulk storage containers are referenced and incorporated in both Part 112.7 and Part 112.9. Mobile drilling and workover equipment are placed within the perimeter containment berms as described in Part 112.7(c) to contain and prevent discharges into navigable waters of the United States or adjoining shorelines. The perimeter containment berms, as referenced in Part 112.7 and Part 112.9 and incorporated into this paragraph, are sufficient to intercept and contain discharges of fuel, crude oil or oily drilling fluids. Blowout prevention assemblies and control systems, capable of controlling well head pressures, are installed before drilling below the casing string or during workover operations. Fox Engineering Solutions LLC September 2009 Page 23 Appendix A Plan Review and Documentation SPCC Plan Revisions Log All amendments, both technical and non-technical, shall be documented in the SPCC Plan Revision Log. Amend the SPCC Plan within six (6) months whenever where is a change in facility design, construction, operation, or maintenance that materially affects the facility's spill potential. The revised Plan must be recertified by a Professional Engineer (PE). Plan Revision Made Page # or Reference Date Initials P E. Certification Necessary? Yes /No Yes /No Yes / No Yes /No Yes /No Yes /No Yes /No Yes /No Yes / No Yes /No Yes /No Yes /No Yes / No Yes / No Yes /No Yes / No Yes / No Yes / No Yes / No Five -Year Documentation Review This Spill Prevention Control and Countermeasure (SPCC) Plan is fully supported by the Management of Williams Production RMT and will be implemented as described herein, reviewed at least once every five years, as required by Part 112.5 (b), and amended within six months, as required by Part 112.5(a), when there is a change in the facility design, construction, operation or maintenance that materially affects its ability to discharge oil. The SPCC Representative is the Designated Person accountable for Oil Spill Prevention at the facility and has the authority to commit the necessary resources to implement this Plan. Management will, as part of this plan, incorporate the requirements outline below in the referenced plan sections. Anticipated First 5 -Year Review: 2014 Authorized SPCC Representative: I have completed a review and evaluation of the Parachute Integrated SPCC Plan on (date) and (will or will not) amend the Plan as a result. SPCC Representative Signature Printed Name Date Anticipated Second 5 -Year Review: 2019 Authorized SPCC Representative: I have completed a review and evaluation of the Parachute Integrated SPCC Plan on (date) and (will or will not) amend the Plan as a result. SPCC Representative Signature Printed Name Date Appendix B 00 Spill Response Plan and Procedures SPILL PREVENTION AND RESPONSE PLAN March 2009 Revision 5 Prepared By: HRL Compliance Solutions, Inc. 744 Horizon Ct, Suite 140 Grand Junction, CO 81506 For: WILLIAMS COMPANIES, INC. Robert Bleil, Principal Environmental Specialist Mike Gardner, Principal Environmental Specialist POBox 370 Parachute, CO 81635 Table of Contents Table of Contents 2 Table of Contents (cont'd) 3 I. SpiII Prevention and Response Policy 1 II. Purpose and Scope 1 111. Plan Applicability 1 IV. SpiII/Release Prevention 2 A. Standard Routine Prevention and Training 2 B. Areas of Special Concern 3 V. Spill Management 3 A. Discovery 4 B. Containment 4 C. Notification (Williams/Contractors) 5 D. Response 5 1. Williams Spills 5 2. Contractor Spills 6 E. Notification 7 F. Reporting 8 G. Remediation 8 VI. Training 9 VII. Spill /Release Costs and Invoicing 9 Table of Contents (cont'd) Appendix A Spill Management Flowchart Appendix B Containment Appendix B-1 Spill Response Station Locations Valley and Highlands Appendix B-2 Spill Response Station Inventory Appendix C Initial Notifications — Valley Asset Team Appendix C-1 Initial Notifications — Highlands Asset Team Appendix D Response Appendix D-1 Spill Investigation Letter Appendix E Federal and State Notification Requirements Appendix E-1 Federal and State Notification Contact Information Appendix E-2 Williams' Notification Guidelines Appendix F Federal and State Reporting Requirements Appendix F-1 Reporting Contact Information Williams E&P Spill Response Plan March 2009 I. Spill Prevention and Response Policy It is Williams' policy that its employees and contractors implement spill prevention and response plans in order to avoid and minimize the potential for spills and releases in the exploration and development of natural gas leases, in accordance with Federal and state regulations. This includes, but is not limited to the development and implementation of Best Management Practices (BMPs), training, and other actions that prevent, and take action to, manage spills and releases on Federal, state or private properties that are leased, managed, owned, or otherwise used by Williams. II. Purpose and Scope The purpose of this plan is to provide clear, comprehensive guidance and expectations for Williams employees and its contractors to prevent, mitigate, and manage spills and releases. This includes spill/release prevention, discovery, notifications, response actions, reporting, and subsequent remedial actions (as applicable). Contractors are required to develop and implement their own spill prevention and response plans tailored to the scope of activities as described in their Master Service Agreement (MSA) and Request for Services (RFS), and assure their plan complies with the guidance and expectations set forth in the Williams Spill Prevention and Response plan. Williams management and employees supervising natural gas exploration and development field activities, including contractor activities, are expected to have a working knowledge of this plan, particularly the chain of command for notification and reporting of spills and releases. Williams contractors are responsible for their spills and releases, and those of their subcontractors, in accordance with their (MSA). In the event of a contractor spill, Williams responsibilities are limited to ensuring that contractors comply with applicable federal and state regulations and guidance (including safety). Corrective action will be implemented (by contractor) to avoid the potential for future spills. III. Plan Applicability This plan is applicable to all aspects of Williams exploration and development operations including, but not limited to, drilling and completion, production, gas plant operations, and pipeline operations. It is specifically applicable to any vehicles, facilities and equipment that use, store, transport, dispose, or otherwise handle or manage chemicals (MSDS-regulated chemicals), hazardous materials, E&P wastes (drilling 1 (Page Revision -5 Williams E&P Spill Response Plan March 2009 muds, produced water, condensate), domestic waste (septic holding tanks), hazardous waste (oil, grease) extremely hazardous substances, or any other Federal or state regulated substance or waste. Federal and State Spill Prevention and Management Regulations Despite implementation of prevention practices and BMPs, spills may still occur. In the event of a spill, regulations for spill management can be found in several Federal and state regulations, including but not limited to the following: ➢ Clean Water Act (CWA): 40 CFR subchapter D parts 100-149 40 CFR 112 part 112 SPCC ➢ Comprehensive Environmental Response, Compensation and Liability Act (CERCLA); 40 CFR part 305 and part 307 ➢ Emergency Planning and Community Right -to -Know Act (EPCRA); 40 CFR part 355 ➢ Toxic Substance Control Act (TSCA); 40 CFR subchapter R parts 700-799 ➢ Resource Conservation and Recovery Act (RCRA); 40 CFR subchapter I parts 260-299 ➢ Clean Air Act (CAA); 40 CFR subchapter C parts 50-99 ➢ Hazardous Materials Transportation Act (HMTA); 49 CFR parts 100-185. ➢ Federal Lands: 43 CFR 3162.5-1 Environmental Obligations. Paragraphs A, B, and C. Colorado state requirements for spills and releases are contained in the following regulations: ➢ COGCC: Complete Rules 317b and 906 (and related sections) ➢ CDPHE: 6 C.C.R. 1007-2 & 1007-3 ➢ CDOT: 8 C.C.R. 1507-25 HMT 3 IV. SpilVRelease Prevention Williams first and foremost priority is that it's employees and contractors take all reasonable measures and implement BMPs to prevent both stationary and transportation- related ransportationrelated spills and releases from occurring. Measures and BMPs include, but are not limited to the following: A. Standard Prevention and Training ➢ Informing and training employees, contractors, and subcontractors of actions required to avoid potential spill situations such as: ■ Checking for open or secured valves prior to, during and after loading/unloading operations 2IPage Revision -5 Williams E&P Spill Response Plan March 2009 • Monitoring tank levels (don't count on alarms) • Building berms around loading/unloading areas • Providing portable spill basins during fluid transfers • Checking equipment (tanks, hoses, valves) for deterioration and leaks • Servicing vehicles/equipment (oil changes, lubrication) responsibly • Maintaining vehicles to avoid accidents resulting in spills • Being aware of surroundings when backing or moving vehicles • Ensuring stable ground when placing equipment, tanks and pipelines > Providing quarterly training to new Williams and contractor personnel on how to avoid potential spill situations. > Provide annual training for all employees who have completed initial spill prevention training. B. Areas of Special Concern (317B Areas) ➢ Williams now operates or will operate in some areas which require, due to increased public concern and new regulations, a higher level of preventative action. This would include the following: • All areas south of the Colorado River • The new 317B areas as outlined in the revised COGCC 300 series rules > Actions that will require further due diligence on the part of Williams when operating in these areas would include: • Checking for seeps and springs within a 1/8 mile radius • Checking for surface water such as ponds within a 1/8 mile radius. • Full understanding of what the new 317B areas are and knowledge of how to implement the Beaver Creek and Battlement Mesa Tactical Spill Response Plan. V. Spill Management For purposes of this plan, spill response and management addresses the major steps listed below. A flowchart illustrating an overall view of how Williams spill response and management operates is located in Appendix A. 3JPage Revision -5 Williams E&P Spill Response Plan March 2009 A. Discovery Discovery includes either actual or potential spills/releases, and in some cases situations that are not a spill or release, but someone has reported it as such. In any event, it is important to confirm that an actual or potential spill situation has occurred before the implementing spill response. If in doubt contact the appropriate spill response personnel as listed in Appendix C for assistance prior to implementing this plan. IF A SPILL OR RELEASE PRESENTS AN IMMEDIATE THREAT TO HUMAN HEALTH, SAFETY, THE ENVIRONMENT, EVOLVES INTO OR IS ALREADY AN EMERGENCY SITUATION AS OUTLINED IN THE EMERGENCY RESPONSE PLANS (ERPs), CALL 911 AND IMPLEMENT THE APPROPRIATE ERP. B. Containment Containment, for purposes of this plan, means stopping the spill or release from increasing in volume, size or duration. The person/persons who discover the spill should attempt to contain the spill only if safe to do so. Under no circumstances should field personnel attempt to manage an unknown spill or situation without adequate training, personal protective equipment (PPE) or without exercising extreme caution. 1 DO NOT ATTEMPT TO CONTAIN THE SPILL IF UNSAFE TO DO SO If there is no immediate threat to human health, safety or the environment, and you are convinced that the spill can be safely contained then one can: ➢ Survey the area for personal safety. ➢ Stop the activity or process causing the spill/release. ➢ Warn others in the .area, secure the scene of the spill/release D Isolate the affected spill area. D Initiate notifications as outlined in Appendix C and C-1 ➢ Avoid direct contact with the spilled material; D Avoid inhalation of any gases, fumes, vapor or smoke — stay upwind; ➢ Stay at safe location near the spill until an authorized spill responder arrives. 4IPage Revision -5 Williams E&P Spill Response Plan March 2009 Spill containment options and materials used may vary depending upon the media affected. See Appendix B for containment options and materials that can be utilized. C. Notification (Williams/Contractors) The person discovering the spill must make initial notifications in accordance with Appendix C and C-1. When making the initial notifications, the information outlined in Appendix C and C-1 must be provided. This information is also on the field notification cards that are provided by both the Valley and Highlands Asset Teams *URGENT NOTIFICATION REQUIREMENT* For any petroleum product (oil, gas) spiWrelease that reaches live water, has the potential to reach live water, affects a drainage that flows to live water, or is in a 317b area; immediately notify the appropriate Williams Env. Team Lead Immediately. (See Appendix C & C1) D. Response 1. Williams Spills Spills in which Williams is the responsible party, response actions will be determined by one or a combination of the following Williams designated personnel as outlined in Appendix C: > Williams Operations Manager or Designee > Williams Environmental Team Lead (Bleil-Valley; Gardner -Highlands) > Williams Spill Contractor (HRL-Valley and Highlands) The appropriate Williams Spill Contractor will perform the following response actions: 1) Receive confirmation of containment actions 2) Direct further response actions as needed using approved spill response contractors 3) Assign a Spill Project Number/Charge Code for response contractor invoicing 4) Investigate using the Environmental Incident Investigation Form (Appendix D) 5) Perform required Federal and/or state notifications if required (Appendix E & F) 6) Report the status of the spill on the weekly Business Unit Spill Tracking Report 7) Forward the weekly report/updates through HRL to designated Williams personnel 5JPage Revision -5 Williams E&P Spill Response Plan March 2009 2. Contractor Spills Contractors with a valid MSA are fully responsible for their spills. This includes all costs associated with responding to, containment, notification and reporting, remediation, and corrective actions necessary to minimize the potential for future spills. Williams or their environmental spill response contractor will complete the necessary reporting to the appropriate federal or state agency as outlined in Appendices E & F. Contractor Spill, response actions will be conducted in accordance with the Contractor's Spill Prevention and Response Plan. Contractors will be responsible for the following items if it is determined that they are the responsible party in the event of a spill or release: D. A meeting will be held with the responsible contractor following notification of the spill. The contractor's representative will be in a supervisory role and will contact the Williams spill response team lead: 1. The contractor responsible for the spill will schedule a meeting with the Williams spill response team lead within 24 hours of the spill. 2. The contractor will bring their spill investigation form and it will be reviewed to assure completeness of the form. 3. In addition a spill investigation letter will be filled out by the responsible contractor and it will be submitted to the Williams spill response team lead within 3 days of the spill or release. A copy of this letter is located in Appendix D-1. 4. The contractor will be informed that the person or persons responsible for the release will attend the next available spill prevention training. D All contractors must provide proof that they have a qualified environmental person in-house or an environmental consultant to manage spills. In the event the responsible party has the ability to control a spill within the guidelines of this plan, the Williams' spill response contractor will still provide oversight on Williams' behalf to assure the spill has been managed correctly and there are no repercussions to Williams as a result of the spill or release, if the spill is located on a Williams lease or property. Wage Revision -5 Williams E&P Spill Response Plan March 2009 Contractors will be required to include and maintain a current listing of all chemicals, substances and wastes used in their operations (as well as the applicable MSDS sheets) in their Spill Prevention and Response Plan. E. Notification Federal and State verbal notification requirements for spills are based on two criteria: 1. The type of material spilled and; 2. The volume of material spilled. 3. Affected environmental media (i.e. soil, water) These materials are further sub -divided into two categories; 1. Exploration and Production Waste (E&P Waste) such as produced water, condensate, or any other material that has been down hole and; 2. Non -E&P Waste such as fuels and oils. This would include materials such as diesel fuel, hydraulic oil, motor oil, and glycol. The most common materials encountered when responding to spills and notification volumes are outlined in Appendix E. For materials that are not listed in Appendix E, one must consult the MSDS sheet for the material spilled, determine if it is E&P or Non -E&P waste and make the appropriate notification if required if the reportable quantity is exceeded. Contact information for federal and state agencies is outlined in Appendix E-1. In order to provide further due diligence, Williams has notification requirements for spills, both company and contractor, with volumes that are less than the federal and state requirements. These notification requirements are in place to satisfy environmental obligations that the operator must comply with. These are set forth in Title 43 of the Code of Federal Regulations. Specifically they are found in Chapter II, Part 3160, subpart 3162, Section 3162.5-1 Environmental Obligations. These are outlined in Appendix E-2. *URGENT NOTIFICATION REQUIREMENT* For any spill/release that migrates off the pad and reaches live water, or has the potential to reach live water, or affects a drainage that flows to live water; immediately notify the Williams Env. Team Lead Immediately. (See Appendix C) In addition, Williams uses the notification requirements as outlined Appendix E-2 to track and document the cause of spills so procedural changes can be implemented to better manage spills and prevent them 7IPage Revision -5 Williams E&P Spill Response Plan March 2009 F. Reporting Federal and State reporting requirements for spills, as with notification, are again based on; 1. The type of material spilled and; 2. The volume of material spilled 3. Affected environmental media (i.e. soil, water) These.materials as well are sub -divided into two categories 1. Exploration and Production Waste (E&P Waste) such as produced water, condensate, or any other material that has been down hole and; 2. Non -E&P Waste such as fuels and oils. This would include materials such as diesel fuel, hydraulic oil, motor oil, and glycol. Even though a spill may not require verbal notification it still may be reportable. The most common materials encountered when responding to spills and reporting volumes are outlined in Appendix F. For materials that are not listed in Appendix F one must consult the MSDS sheet for the material spilled, determine if it is E&P or Non -E&P waste and submit the appropriate form or forms if required. Contact information for federal and state agencies is outlined in Appendix F-1. In the event that a spill or release resolve in significant damage to equipment, a Form 22 will be submitted to the COGCC by Williams' safety department within 10 days of the incident. G. Remediation In some instances, remediation may be required when a spill occurs. Whether or not a spill requires remediation is, again, dependant on the type of material spilled, the volume spilled, and if the spill is contained on the pad by stormwater controls or tank berms already in place. In addition remediation will be dependent on whether or not the pad is a working well pad or a well pad that has been reclaimed. Spills that migrate off any pad in volumes greater than those stated in Appendix E-2 will, in most cases, need to be remediated. The Williams environmental team lead, or the appropriate spill response contractor will make these determinations. *URGENT NOTIFICATION REQUIREMENT* For any spill/release that migrates off the pad and reaches live water, or has the potential to reach live water, or affects a drainage that flows to live water; immediately notify the Williams Env. Team Lead Immediately. (See Appendix C) Revision -5 Williams E&P Spill Response Plan March 2009 In the event a spill is remediated and results in the accumulation of either E&P or Non - E&P waste, refer to the Williams Waste Management Plan for management and disposal of these wastes. VL Training It is required that all Williams and contractor personnel responsible for spill response and management complete Williams spill response training on an annual basis. At a minimum this includes Operations Managers, Field Supervisors, and EHS management and staff. It is strongly recommended that Williams and contractor personnel performing field response and remediation activities complete the 24 -Hour HAZWOPER course and annual refresher courses. As stated in Section IV, training for new Williams and contractor employees will be offered on a quarterly basis. This can be arranged through HRL Compliance Solutions, Inc or Cordilleran Compliance Services, Inc. Documentation that your employees have completed the necessary training will be provided. Williams and contractor employees that have documented proof they have completed the initial spill response training will be required to update their training annually. VII. Spill /Release Costs and Invoicing All spills must be billed to the appropriate project charge code (aka AFE) regardless of where the spill actually occurred. For contractor spills, Williams will only pay the costs associated with oversight of the spill billed to Williams by its Spill Response Contractor. All other costs are the responsibility of the contractor causing the spill. This includes response costs by third party contractors to contain spills. Williams will not accept invoices from third parties for contractor spills. If a bill is inadvertently forwarded to Williams, the amount will be deducted from future payments and show as a credit to Williams. 9IPage Revision -5 Appendix A. Williams Spill Management Flowchart a2 w r — £ a 1k «£ 20. ( a Appendix B. Containment Williams, designated spill response, and contractor personnel involved in day to day operations at Williams facilities should carry some basic spill response materials with them at all times in order to contain spills and releases. However, as stated in section B of the Spill Prevention and Response Plan; 1 DO NOT ATTEMPT TO CONTAIN THE SPILL IF UNSAFE TO DO SO Listed below are some options that can be implemented for spill containment Containment materials for spills/releases to soil and surface water 1. Portable spill kits as stated above. Kits should contain • Absorbent pads • Absorbent Booms • Absorbent Clay • Shovels 2. Soil stockpiles located in strategic locations for berm construction of needed. 3. Vacuum truck company phone numbers for removal of free liquids from pads, roads, drainages, and surface water in the event free product or sheen is present. In the event that additional spill response materials are needed; Williams has placed six spill response stations at various locations. Six are located in the Valley and three are located in the Highlands. Figures 1 & 2 in Appendix B-1 depict the locations of Williams' Spill Response Stations. A list of materials and equipment that is stored in the spill response stations is included in Appendix B-2. Note: Each spill response station has an inventory checkout list that should be filled out prior to taking materials from the station. This better enables Williams to track items utilized during spill response. An example of the inventory checkout list is also included in Appendix B-2. Containment options for spills/releases to soil and surface water If it is determined that there is no immediate threat to human health and one is certain that the spill can be safely contained then the following options can be implemented; 1. Attempt to stop the spill at the source such as closing valves, plugging holes, etc. 2. For releases to soil try to isolate the spill area by constructing earthen berms, placing booms or absorbent pads around the spill avoiding direct contact with the material spilled. 3. Remove free liquids if possible 4. For spills/releases that potentially or have impacted surface water attempt to stop the material released at the point where it enters the water. (i.e. earthen berms, absorbent booms/ pads) then; 5. In flowing water place booms/dikes at easily accessible downstream locations as close to the point where the spill/release enters the surface water. 6. Have vac trucks dispatched to the location to remove any free product or sheen visible on the water. Appendix B-1. Spill Response Station Locations Valley and Highlands uoge}S asuodsaa !!!ds Legend Spill Response Station Existing Road Figure 2: Highlands Spill Response Station Locations OVM*IMPICLUdOPM.P.M710,29-8PWRIISPOIVId.00INI011fjiRMSPERGITOOMIHOW16.11111d Innrynad wiao1„ma,AU 5 Miles Appendix B-2. Spill Response Station Inventory Spill Response Station Inventory List All valley and Highlands spill response stations will at a minimum contain the following items with the exception of the GV 82-5 and the RU 31-12V stations which will have additional spill response materials as noted below. 3 -Cases 17" x 19" x 3/8" Oil absorbent Pads (12 per case) 1 -Case 7" W x 15" L Oil Absorbent Pillows (16 per case) 1 -Case 3" x 4' Mini Booms (30 per case) 2 -Cases 3" x 8" Oil Absorbent Booms (6 per case) 1 -Case 5" x 10' Oil Absorbent Booms 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 (12 pairs per bag) 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 20' x 20' Liner 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 4 5 -gallon buckets with lids 1 -sheet 1/2" plywood Note: The GV 82-5 spill response station will contain 2-12" x 50' river booms for spills that could potentially impact the Colorado River. It will also contain a small trash pump and associated plumbing to pump water if necessary. The RU 31-12V will contain an additional Case of 5" x 10' oil absorbent booms. Spill Response Station Inventory List 1 8 0 36" x 56" 3 mil Trash Can Liners Square Point Blade Shovels 5-1/2 foot Steel Fence Posts 20' x 20' Liner 28" Traffic Cones d mv oo • = c▪ 42 Un U U U U r d LC a h 4 GG d m C, Q mo .it a°� h • • • N ^ N .. .., N N so N N M (-sit) .. V .. Z 10. .2 0 .2 .o 0 2 0 O T.; b 0 v k p fV � N •O 'S O 8 O O m • C 0 W 61 a O m U pg N 00 I • M d • R Appendix C. Initial Notifications (Williams/Contractors) Piceance Valley Asset Team Contacts for Emergencies/Spills/Incidents Piceance-Valley Asset Team Contact Emergencies/Spills/ Incidents Name Title Position Operation Management Cell# Other# Steve Soychak E&P District Manager Scott Brady Drilling/Completion Supt Steve Hams Completions Mgr Brad Moss Production/Facilities Supt 970-216-0922 970-270-9187 970-948-4312 970-987-1737 Paul White District Prod Engineer Mgr -E&P Health & Safety 970-456-3337 970-309-9766 970-523-0332 303-618-7341 970-256-3379 970-245-5417 Kevin McDermott Safety Mgr Delbert Dowling Exploration & Production Safety Coord. Sr. Brian Gingrich Exploration & Production Safety Coord. Sr. Greg Anoia Exploration & Production Safety Coord. Sr. Environmental 970-309-1195 970-589-5736 970-216-6820 970-216-1387 N/A N/A N/A N/A Rob Bleil Environmental Manager Kent Rider Environmental Lead - E Rulison 'Jason Raley Environmental Lead - Parachute / W Rulison Mike Shoemaker Environmental Lead - GV / Red Point Karolina Blaney Spills / Incident Lead Public Relations 970-210-2050 970-250-7328 970-210-4351 970-250-5778 970-589-0743 970-243-1936 970-640-5266 970-231-0554 970-985-8661 970-245-3791 Susan Alvillar Communication Spec. III Donna Gray Communication Spec. II Land 970-216-38781 970-241-4430 970-589-1557 N/A Sandy Hotard Field Land Manager Bryan Hotard South of the River Roy McClung North of the River Walt Proulx Contractors 970-210-9709 970-361-2006 970-640-2790 970-256-8939 970-985-4904 970-285-7028 Gene Thurston MB Construction (Spill Response) MB Construction -Only if can't Reach Walt Pat Brown Roustabouts (Spill Response) Mark Mumby HRL Comp (Spills/Releases) Tom Kirkpatrick KERSI (Storm water) 970-985-1372 970-858-8546 970-216-0642 N/A 970-210-9051 970-243-8519 970-260-1576 970-243-2209 970-270-7687 683 -1777 -Blake Appendix Cl. Initial Notifications (Williams/Contractors) Highlands Asset Team Contacts for Emergencies/Spills/Incidents Piceance HIGHLANDS Asset Team Contacts -- Emergencies/Spills/incidents Name Title/Position CeII # Other # 1 Home # ,ENVIR9NMENTAL fkaGENCIESIIINCILIktiTS 41)11 4, pig la "twits, storm wafer, etc,...1 Envjronmei�erier:t t roritacikt: Mike Gardner Environmental Team Manager 970-623-4875 970-263-2760 970-858-0708 John Suchar Environmental Specialist 970-274-9543 970-623-8988 970-640-8993 Jason Rauen Environmental Specialist 970-274-4564 970-623-8993 970-254-9377 Tom KGrkpatrick KERSI (Storm water Contractor) 970-270-7687 N/A N/A Mark Mumby HRL (Spill Response Contractor) 970-260-1576 970-243-3271 970-243-2209 Kris Rowe HRL (Spill Response Contractor) 970-261-2015 970-243-3271 N/A Herman Lucero HRL (Spill Response Contractor) 970-261-3571 970-243-3271 970-241-0296 Dri in ,....,:4 `nage lnen-cDnuicts for hurldei : vial=;d tvi iiritlinu.a=_llvilies Jim Jackson Drilling Superintendent 970-930-5396888-623-2253 N/A L n Cass Drilling Superintendent 970-755-0083 I Cgrailafltens 970-263-2716 970-984-0647 i1 na_ae hent-CeutaeAS f& Ls a�60cia%eci' Jim Lake cmnoletirgi acilleities Completions Superintendent 970-270-7356 970-263-2761 970-285-2245 Colt Stewart Completions Supervisor 970-623-5153 N/A N/A - - prodtictloFliOperatfOns Management--coniaci #'o rileideratcae ogietpdwrpreductIon _ Blake Roush Highlands Project Manager 970-260-7028 and c2at'0 970-263-5321 rte N/A Ron Cornett Construction Manager 970-987-4603 970-623-8947 N/A Darryl Zimmerman Construction Supervisor 970-755-0090 N/A N/A Scott Dembowski Ryan Gulch Supervisor 970-755-0078 877-532-9926 N/A Sam Bevan Allen Point Supervisor 970-589-1435 970-263-2813 N/A Mike Grattan Allen Point Supervisor_ 970-250-9680 _ 970-263-_53.17 N/A _ Egviprvent earittaGtors--Contae:t if there is an INtitE.DIA1E neerd 1'br Bob Prather MB Construction egpipment 970-574-8120 970-250-0385 N/A Doug Moody Moody Construction 970-379-6351 970-878-8771 N/A Quentin Hoops Roustabout Specialties 970-640-3360 N/A N/A Curt Dembowski C & J Field Services 970-629-5161 970-675-2480 N/A Spilt Response Statlone-Access only for IMMEDIATE need.. of spill response/containment mate:leis Ryan Gulch Station: Located at Ryan Gulch Compressor Station Trail Ridge Station: Located at Trail Ridge Man Camp All ,n Point Station: Located at AP 34-8-695 Well Pad HEALTH & SAFETY EMERGENCIES (operational/vehicle accidents involving human health) tiesIth & Safety Management. Contacts: Kevin McDermott Safety Spec Team Leader 970-309-1195 970-683-2294 N/A Delbert Dowling Safety Coord. Sr. - Drilling 970-589-5736 970-623-8918 N/A Biian Gingrich Safety Coord. Sr. - Production 970-216-6820 970-263-2705 N/A Gre Anoia Safe Coord. Sr. - Plants 970-216-1387 970-263-1387 N/A Mist Caller should provide the following information for safe and efficient Incident response: X Name of caller w/ call back number X Location of incident X Type of substance released X Estimated quantity released X Time/Date of incident X Responsible party X Cause of incident X Impacted areas (i.e. pad surface only, off location, surface water, etc) X Immediate response/mitigation actions Revised 11/21/2008 Appendix D. Response Williams Environmental Incident Investigation Form ss ENVIRONMENTAL INCIDENT INVESTIGATION (FIELD WORKSHEET— NOT OFFICIAL) Occurred: Location ID: Field T R S Qtr/Qtr Investigation Date: Lead: Incident Log Entry: Time: Discovered By: Company: Phone: RESPONSE ACTIONS Response Contractor -1: Response Contractor - 2: Date: Environmental Contractor Contacted ( ) Yes () No Date: Samples Required: () Yes ()No Time: Time: I COCs: DESCRIPTION OF ACTIONS (Equipment/Materials Used, containment, soils removed, water removed, etc.) Terminated By: Date: SURFACE OWNER Time: INCIDENT TYPE RELEASE TYPE LANDS AFFECTED MEDIA AFFECTED BIOTA AFFECTED ( ) Facility ( ) Transportation ( ) E&P Waste ( ) Non — E&P ( ) Private ( ) Federal ( ) State ( ) Land/Soils ( ) Air ( ) Waters (U.S.) ( ) Wetland/Riparian ( ) Ground water ( ) None ( ) Plants ( ) Wildlife — Game ( ) Wildlife — T&E ( ) Wildlife — Non -game ( ) Other: ( ) Other: ( ) On -Lease ( ) Off -Lease SIGNIFICANT THREAT TO HUMANS OR ENVIRONMENT ( ) NO () YES — Implement Emergency Response , INCIDENT DESCRIPTION (How incident occurred, type of effluent, emissions, chemical, etc.): r ESTIMATED VOLUME/QUANTITY OF RELEASE: RESPONSIBLE PARTY: COMPANY: CONTACT: PHONE: WILLIAMS CONTACTS: Parachute: ( ) BIeiI ( ) Gardner RESPONSE ACTIONS Response Contractor -1: Response Contractor - 2: Date: Environmental Contractor Contacted ( ) Yes () No Date: Samples Required: () Yes ()No Time: Time: I COCs: DESCRIPTION OF ACTIONS (Equipment/Materials Used, containment, soils removed, water removed, etc.) Terminated By: Date: SURFACE OWNER Time: AGENCY NOTIFICATION / REPORTING ACTIONS Agency/Owner 1 Notification Required Y Y Y Y Fed - BLM COGCC CDPHE NRC N 1 Date: N Date: N 1 Date: N Date: Y Y Y Y Reporting Required N Date: N Date: N Date: N Date: REMEDIAL ACTION REQUIRED: ( ) NO ( ) YES: FORM 22 REQUIRED: ( ) NO ( ) YES: If yes contact HSE for submittal of the Form 22 1 I Surface Owner I Notification Required L Contacted By Date r I AGENCY NOTIFICATION / REPORTING ACTIONS Agency/Owner 1 Notification Required Y Y Y Y Fed - BLM COGCC CDPHE NRC N 1 Date: N Date: N 1 Date: N Date: Y Y Y Y Reporting Required N Date: N Date: N Date: N Date: REMEDIAL ACTION REQUIRED: ( ) NO ( ) YES: FORM 22 REQUIRED: ( ) NO ( ) YES: If yes contact HSE for submittal of the Form 22 1 Appendix D 1. Response Williams Spill Investigation Letter (Date) (Contractor's Address) Dear Mr or Ms. WILLIAMS PRODUCTION RMT COMPANY 1058 Cotmty Road 215 P.O. Box 370 Parachute, Colorado 81635 office (970) 285-9377 fax (970) 285-9573 The following information is required to be submitted to Williams within 3 business days of the date of the spill to demonstrate compliance with the terms and conditions of your MSA regarding spills. a. The date and time of the spill b. The date, time Williams was notified c. The name of the Williams' person contacted d. The name of the responsible supervisor e. The name of the responsible individual f. The name of your Environmental Consultant g. Description of what was spilled h. The cause of the spill i. The volume of the spill j. Media Affected (soil, live water, drainage, vegetation) k. The location of the spill on a 1:24,000" topo map or aerial photo, with GIS coordinates. 1. Photos of the spill m. Actions taken to stop and contain the spill n. Planned remediation o. Storage, treatment and disposal of spill waste p. Communication with third parties to include law enforcement, other agencies. q. A copy of your Spill Prevention and Response plan r. Evidence that the responsible individual and supervisor are trained in spill prevention and response. s. Planned actions to prevent further occurences Spill Prevention and Response is critical to Williams reputation with regulatory agencies, landowners and the communities in which we operate. Repeated spills and releases that may be deemed as negligence by Williams or regulatory agencies may result in revisions to, or termination of, your MSA with Williams. Karolina Blaney Williams Spill Program Lead cc: R. Bleil M. Paules E. Joyner M. Mumby (HRL) Operations Manager Wifiiarns WILLIAMS PRODUCTION RMT COMPANY 1058 County Road 215 P.O. Box 370 Parachute, Colorado 81635 office (970) 285-9377 fax (970) 285-9573 Appendix E. Federal and State Notification Requirements 4.0 05 3 01/W DC lC G7 0 DC 731 o ° x ° zN N N it >10 bbls but <100 bbls (FED) n 4.4 w n a n >10 bbls but <100 bbls (FED) oni Condensate/Crude Oil 01 01 3 Gz7 0 z DC DC yC 0 aU -01 N z 101 gi it Er3'6 p 0 O 06 sfi a Diesel Fuel/Gasoline Waste Oil/Lube Oil DC M DC M M 0.1 G3 N z x N z x N x N z a A a t 44 n 0 0 N U cg 0 0 Ethylene Glycol Methyldiethanolamine O co 0 coO gcl ^1" O . W a1 +' — .G C U o 641 O O N g c-) +O O O Ey 0 O U U U 0 0 .i7 N 0 c4-1.0 r., 0:! "0A o t 1 0 0 4.11 o oussElki • wa 11.). W -• ; N M t} Appendix E-1. Federal and State Notification Contact Information Public Safety Officials and Government Agencies Public Safety Notification - Verbal Fire Police/Sheriff 911 Colorado State Highway Patrol Hazardous Waste Division 911 ..970-858-2291 Government Agency Notifications — Verbal National Response Center 1-800-424-8802 (24 hr/day — 7 days/week) Colorado Department of Natural Resources 303-894-2100 Oil and Gas Conservation Commission (24 hr/day) Colorado Department of Public Health and Environment 970-625-2497 24 Hour Spill Response Colorado Department of Public Health and Environment 303-692-3500 Water Quality Control Division Garfield County Health Department 970-625-5200 U.S. Department of Interior, BLM, White River Field Office 970-878-3800 U.S. Department of Interior, BLM, Glenwood Springs Field Office 970-947-2800 U.S. Department of Interior, BLM, Grand Junction Field Office 970-244-3000 Appendix E-2. Williams Notification Guidelines Williams Company and Contractor Notification Requirements As stated in section E. of this plan, Williams has established threshold values on materials spilled or released in order to provide additional due diligence to satisfy federal and state .requirements. Also Williams utilizes this data to track and identify potential trends to implement procedural changes which can better manage spill/releases and better manage them. The Williams reporting requirements area as follows; 1. Any spill of E&P waste (produced water, condensate) greater than 1 barrel and Any Spill of non -E&P waste (Diesel fuel, motor oil) greater than 5 gallons needs to be reported to the proper Williams environmental team lead in order to provide the due diligence requirements set forth in Section 3162.5-1 of the Code of Federal Regulations. 2. Any spill of E&P or non -E&P waste in the quantities listed above that has migrated off-site needs to be reported to the appropriate Williams environmental team lead Immediately. As stated above; if you are unable to contact the designated Williams personnel listed in Appendix C, contact the appropriate spill response contractor (HRL Valley/Highlands) so any notification/reporting that may be necessary can be completed within the designated reporting time. *URGENT NOTIFICATION REQUIREMENT* For any spill/release that migrates off the pad and reaches live water, or has the potential to reach live water, or affects a drainage that flows to live water; immediately notify the Williams Drilling/Field Lead Supervisor and the appropriate Williams Env. Team Lead Immediately. (See Appendix C) Appendix F. Federal and State Reporting Requirements U U z .10 0 a 85' lj >10 bbls but <100 bbls (FED) >100 bbls (FED) 44 V A A >10 bbls but <100 bbls (FED) >100 bbls (FED) 0 rr Ct CO Akel 1,1rvi 0 z 4-3 1 te n a 5 1 n 0 a 0 Diesel Fuel/Gasoline Waste OiULube Oil NRC COGCC CDPHE BLM X cn cn X X cn cn X m cn X Notification Requirement (Verbal) cd A In ZA kr) 15 Days 15 days 0 None A A 15 Days None 15 Days Minimum Amount to Report RQ Any Amount Impacting Water (FED) A X4#0 A 1 Fil 0 7\ A Any Amount Impacting Water (FED) > 25 gallons (FEE/FED) >10 bbls but <100 bbls (FED) A 0 Media Affected Surface water/Groundwater r� Surface water/Groundwater r/) Soil Ta A Ethylene Glycol p 0 a Appendix F-1. Reporting Contact Information Government Agency Reporting — Written Colorado Department of Public Health and Environment 303-692-3500 Water Quality Control Division 4300 Cherry Creek Drive South Denver, Colorado 80222-1530 Colorado Department of Natural Resources 303-894-2100 Oil and Gas Conservation Commission 707 Wapiti Ct., Suite 204 Rifle, Colorado 81650 Colorado Public Utilities 1580 Logan Street, 2"d Floor Denver, Colorado 80203 303-894-2000 U.S. Department of Transportation 202-366-4595 Office of Pipeline Safety Information Resource Manager Washington, DC 20590 (Gas Distribution — Form RSPAF 7100.1-1) Gas Transmission and Gathering — Form 7100.2-1) U.S. Department of Transportation 720-963-3161 Office of Pipeline Safety 12300 West Dakota Avenue, Suite 110 Lakewood, Colorado 80228 (To Obtain Forms RSPAF 7100.1-1 and 7100.2-1) Appendix C Inspection Records and Procedures Procedures and Responsibilities These procedures establish the requirements at each individual facility for periodic inspections, tests and documentation for the oil storage tanks, vessels, connected piping and oil -filled equipment. The Williams' SPCC representative is responsible for the implementation of these procedures and for documenting and conducting the inspections; producing documentation for deficiencies found during the inspections; and making certain that remediation or repair work is properly prioritized and completed in a timely manner. The Williams' SPCC representative may designate another personnel member or contractor to complete the inspections. Formal annual inspections shall be directed by the Williams' SPCC representative. Field personnel shall be responsible for the Annual Flowline Inspection. Oil handling personnel will become familiar with the Annual Flowline Inspection Checklist below. After the third year of operations, flowlines will be pressure tested annually per industry standards. Additionally, the Annual Flowline Inspection Checklist items are to be observed by oil handling personnel as part of their routine operational visits to the sites. Provide a written copy of the completed Annual Flowline Inspection Checklist to the SPCC representative and upon discover of a spill or deficiency during routine operational visits. Provide further description and comments, if necessary, on a separate sheet of paper and attach to this sheet. *Any item that receives "yes" as an answer must be described and addressed immediately. The Annual Facility Data and Inspection Checklist, below, must be conducted and completed each year. If any response requires further elaboration, provide comments in the spaces provided. Further description and comments, if necessary, must be provided on a separate sheet of paper and attached to this sheet. Any deficiencies that require attention must be brought to the attention of the SPCC representative and addressed immediately. If, during any of the inspections, an oil spill is observed, the inspector shall immediately initiate the oil spill response procedures outlined in Appendix B of this SPCC Plan. All drainage releases from containment areas shall be documented on the Containment Release Documentation form in this section. Produced water storage pits levels shall be observed on routine operational and maintenance visits. Sudden or unexplained level drops; or maintenance issues shall be reported and investigated immediately. Annual inspections shall also be documented in the Annual SPCC Inspection Facility List in this section. All of the records and documentation for this plan may be stored under normal business practices including electronic media. The SPCC representative will examine the inspection reports to determine if changes to secondary containment are required as the result of tank changes in the field or if other conditions have changed since the last inspection. Technical amendments will be initiated as outlined in this SPCC plan. Annual Flowline Inspection Checklist After the third year of operations, flowlines will be pressure tested annually per industry standards. This form is to be completed after the flowline test. Provide further description and comments, if necessary, on a separate sheet of paper and attach to this sheet. *Any item that receives "yes" as an answer must be described and addressed immediately. Oil handling personnel will become aware and familiar with the following checklist items. These items are to be observed as part of routine operational and maintenance visits to the facilities. Facility Name: Date of Inspection: Inspector's Signature: Periodic Inspection Checklist if . Description &Comment Storage Tanks Tank surfaces show signs of leakage Tanks are damaged, rusted or deteriorated Bolts, rivets, or seams are damaged Tank supports are deteriorated or buckled Tank foundations have eroded or settled Have tanks been removed or placed this quarter Vents are obstructed Secondary containment is damaged or stained Level/Indicator Alarm & Telemetry working Cathodic Protection Installed & Connected Piping Valve seals, gaskets, or other appurtenances are leaking Pipelines or supports are damaged or deteriorated Flowline piping area show evidence of leakage Buried piping is exposed Flowline pressure testing (annually) Truck Loading Area Load Buckets functional & in good condition Evidence of recent spills on ground Storm water control BMPs in place for adequate secondary containment for manned loading operations BMP drainage occurring Oil/water Separator & Dehydrators Leakage at or inside Oii/water separator or dehydrator Evidence of corrosionleaks on intemal piping & vessels Security ' Fencing and gates functional at public access sites Other Water Drained from containment berms (Use form below) Produced water pit levels normal Facility Name: Date of Inspection: Inspector's Signature: Annual Facility and Data Inspection Checklist This inspection record must be completed each year. If any response requires further elaboration, provide comments in the spaces provided. Further description and comments, if necessary, must be provided on a separate sheet of paper and attached to this sheet. All deficiencies must be brought to the attention of the SPCC representative and addressed immediately. Night/ ke lector WiierrsWbllhtladshaCInereillan1rinrtnatla i Mixes Talon YIN Problem: Found YR4 FadNyMultDsie Fled/(yN1l♦1 Nm(Rinuy) krllhrUlaeNn6a61ire�i Inikaffaud Dia Taicirfatretion NdxrQndasdeTaia tinier PcduadWier Tads Leered Flialed/Yaas-Chinn RI illtgabliehevakaip BarrAektte Page 1 of 2 Laub N31184 [GOA AN'n823 1 ItardiP Rap 8dorr Laffim Field De1Mp FlaiNara NO3Sdieatiem LaaimWarraim EU Main Mb Let DacDeg Deg Pan Sec Dec Dm Deg Nil Sec TakD Talc N) Talc Oriafs PFSID ami4( Smalls) abteFJ Meed Oaied vigcaziMaul Tat Tak ID TakN) Tak Oriels Takaadim DifEkal $ linforMie%b aGdainert Faife;oty OrisinatT U>bimadD TakD MAN) Tak Galeria TakRxd Tam 8g OenOkradm Tak Nara Ta cOia Fleletkls Nnel ldeSaki tb Maafaiva unarinntoaaout nainawan Laalmt Laded? Oadiar(ecodBal) loath/ keldeBam Mr9 Limed!, BamOrradora Lays EbIbm IWdhMan WdtrTcpMgt MIRIUO IyU IQII Mix Oatdmat RENOWN), OatefiretlD EttaRaat(YRN Annual Facility and Data Inspection Checklist Page 2 of 2 Failure Information Outside of Containment Date: Inspector's Signature Equipment to Fal Drainage Direction Azimuth Degrees Comments Facility Property rroaucaon Equipment Fenced Signage Indentify and Describe Diversions or Drainage Structures within the Facility Boundary, including Catchment Basins, Culverts, Identify any Areas of Stained Soil or other Indications of 011 Leaks Surrounding Drainage Distance b Nearest Surface Water in Feet i Direction to Nearest Surface Water Azimuth Mcie in Degrees I Type of Surface Water Y or Blank Name If Available (ordeaaibs) k tannktent/EphemeraVPeemial Steam (Y/N) Poncl/Lake River(Y/N) Dry WaeWDrainegdDry Arroyo (YiN) Weland (YiN) Road Dlcit(Y/N) Description of Diversion or Drainage Structures Near the Facility General Description of Strrounding Properties Description of Area Topography and Specify Offsite Drainage Direction Other Issues Not Described Above SPCC Facility Plot Plan Completed (YM) Y I -Indicate each stomp container, secondrycortainmer t stuctune and time -phase separator SPCC Fatuity Plot Plat Wad DocumentLidc Date: Inspector's Signature Containment Release Documentation Facility Name: Date and Time at Drainage /aspec `etr' InnisIs Containment Area Domed Appearances otsuat odorre ) Note: do no* discharge mer containing any contaminant and ogee all pmts Quantity Removed Mas) Method of' Removal and DsposaI Annual SPCC Inspection Facility List Facility Name: Annual Flowline Inspection Dates Annual Facility Data and Inspection Dates APPENDIX D Record of Annual Discharge Prevention Briefings and Training Oil Handling Personnel Training Documentation and General Training Outline Briefings will be scheduled and conducted by the facility SPCC representative for oil handling personnel and inspectors at least once annually to ensure adequate understanding of this SPCC Plan. The briefings will also highlight and describe known discharge events or failures, malfunctioning components, and recently implemented precautionary measures and best practices. Personnel will also be instructed in operation and maintenance of equipment to prevent the discharge of oil, and in applicable pollution laws, rules, and regulations. Facility operators and other personnel will have an opportunity during the briefings to share recommendations concerning health, safety, and environmental issues encountered during facility operations. Date Subjects Covered Employees in Attendance Instructor(s) General Training Outline A. Introduction/Attendance Sign -in B. Applicable Rules and Regulations • Federal Regulations • 40 CFR 110: Discharge of Oil • 40 CFR 112: Oil Pollution Prevention • State Regulations (COGCC & CDPHE) • Local County Regulations C. Williams Production RMT Company Facility SPCC Plan • Williams SPCC Management & Administrative Structure • Physical Location of Plan • Introduce/Review Contents of SPCC Plan • Facility Layout • General Facility Operations • Location of Oil Storage Areas and Oil Containing Equipment • Above Ground Storage Tanks • Dehydrators and Separators • General SPCC Requirements (§112.7) • Specific Requirements for Onshore Production Facilities (012.9) • Operation of Oil -Filled Equipment and Containment Equipment • Above Ground Storage Tanks • Fill Procedures • Maintenance Procedures • Handling Procedures • Drilling, workover and completion operations • Master Service Agreement SPCC requirements D. Oil and Fluids Discharge Response Procedures E. Discussion of Known Oil SpilUDischarge Incidents at Facility in Past 12 Months Appendix E Facility Specific Data Williams Production RMT Facility Name: P GV 82-05_62053814 Facility Specific Details for Inclusion Into the PARACHUTE INTEGRATED SPCC PLAN Plan: PARACHUTE INTEGRATED SPCC PLAN WILLIAMS PRODUCTION RMT COMPANY SPCC Facility Specific Details Facility Name: Facility Description: Date Facility Became Operational: Facility Location: Potential Volume Capacity: Substantial Harm Determination: Well Pad Assets: Distance to Nearest Surface Water: Direction to Nearest Surface Water: General Description of Adjacent Land: P_GV 82-05 62053814 On -shore production related facility natural gas well pad with associated oil and produced water assets. 11/12/1990 State: Section: Latitude: Colorado 5 39.46452 37800 gallons Township: 7S Range: 95W 6th P.M. degrees Longitude: -108.01988 degrees This Facility does not meet the substantial harm criteria specified in 40 CFR Part 112.20. Permanent Production Equipment: Well Heads Flowlines Separators Dehydrators Oil Storage (produced water, oil/condensate, still vent drip, pits) Loadout Buckets Secondary Containment Structures Temporary Equipment and Containers: Drill rigs Bulk Fuel Tanks for Oil Hydraulic Fracturing Tanks containing Produced Water Oil and Produced Water Separators Qualified Oil -filled Equipment Other Non -SPCC Related Assets: Methanol Tanks, Piping and Pumps Biocide Tanks, Piping and Pumps Corrosion Inhibitor Tanks, Piping and Pumps 250 Feet 300 Azimuth Angle in Degrees This pad consists of one condensate tank, two produced water tanks, five gaud separators, and one dual separator, all of which are located on the west side. Nabors 577 is on location. The site is adjacent to the Colorado River. Description of Area Topography and The pad sits above a gradually sloping wetland area adjacent to the Colorado Specify Off-site Drainage Direction: River. Substantial Harm Determination Form Facility Name: P GV 82-05 62053814 Facility Location: State: Colorado Section: 5 Township: 7S Range: 95W 6th P.M. Latitude: 39.464517 degrees Longitude: -108.019883 degrees US Environmental Protection Agency (USEPA) Criteria 1. Does the non -transportation facility have a total oil storage capacity greater than or equal to 42,000 gallons and transfers oil over water to or from vessels? YES NO 2. Does the facility have a maximum oil storage capacity greater than or equal to one million (1,000,000) gallons and is the facility without secondary containment for each aboveground storage area sufficiently large to contain the capacity of the largest aboveground storage tank within the storage area? YES NO x 3. Does the facility have a maximum oil storage capacity greater than or equal to one million (1,000,000) gallons and is the facility located at a distance such that a discharge from the facility could cause injury (as defined at 40 CFR 112.2) to fish and wildlife and sensitive environments? (See Attachment C -III for the formulas to determine the distance at which an oil spill could cause injury.) YES NO 4. Does the facility have a maximum oil storage capacity greater than or equal to one million (1,000,000) gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C -III of 40 CFR 112.20 Appendix A, or an alternative formula considered acceptable by the USEPA RA), such that a discharge from the facility would shut down a public drinking water intake, which is analogous to a public water system as described in 40 CFR 143.2? YES NO x 5. Does the facility have a maximum oil storage capacity greater than or equal to one million (1,000,000) gallons and within the past 5 years, has the facility experienced a reportable spill in an amount greater than or equal to 10,000 gallons? YES NO CERTIFICATION I certify, under penalty of law, that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete. Signature: Date: Printed Name: Title: 4 Legend ; Sep, DeHy and Tanks Li Separators and Tanks IJ Separators Only r Tanks Only Separators and DeHy Existing Road Existing Pad Williams Production RMT SPCC Facility Location Map 1269 - P_GV_82-05 62053814 1:1Projects1PIC\_MulliProspech0910817 SPCC BySteISPCC.rand mreyndd 9/14/2009 1:49:30 PM 500 1,000" Feet Walla 4 Lined drilling pit Entry 1 4 Diversion ditch S4 S4 L s D Sump Entry Well head Load out Condensate Tank Separator Dehydrator Produced Water Tank Sump Entrance Still Vent Drip Tank to Facility •—•—• Road Ditch Pipe Run --► Drainage Direction ��► North Direction Fence Berm Area Facility Perimeter • SPCC Facility Plot Plan Williams Production RMT Company ' Wifilanis SPCC Plan Name: PARACHUTE FacilityName: P GV 82-05 62053814 Revision Date: Revision Number: # Condenaate/Water Tanks: 1/2 Scale: NTS Approved By: DIF Initials of Inspector: NS Date of Inspection: 9-11-09 C O ow CO 8. cs O e O A CO 0 i! LLME P GV 82-05_62053814 W E cu �U a 0 �inca7m4 N O � M V 0 W W I ' meo 0 Mr 2 m smd m a. mg 024 IA d. CV W T g CV r T- I— I— to co Cr w N ntainment Calculations and Preci V m 414 11,1 a£wCg - - N M m Calculations and Ade 0 CO M . in O r. CO N r.. 1I d $ .0 CO I C ° al RI 0 iacements Within Containme > 0 W a 1- > _yl o-0 a G r Y C c o 0 o o M 7O A 0 co aNwI N a 0 0 O 0 c o o o m M 0 1 0 0 00 0 o 0co 0 c0•' > I o .o H Algo ai c0 g0co co = a 0Ic0cqu' CO 03 OD CO 03 go ci 03 CD CO b -r .O - Y m 1W a +�� 0 °= m C ." c g f `aw' W c 0 ooc r N r N r Y F = z r �rpo o(rp fOM Mffl •-'N Mr c m go a T r q N 0 01 go to co 4' go> 0 o a E 0 .. p ,e 1 M H C C Qn � 5 iti E Y EE oc0 0 y 1 % IW m m o 0 QCQ 0 a L, C C> 0 v o I- v Imo- o e t' 1- 0 0 o os 0 0 0 H o` 0 w 1 9 Q 8 n I1 3 i k • V 0 6 115 all o 0 0 Tank Contents m '40 co id W W c 0 0 g e -NT -Ne - g N C C z E55 a.w 0.0 E to - 5 'a a 3 S c '3 N C E2 2▪ ww Q'= L C Y9a c 2 0 a� a2N Ewa .O. g 0 N O N O 8 r N g N C o l0 O m a Williams Production RMT Facility Name: PPA 41-9 62060410 Facility Specific Details for Inclusion Into the PARACHUTE INTEGRATED SPCC PLAN Plan: PARACHUTE INTEGRATED SPCC PLAN SPCC Facility Specific Details Facility Name: Facility Description: Date Facility Became Operational: Facility Location: Potential Volume Capacity: Substantial Harm Determination: Well Pad Assets: Distance to Nearest Surface Water: Direction to Nearest Surface Water: General Description of Adjacent Land: Description of Area Topography and Specify Off-site Drainage Direction: P_PA 41-9_62060410 WILLIAMS PRODUCTION RMT COMPANY On -shore production related facility natural gas well pad with associated oil and produced water assets. 4/13/2009 State: Colorado Section: 9 Township: 7S Latitude: 39.45755 degrees 29088 gallons Range: 95W 6th P.M. Longitude: -107.99675 degrees This Facility does not meet the substantial harm criteria specified in 40 CFR Part 112.20. Permanent Production Equipment: Well Heads Flowlines Separators Dehydrators Oil Storage (produced water, oil/condensate, still vent drip, pits) Loadout Buckets Secondary Containment Structures Temporary Equipment and Containers: Drill rigs Bulk Fuel Tanks for Oil Hydraulic Fracturing Tanks containing Produced Water Oil and Produced Water Separators Qualified Oil -filled Equipment Other Non -SPCC Related Assets: Methanol Tanks, Piping and Pumps Biocide Tanks, Piping and Pumps Corrosion Inhibitor Tanks, Piping and Pumps 250 Feet 45 Azimuth Angle in Degrees juniper forest, open range, oilfield development (spotty) bench above river valley, regional slope to NW off site Substantial Harm Determination Form Facility Name: PPA 41-9_62060410 Facility Location: State: Colorado Section: 9 Township: 7S Range: 95W 6th P.M. Latitude: 39.45755 degrees Longitude: -107.99675 degrees US Environmental Protection Agency (USEPA) Criteria 1. Does the non -transportation facility have a total oil storage capacity greater than or equal to 42,000 gallons and transfers oil over water to or from vessels? YES NO St 2. Does the facility have a maximum oil storage capacity greater than or equal to one million (1,000,000) gallons and is the facility without secondary containment for each aboveground storage area sufficiently large to contain the capacity of the largest aboveground storage tank within the storage area? YES NO x 3. Does the facility have a maximum oil storage capacity greater than or equal to one million (1,000,000) gallons and is the facility located at a distance such that a discharge from the facility could cause injury (as defined at 40 CFR 112.2) to fish and wildlife and sensitive environments? (See Attachment C -III for the formulas to determine the distance at which an oil spill could cause injury.) YES NO x 4. Does the facility have a maximum oil storage capacity greater than or equal to one million (1,000,000) gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C -III of 40 CFR 112.20 Appendix A, or an alternative formula considered acceptable by the USEPA RA), such that a discharge from the facility would shut down a public drinking water intake, which is analogous to a public water system as described in 40 CFR 143.2? YES NO ac 5. Does the facility have a maximum oil storage capacity greater than or equal to one million (1,000,000) gallons and within the past 5 years, has the facility experienced a reportable spill in an amount greater than or equal to 10,000 gallons? YES NO CERTIFICATION I certify, under penalty of law, that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete. Signature: Date: Printed Name: Title: rt 9 O 1,1 Feet Legend = Bap. Denyararranta Separam [Ytfa D separates OW saparatisanrl Doty Wing Road Exiting Pad aiPaqikanniciattntagravalrilttLEPIXAMaineaus /trivial 1214 a t :eswr Fitfiifafn Ftaducf art RMT tPCC Faditty Location Map 1358 - P_PA 41-9 62060414 IVI Entry 1 Entry D S2 --1 L S Well head Load Out Separator ID I Dehydrator Sump Sump Entry Entrance to Facility Condensate Tank P Produced Water Tank O Still Vent Drip Tank #1. • — • — .01 Road Ditch Pipe Run —10. Drainage Direction C,....•01. North Direction —••—••— Fence Berm Area Facility Perimeter SPCC Facility Plot Plan Williams Production RMT Company Vii%fansi SPCC Plan Name: PARACHUTE Facility Name: P PA 41-9 62060410 Revision Date: Revision Number: # Condensate/Water Tanks: 1/1 Scale: Approved By: Initials of Inspector: Date of Inspection: NTS DJF NS 2/13/09 1 PPA 41-9 62060410 9 d1 c lc LL' M r m 2 N I0 • C D— N r g m` x Yr g€a M M 2m= • N▪ r F 4 01 N w F1 O -.3 4 a m M C V) IC E 6 01 6 lel m a o. N fainmenf Calc O o0oo 0 r N A o To 00 4c E V 15 a a e c o s ° O tl LL 0e To 15a v ro V co _ co w m t Nyr m m ro a. aI v 430oIL co n Containment Area coin ats: In E < 1 S, Qop O N 10 f0 CD tl a as > I N co a' ee l -. cotl 47 i ID Y W < O) V7 ;E • 0 an P Q c c W0 to 1' 0 1- Z a U� 00 < < < tl Y .0 !0 Z ro i0 C1- c 1. to C E M < M ul O O u el I Q a 0 b c < , N M vE 5 C E rpq o C Q (0 O ra M n m 0 CC O 0 S 3 0 g. E° A a c a a C o 0. ^ E E 0 e tl tl 1- m m e o a E ! c>° f. ° . O a CO> G x c iaI- v aN tl O o ° a° ` a 0) w Secondary Containment Status Tank Contents O N NC a- OA o in O N CO 0 Ce ai I ZI wa 03 0 NLO r 72. N c E 2 0� a 1Ec e E grgr O a d • Y X20. • 0. $ e � � c Y 4q 6 y C 2 Y N o` E1 e 8 74 .2.� o a 2 0. 4-a o �▪ 0 •co.0 C' N Y N CO 0- 03 h. ma. u CO 0 Y CO CO O. Appendix F Storm Water Management Plan References STATE OF OLOFADO Bill Ritter, Jr., Govemor James B. Martin, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 TDD Line (303) 691-7700 Located in Glendale, Colorado http://www.cdphe.state.co.us June 20, 2007 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Dave Cesark, Prin Env Spec Williams Production RMT Co., P.O. Box 370 Parachute, CO 81635 970/285-9377 RE: Final Permit, Colorado Discharge Permit System — Stormwater Certification No: COR -038541 Parachute Field Garfield County Local Contact: Michael Gardner, Sr. Env Spec 970/263-2760 Dear Sir or Madam: Colorado Department of Public Health and Environment Enclosed please find a copy of the new permit and certification which have been re -issued to you under the Colorado Water Quality Control Act. Your old permit expires on June 30, 2007. This is a renewal to the permit, and replaces the old one. See page 2 of the Rationale (the pages in italics) for a summary of the changes to the permit. Your Certification under the permit requires that specific actions be performed at designated times. You are legally obligated to comply with all terms and conditions of the permit. Please read the permit and certification. If you have any questions please visit our website at : www.cdphe.state.co.us/wq/permitsunit/stormwater or contact Matt Czahor at (303) 692-3517. Sincerely, Kathryn Dolan Stormwater Program Coordinator Permits Unit WATER QUALITY CONTROL DIVISION xc: Regional Council of Governments Local County Health Department District Engineer, Technical Services, WQCD • Permit File COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT STATE OF COLOPADO 11 WATER QUALITY CONTROL DIVISION TELEPHONE: (303) 692-3500 CERTIFICATION TO DISCHARGE UNDER CDPS GENERAL PERMIT COR -030000 STORMWATER DISCHARGES ASSOCIATED WITH CONSTRUCTION Certification Number COR038541 This Certification to Discharge specifically authorizes: Williams Production RMT Co. LEGAL CONTACT: Dave Cesark, Prin Env Spec Williams Production RMT Co. P.O. Box 370 Parachute, CO 81635 Phone # 970/285-9377 dave.cesark@williams.com LOCAL CONTACT: Michael Gardner, Sr. Env Spec, Phone # 970/263-2760 michaeLgardner@williams.com During the Construction Activity: Gas/Oil Field Exploration and/or Development to discharge stormwater from the facility identified as Parachute Field which is located at: Map In File , Co Latitude 39.484, Longitude 107.991 In Garfield County to: -- Colorado River Anticipated Activity begins 07/01/2005 continuing through 06/30/2010 On 79.2 acres (79.2 acres disturbed) Certification is effective: 07/01/2007 Certification Expires: 06/30/2012 Annual Fee: $245.00 (DO NOT PAY NOW — A prorated bill will be sent shortly.) Page 1 of 22