Site Logo Colorado Oil & Gas Satellite Watch

Gunnison County, ... Oil & Gas

Gunnison County, Colorado Oil & Gas

Map Legend

Map Legend
Tank Battery Permit Pending Approved Permit Spill Flowline Flowline (other end location unknown)
Producing Well Water Test Results Horizontal Drilling Plugged and Abandoned Dry and Abandoned Abandoned Location: Permit Vacated; per Operator, Well has not been Spudded
Inspection Pit Approved Permit to Drill Wellbore; not yet Reported as Spudded; Includes Expired Permits Shut-in Well: Completed Wellbore is not Producing but is Mechanically Capable of Production Temporarily abandoned Well: Completed Wellbore not Mechanically Capable of Production without Intervention Drilling Wellbore: well has been Spudded but is not yet Reported as Completed Injection Wellbore for Waste Disposal or Secondary Recovery
Active Well : Gas Storage Well Completion or Monitor Well (Manually Assigned by COGCC Staff) Waiting for Completion: Well has been Drilled but not yet Reported as Completed Suspended Permit: Permit to Drill is Suspended until an Issue is Resolved Commingled: Multiple Wellbores Completed and Producing from the same Formation in the Well Abandoned Drilled Wellbore or Vacated Permit for Wellbore that will not be Drilled or the well has been abandoned Domestic Gas Well School

Complaints

The following 18 complaint(s) have been assigned to Gunnison County, Colorado:

  • Date Received: June 20, 2017 Document No.: 200443082 ROYALTY GUNNISON Operator: Sg Interests I Ltd Facility: Falcon Seaboard 11-90-12 Description: Location: Gunnison County, 4 miles from HWY133 on CR 265: Falcon Seaboard 11-9-12# 3 well located within the SWNE, Section 12, T.11S., R.90W., 6th P.M. (SHL) and NWNW, Section 12, T.11S., R.90W, 6th P.M. (BHL) I believe the SHL means well entrance and BHL means the terminal of the directional well. Falcon Seaboard 11-9-12 #3 (Mancos Terminal) Operator: SG INterests I, Ltd. Robert H. Guinn, II 100 Waugh Dr., Ste. 400 Houston, TX 77007 Issue: The terminal of the well is located in the the Bull Mountain Unit 600 ft. south of the Unit boundary. Our lease with SG Interests includes 80 acres outside the Bull Mountain unit but within the 640 acre drawing area (pool) of the well. No payments are being made for the area outside the unit boundary even though nearly half of the drawing area of the well is outside the unit. This includes 80 acres of my leased property as well as federal lands. I have a diagram that I can send to demonstrate this more visually. Resolution:
  • Date Received: July 10, 2015 Document No.: 200435625 ODOR GUNNISON Operator: Sg Interests I Ltd Facility: FEDERAL 11-89-17 Description: I was driving on Route 133, towards Paonia, on July 3, 2015. It was 11:15 AM, on that Friday, as I was driving down McClure's Pass, after mile Marker 40, that I was assaulted by the most extreme and dense vapors/gas from a chemical source. It was so extreme, that I thought I might pass out. It lasted for several minutes at the very extreme level and then as I drove further away, the fumes left my truck's cab. On the right of my truck, at the moment I first smelled the heavy chemical fumes, I saw liquid rushing down the mountainside. This liquid ran down the mountainside and down a ditch along the side of the highway. This liquid may or may not have been the source of the chemical fumes. There are 2 active gas well sites and companies operating in the vicinity of my exposure to the chemical vapors. The first company is SG Interests and the second company is Gunnison Energy. Route 133, mile marker 39-40, west of McClure's Pass, outside of Marble, Colorado and before Paonia, Colorado. Resolution: No sign of spill or discharge found. See Inspection Doc# 680400116
  • Date Received: May 6, 2015 Document No.: 200431768 ROADS GUNNISON Operator: Invalid Operator Facility: Description: Road Congestion, Speeding, Careless Driving, Aggressive Driving SG Interests promised to do noise, dust and road work during and after construction of the Bull Mtn. Pipeline pumping station. The county road was supposed to be widened and maintained and dust mitigation was to be in place for the initial construction of the plant as well as follow up work to keep down dust, etc. Other than the county grader, no work for this has been done by SG. They also promised only one truck a week, to do upkeep and occasionally a truck to haul away "produced" water. The trucks do not follow the rules of the road and yield to uphill traffic making hauling my horses and riding them down the road hazardous, if not nearly impossible. Resolution: Staff has attempted to contact the reporting party on several occasions; however contact with the RP was not made. It has been determined that the Cogcc does not have any authority over this facility. Mesa County has been made aware of the issues on this facility.
  • Date Received: May 6, 2015 Document No.: 200431768 NOISE GUNNISON Operator: Invalid Operator Facility: Description: See above Resolution: Staff has attempted to contact the reporting party on several occasions; however contact with the RP was not made. It has been determined that the Cogcc does not have any authority over this facility. Mesa County has been made aware of the issues on this facility.
  • Date Received: May 6, 2015 Document No.: 2542 TRASH GUNNISON Operator: Src Energy Inc Facility: Description: See above Resolution: Staff has attempted to contact the reporting party on several occasions; however contact with the RP was not made. It has been determined that the Cogcc does not have any authority over this facility. Mesa County has been made aware of the issues on this facility.
  • Date Received: May 6, 2015 Document No.: 200431768 LIGHTING GUNNISON Operator: Invalid Operator Facility: Description: see above Resolution: Staff has attempted to contact the reporting party on several occasions; however contact with the RP was not made. It has been determined that the Cogcc does not have any authority over this facility. Mesa County has been made aware of the issues on this facility.
  • Date Received: May 6, 2015 Document No.: 200431768 GROUND WATER GUNNISON Operator: Invalid Operator Facility: Description: see above Resolution: Staff has attempted to contact the reporting party on several occasions; however contact with the RP was not made. It has been determined that the Cogcc does not have any authority over this facility. Mesa County has been made aware of the issues on this facility.
  • Date Received: May 6, 2015 Document No.: 200431768 AIR QUALITY GUNNISON Operator: Invalid Operator Facility: Description: Noise and diesel, from the generators, drift downhill as well as the dust and diesel from the road to the facility have been an ongoing problem. There was supposed to be noise, sight and dust mitigation done and this has not happened. This is an ongoing problem that has been an issue ever since the facility was being built. Before approval of the Bull Mountain Pipeline, Mesa County heard the concerns of the residents of the area that was to be directly impacted by the building of this pumping station. We were assured, as well as the county commissioners, that there would be noise mitigation work completed as well as road improvements, dust mitigation and sight mitigation. In fact there was so many pictures of the promised work, they took the emphasis off of the original complaint of this not being within the best interests of the residents of the area. There have been complaints registered with county offices, commissioners and the COGCC for noise. I have not seen any follow through on getting compliance on any of the other promised, contracted work, or any sanctions for noise. The company has a history of promising to do work, but, follow through has only happened when pressured by the court system or the regulatory commissions. Since there has been no work on the obvious problems, I don't know how many other issues have been overlooked as well. We have a residence less than a half mile from the facility, downhill, and hear the noise and have the dust, traffic and accompanying noise to deal with as well as not knowing if they have done the work to stop ground pollution and water pollution to our well, the only source of water we have. Resolution: Staff has attempted to contact the reporting party on several occasions; however contact with the RP was not made. It has been determined that the Cogcc does not have any authority over this facility. Mesa County has been made aware of the issues on this facility.
  • Date Received: May 6, 2015 Document No.: 200431768 DUST GUNNISON Operator: Invalid Operator Facility: Description: see above Resolution: Staff has attempted to contact the reporting party on several occasions; however contact with the RP was not made. It has been determined that the Cogcc does not have any authority over this facility. Mesa County has been made aware of the issues on this facility.
  • Date Received: May 6, 2015 Document No.: 200431768 TRASH GUNNISON Operator: Invalid Operator Facility: Description: See above Resolution: Staff has attempted to contact the reporting party on several occasions; however contact with the RP was not made. It has been determined that the Cogcc does not have any authority over this facility. Mesa County has been made aware of the issues on this facility.
  • Date Received: March 27, 2015 Document No.: 2582 ROYALTY Operator: Invalid Operator Facility: Description: Royalty checks never on time - the last royalty check was 2 months over due - I deposited check on 02-06-2015 and check was returned - redeposited on February 11th and it cleared. Attached are E-mails to mr Pandolfo and his responses to me and Mrs. Hugueley that are totally different excuses. I have called him several times since then with no response. Resolution:
  • Date Received: Sept. 7, 2012 Document No.: 200362296 SOIL CONTAMINATION GUNNISON Operator: Invalid Operator Facility: RAGGED MOUNTAIN Description: 1. At approximately 1:00 p.m. on Tuesday, September 04, 2012 I was traveling on USFS Road 844A which leads through and past the Ragged Mountain Compressor Station. Dusty Carson of SG and Steve Tuck were in the vehicle with me. We did not stop the vehicle as we drove past the Ragged Mountain Compressor. 2. As we drove past the station, I noticed the grass on both sides of the road on the southwest edge of the Station. The grass on the west edge of the road above the inlet to a culvert was yellow and orange in color. The grass on the east edge of the road at and below the outlet of the same culvert was this same yellow and orange color. The grass appeared to be colored from a chemical “burn” or reaction. The grass surrounding the ditch and the outlet of the culvert was not discolored, but rather was green and brown as would be expected in the area. 3. At the same time I witnessed the discolored grass, I saw a pile of ¾” minus rock in a pile on the west side of the road northeast of the horizontal propane tank. This rock had not been present when I had been on location on 8-29-12. While on location with other SG personnel, Al Arsenault and Phil Nichol of Gunnison Energy Corporation has indicated/admitted there had been a release of amine from the Station. A dark stain across the road and residue on the grass above and below the culvert were visible on 8-29. 4. Later on 9-4-12, at approximately 3:00 p.m., I returned to the Ragged Mtn. Compressor Station with Dusty Carson. As I approached the Station, I witnessed a skid steer operating on and near the road. I pulled through the Station and parked my vehicle on the road. I exited my vehicle and the individual operating the skid steer suspended his operation, exited his vehicle and approached. 5. The individual, Dan Hudson of Hudson Excavation, introduced himself and asked if he could help me. 6. I introduced myself to Hudson, informing him that I worked for SG Interests and we were half owners of the Station. I asked Hudson what he was doing. Huds Resolution: Issues regarding this complaint have been addressed. See Document 2230703. AFischer
  • Date Received: Feb. 21, 2012 Document No.: 200344244 SPILLS GUNNISON Operator: Gunnison Energy Corporation Facility: HOTCHKISS 12-90 Description: Staff of SG Interests (SGI) contacted COGCC on 2/21/2012 and reported that they had discovered a release of produced water at the subject well pad on 2/9/2012. Complainant reported staff of SGI were breaking trail with snowmobiles in preparation of a site walk when the release was noticed. SGI is permitting a well on adjoining land and he site walk was to occur the following day. SGI staff reported that produced water and gas were leaking from the wellhead and that the noise from the gas leak could be heard over snowmobile engines. Complainant reported that entire area was snow-covered; roads had not been plowed, there were no tracks on the subject well pad. SGI staff reported that they estimated produced water ponding near the wellhead to be about 1 foot deep, and that the area impacted by the produced water could be seen because the melted snow. They reported ambient temperature was in the 20 degree Farenheit range, so do not believe snow was melting due to temperatures. SGI staff estimated > 20 barrels of produced water were released and reported they could see undercutting and caving of the snow covering the ephemeral drainage to the south of the well pad. SGI Staff contacted Gunnison Energy (GEC) the same day to report the problem at the well. SGI staff reported that the following day, 2/10/2012, when they conducted their site walk, they noticed that the Hotchkiss Federal 12-90 wellpad had been cleared of snow by a snowplow blade. SGI staff wanted to get a copy of the spill report submitted by GEC to the COGCC and to be copied on the spill investigation results. COGCC had not received a spill report for the Hotchkiss Federal 12-90 at the time of this call. Resolution: Gunnison has taken care of the spill cleanup. Confirmation samples are in compliance with Table 910-1. There was a remaining staining near the wellhead, that has been recently excavated. No Further Action is required. Form 19 (doc #2223856) and Form 27 (REM#7032) have been closed. Reports and lab data are available online, and open to the public. Complaint is being closed. C Lujan, 08/27/2014
  • Date Received: Aug. 31, 2011 Document No.: 200319852 INACTIVE WELL GUNNISON Operator: Invalid Operator Facility: FEDERAL Description: The well appears to be abandoned Resolution: Operator has filed for bankruptcy
  • Date Received: Aug. 12, 2010 Document No.: 3924 GROUND WATER Operator: Magpie Operating, Inc Facility: Description: Bob Remmerde called to request that his domestic water well be sampled. Gunnison Energy is preparing to drill nearby and he is concerned about his well. Resolution: SUMMARY LETTER SENT TO LANDOWNER.
  • Date Received: Jan. 6, 2010 Document No.: 200226156 OTHER GUNNISON Operator: Sg Interests I Ltd Facility: FEDERAL 11-90-15 Description: Operator has faild to file the mud log or a completion report in a timely manner as per the COGCC rules. It is believed this is intentionally done to prevent other operators from competing with SG. Resolution: Please see Form 18A Doc # 200253661 for 18A close out info. This 18A entered to close Form 18.
  • Date Received: Jan. 6, 2010 Document No.: 200226156 OTHER GUNNISON Operator: Sg Interests I Ltd Facility: FEDERAL 11-90-15 Description: Operator has faild to file the mud log or a completion report in a timely manner as per the COGCC rules. It is believed this is intentionally done to prevent other operators from competing with SG. Resolution: Please see Form 18A Doc # 200253661 for 18A close out info. This 18A entered to close Form 18.
  • Date Received: Jan. 6, 2010 Document No.: 200226156 OTHER GUNNISON Operator: Sg Interests I Ltd Facility: FEDERAL 11-90-15 Description: Operator has faild to file the mud log or a completion report in a timely manner as per the COGCC rules. It is believed this is intentionally done to prevent other operators from competing with SG. Resolution: Please see Form 18A Doc # 200253661 for 18A close out info. This 18A entered to close Form 18.

NOAVs

COGCC has issued 36 NOAVs in Gunnison County, Colorado:

Document No.: 200226184 Enforcement Action: Final Resolution Comment: No Action

Document No.: 200257623 Enforcement Action: Final Resolution Comment: NOAV resolved. Following Linda’s approval the pit was fully backfilled and the surface reclaimed. A bore hole was drilled across the road and no water was encountered (see Phase III report on file). Carlos Lujan did a Site Visit on 08/07/2013 and confirmed pit backfill and reclamation.

Document No.: 200285651 Enforcement Action: Final Resolution Comment: RECIVED EMAIL FROM THEODORE J. HARTL STATING THAT RIVIERA DRILLING & EXPLORATION HAS FILED FOR CHAPTER 11 BANKRUPTCY IN THE STATE OF COLORADO. CASE NO. 10-11902-HRT, FILED 12/23/2010.

Document No.: 200285652 Enforcement Action: Final Resolution Comment: RECIVED EMAIL FROM THEODORE J. HARTL STATING THAT RIVIERA DRILLING & EXPLORATION HAS FILED FOR CHAPTER 11 BANKRUPTCY IN THE STATE OF COLORADO. CASE NO. 10-11902-HRT, FILED 12/23/2010.

Document No.: 200285655 Enforcement Action: Final Resolution Comment: RECEIVED EMAIL FROM THEODORE J. HARTL ON 02/10/2011 STATING THAT RIVIERA DRILLING & EXPLORATION HAS FILED FOR CHAPTER 11 BANKRUPTCY IN THE STATE OF COLORADO. CASE NO. 10-11902-HRT, FILED 12/23/2010.

Document No.: 200285683 Enforcement Action: Final Resolution Comment: RECEIVED EMAIL FROM THEODORE J. HARTL ON 02/10/2011 STATING THAT RIVIERA DRILLING & EXPLORATION HAS FILED FOR CHAPTER 11 BANKRUPTCY IN THE STATE OF COLORADO. CASE NO. 10-11902-HRT, FILED 12/23/2010.

Document No.: 200285660 Enforcement Action: Final Resolution Comment: RECEIVED EMAIL FROM THEODORE J. HARTL ON 02/10/2011 STATING THAT RIVIERA DRILLING & EXPLORATION HAS FILED FOR CHAPTER 11 BANKRUPTCY IN THE STATE OF COLORADO. CASE NO. 10-11902-HRT, FILED 12/23/2010.

Document No.: 200285656 Enforcement Action: Final Resolution Comment: RECEIVED EMAIL FROM THEODORE J. HARTL ON 02/10/2011 STATING THAT RIVIERA DRILLING & EXPLORATION HAS FILED FOR CHAPTER 11 BANKRUPTCY IN THE STATE OF COLORADO. CASE NO. 10-11902-HRT, FILED 12/23/2010.

Document No.: 200285670 Enforcement Action: Final Resolution Comment: RECEIVED EMAIL FROM THEODORE J. HARTL ON 02/10/2011 STATING THAT RIVIERA DRILLING & EXPLORATION HAS FILED FOR CHAPTER 11 BANKRUPTCY IN THE STATE OF COLORADO. CASE NO. 10-11902-HRT, FILED 12/23/2010.

Document No.: 200285690 Enforcement Action: Final Resolution Comment: RECEIVED EMAIL FROM THEODORE J. HARTL ON 02/10/2011 STATING THAT RIVIERA DRILLING & EXPLORATION HAS FILED FOR CHAPTER 11 BANKRUPTCY IN THE STATE OF COLORADO. CASE NO. 10-11902-HRT, FILED 12/23/2010.

Document No.: 200285657 Enforcement Action: Final Resolution Comment: RECEIVED EMAIL FROM THEODORE J. HARTL ON 02/10/2011 STATING THAT RIVIERA DRILLING & EXPLORATION HAS FILED FOR CHAPTER 11 BANKRUPTCY IN THE STATE OF COLORADO. CASE NO. 10-11902-HRT, FILED 12/23/2010.

Document No.: 200285675 Enforcement Action: Final Resolution Comment: RECEIVED EMAIL FROM THEODORE J. HARTL ON 02/10/2011 STATING THAT RIVIERA DRILLING & EXPLORATION HAS FILED FOR CHAPTER 11 BANKRUPTCY IN THE STATE OF COLORADO. CASE NO. 10-11902-HRT, FILED 12/23/2010.

Document No.: 200285658 Enforcement Action: Final Resolution Comment: RECEIVED EMAIL FROM THEODORE J. HARTL ON 02/10/2011 STATING THAT RIVIERA DRILLING & EXPLORATION HAS FILED FOR CHAPTER 11 BANKRUPTCY IN THE STATE OF COLORADO. CASE NO. 10-11902-HRT, FILED 12/23/2010.

Document No.: 200290857 Enforcement Action: Final Resolution Comment: No Action.

Document No.: 200437638 Enforcement Action: Final Resolution Comment:

Document No.: 401562370 Rule: 1102 Rule Description: Operations, Maintenance, and Repair Alleged Violation Description: Pursuant to Rule 1102.a.(1), Gunnison Energy LLC (“GE”) shall take reasonable precautions to prevent failures, leakage and corrosion of pipelines. During a walkthrough on July 27, 2017, in anticipation of an upcoming flow pattern change, GE personnel noted that a gate valve on a pipeline riser had leaked (Spill/Release ID 451553) for an unknown period of time. Dead grass and shrubs were observed (Document Nos. 401358421 and 401378235) where produced water periodically sprayed from the valve. The subject pipeline transports produced water pumped from the Deadman Gulch U Hotchkiss Fed #20-12D (API No. 05-051-06082) to the injection well Hotchkiss 1289 #18-22D (API No. 05-051-06073) GE reported the spill to COGCC on Initial Form 19 on July, 28, 2018, and filed supplemental Form 19s on August 7, 2017 and August 16, 2017, (Document Nos. 401358421, 401367007, and 401378136). On August 10, 2017, COGCC Staff conducted an environmental field inspection of the release (Document No. 689100032) and observed an area of approximately 4,000 square feet that was impacted. Vegetation including sagebrush was dead. GE personnel stated that the valve was cracked open and they did not know when the release started. On the August 16, 2017, Supplemental Form 19, GE documented a plan to prevent future spills: “to prevent future pipeline spills, we have implemented the following: 1) Purchased a drone with a high resolution camera and GPS, plus established a quarterly schedule for visual surveillance of our gas and water gathering pipelines; 2) Established a schedule of monthly inspection of all pipeline risers by our pumpers; 3) Established an operator training program to train our pumpers in pipeline maintenance and monitoring” (Document No. 401378136). COGCC Staff evaluated this plan and determined that the three precautions are reasonable, not cost prohibitive, and any one of them could have and should have been implemented prior to this event to prevent its occurrence. Operator failed to take reasonable precautions to prevent the failure and leakage discovered on July 27, 2017, in violation of Rule 1102. Enforcement Action: Corrective Action Description: GE shall develop and submit to COGCC written documentation of the following: (1) Root cause analysis of the valve failure, to include (1.1) Make, model, pressure rating, and temperature rating of the failed valve; (1.2) All available pressure testing and maintenance records pertaining to the failed valve; and (1.3) Determination of the root cause of the valve failure; and (2) Prevention plan that addresses how this problem will be avoided in the future by use of engineering, pressure testing of this flowline, management, and training actions as necessary. This plan shall include: (2.1) GE’s standard operating procedure for conducting “routine inspections”; (2.2) Specifics of the frequency of “routine inspections” both as of the discovery of this failed valve and as of the present; (2.3) Determination of how reoccurrence of the failure of this and similar pipeline gate valves in use by GE will be prevented; and (2.4) Pipeline valve maintenance and inspection program in accordance with manufacturer’s recommendations, industry standards and best practices. GE shall develop and submit a map of their produced water gathering system showing all connections, risers, valves, et cetera, and covering their operations in Sections 7, 8, 17, 18, 19, 20, 21, and 30, Township 12 South, Range 89 West. Final Resolution Comment:

Document No.: 401562370 Rule: 324A.a Rule Description: General Environmental Protection Alleged Violation Description: Pursuant to Rule 324A.a., Gunnison Energy LLC (“GE”), shall take precautions to prevent significant adverse environmental impacts to air, water, soil, or biological resources to the extent necessary to protect public health, safety and welfare, including the environment and wildlife resources, taking into consideration cost-effectiveness and technical feasibility to prevent the unauthorized discharge or disposal of oil, gas, E&P waste, chemical substances, or other oilfield waste. During a walkthrough on July 27, 2017, in anticipation of an upcoming flow pattern change, GE personnel noted that a gate valve on a pipeline riser had leaked (Spill/Release ID 451553) for an unknown period of time. Dead grass and shrubs were observed (Document Nos. 401358421 and 401378235) where produced water periodically sprayed from the valve. The subject pipeline transports produced water pumped from the Deadman Gulch U Hotchkiss Fed #20-12D (API No. 05-051-06082) to the injection well Hotchkiss 1289 #18-22D (API No. 05-051-06073) GE reported the spill to COGCC on Initial Form 19 on July, 28, 2018, and filed supplemental Form 19s on August 7, 2017 and August 16, 2017, (Document Nos. 401358421, 401367007, and 401378136). On August 10, 2017, COGCC Staff conducted an environmental field inspection of the release (Document No. 689100032) and observed an area of approximately 4,000 square feet that was impacted. Vegetation including sagebrush was dead. GE personnel stated that the valve was partially open and they did not know when the release started. The subject pipeline traverses an area mapped by Colorado Parks and Wildlife as sensitive wildlife habitat for critical winter range for mule deer--adequate winter vegetative forage is one reason mule deer rely on this area. GE submitted an Initial and a Supplemental Form 27 Site Investigation and Remediation Workplan on August 16 and October 19, 2017, respectively, (Document Nos. 401378136 and 401435733). According to the disposal manifests (Document No. 401435770) GE submitted with the October 2017 Form 27, GE excavated approximately 463 tons of E&P waste impacted material between August 31 and September 27, 2017, for offsite disposal. After this remediation effort, electrical conductivity (“EC”) and sodium adsorption ratio (“SAR”) levels remained at concentrations above COGCC Table 910-1, as documented by samples collected on September 8 and 21, 2017 (Document Nos. 401378235 and 401435733). On the August 16, 2017, Supplemental Form 19, GE documented a plan to prevent future spills: “to prevent future pipeline spills, we have implemented the following: 1) Purchased a drone with a high resolution camera and GPS, plus established a quarterly schedule for visual surveillance of our gas and water gathering pipelines; 2) Established a schedule of monthly inspection of all pipeline risers by our pumpers; 3) Established an operator training program to train our pumpers in pipeline maintenance and monitoring” (Document No. 401378136). COGCC Staff evaluated this plan and determined that the three precautions are reasonable, not cost prohibitive, and any one of them could have and should have been implemented prior to this event to prevent its occurrence. GE failed to take reasonable precautions to prevent the unauthorized discharge of E&P waste from this gate valve, in violation of Rule 324A.a. This discharge resulted in loss of vegetation in critical winter range for mule deer and exceedances of pollutant concentration standards that persist even after the removal of over 460 tons of Enforcement Action: Corrective Action Description: GE shall submit to COGCC a Supplemental Form 27 – Site Investigation and Remediation Workplan containing and implementing plans for completing a sensitive area determination in accordance with Rule 901.e. GE shall comply with Rule 901.f. for operations in sensitive areas. GE shall incorporate adequate measures and controls to prevent significant adverse environmental impacts. GE shall review all similar gate valves throughout their entire operations incorporating adequate measures and controls to prevent significant environmental impacts.. GE shall provide to the COGCC the specific measure and controls they have implemented. GE shall submit an annual summary of results of quarterly visual or drone monitoring, monthly inspections of pipeline risers, and evidence of operator training program at a mutually agreed upon calendar date. GE shall monitor the remediated and reclaimed area for revegetation, weeds, and stormwater erosion monthly at a minimum until the remediated and reclaimed area meets the final reclamation threshold of Rule 1004.c. Final Resolution Comment:

Document No.: 401562370 Rule: 1101 Rule Description: Installation and Reclamation Alleged Violation Description: Pursuant to Rule 1101., Gunnison Energy LLC (“GE”) is required to install pipelines with materials, design, and cover sufficient to maintain structural integrity and prevent failure. Operator is also required to pressure test flowline segments at the maximum anticipated operating pressure prior to operating that segment. During a walkthrough on July 27, 2017, in anticipation of an upcoming flow pattern change, GE personnel noted that a gate valve on a pipeline riser had leaked (Spill/Release ID 451553) for an unknown period of time. Dead grass and shrubs were observed (Document Nos. 401358421 and 401378235) where produced water periodically sprayed from the valve. GE failed to install this pipeline riser gate valve with materials and design sufficient to maintain structural integrity and prevent failure, in violation of Rule 1101. Enforcement Action: Corrective Action Description: GE shall develop and submit to COGCC written documentation of the following: (1) Root cause analysis of the valve failure, to include (1.1) Make, model, pressure rating, and temperature rating of the failed valve; (1.2) All available pressure testing and maintenance records pertaining to the failed valve; and (1.3) Determination of the root cause of the valve failure; and (2) Prevention plan that addresses how this problem will be avoided in the future by use of engineering, pressure testing of this flowline, management, and training actions as necessary. This plan shall include: (2.1) GE’s standard operating procedure for conducting “routine inspections”; (2.2) Specifics of the frequency of “routine inspections” both as of the discovery of this failed valve and as of the present; (2.3) Determination of how reoccurrence of the failure of this and similar pipeline gate valves in use by GE will be prevented; and (2.4) Pipeline valve maintenance and inspection program in accordance with manufacturer’s recommendations, industry standards and best practices. Final Resolution Comment:

Document No.: 401562370 Rule: 605.d Rule Description: O&G Facilities - Mechanical Conditions Alleged Violation Description: Pursuant to Rule 605.d., Gunnison Energy LLC (“GE”) shall keep all valves, pipes, and fittings securely fastened; inspected at regular intervals; and maintained in good mechanical condition. During a walkthrough on July 27, 2017, in anticipation of an upcoming flow pattern change, GE personnel noted that a gate valve on a pipeline riser had leaked (Spill/Release ID 451553) for an unknown period of time. Dead grass and shrubs were observed (Document Nos. 401358421 and 401378235) where produced water periodically sprayed from the valve. On August 10, 2017, COGCC Staff conducted an environmental field inspection of the release (Document No. 689100032) and observed an area of approximately 4,000 square feet that was impacted. Vegetation including sagebrush was dead. GE personnel stated that the valve was partially open and they did not know when the release started. GE failed to keep this pipeline riser gate valve securely fastened and maintained in good mechanical condition, in violation of Rule 605.d. Enforcement Action: Corrective Action Description: GE shall develop and submit to COGCC written documentation of the following: (1) Root cause analysis of the valve failure, to include (1.1) Make, model, pressure rating, and temperature rating of the failed valve; (1.2) All available pressure testing and maintenance records pertaining to the failed valve; and (1.3) Determination of the root cause of the valve failure; and (2) Prevention plan that addresses how this problem will be avoided in the future by use of engineering, pressure testing of this flowline, management, and training actions as necessary. This plan shall include: (2.1) GE’s standard operating procedure for conducting “routine inspections”; (2.2) Specifics of the frequency of “routine inspections” both as of the discovery of this failed valve and as of the present; (2.3) Determination of how reoccurrence of the failure of this and similar pipeline gate valves in use by GE will be prevented; and (2.4) Pipeline valve maintenance and inspection program in accordance with manufacturer’s recommendations, industry standards and best practices. Final Resolution Comment:

Document No.: 401562370 Rule: 907.a Rule Description: General E&P Waste management Requirements Alleged Violation Description: Pursuant to Rule 907.a.(1), Gunnison Energy LLC (“GE”) shall ensure that E&P waste is properly stored, handled, transported, treated, recycled, or disposed to prevent threatened or actual significant adverse environmental impacts to air, water, soil or biological resources or to the extent necessary to ensure compliance with the concentration levels in Table 910-1, with consideration to WQCC groundwater standards and classifications. During a walkthrough on July 27, 2017, in anticipation of an upcoming flow pattern change, GE personnel noted that a gate valve on a pipeline riser had leaked (Spill/Release ID 451553) for an unknown period of time. Dead grass and shrubs were observed (Document Nos. 401358421 and 401378235) where produced water periodically sprayed from the valve. The subject pipeline transports produced water pumped from the Deadman Gulch U Hotchkiss Fed #20-12D (API No. 05-051-06082) to the injection well Hotchkiss 1289 #18-22D (API No. 05-051-06073) GE submitted an Initial and two Supplemental Form 19 Spill Reports between July 28 and August 16, 2017. Analytical results from a July 31, 2017, sampling event indicated that soil was impacted with hydrocarbons above Table 910-1. Additionally, electrical conductivity (“EC”) and sodium adsorption ratio (“SAR”) exceeded COGCC Table 910-1 concentration levels. (Document Nos. 401358421, 401367007, and 401378136) On August 10, 2017, COGCC Staff conducted an environmental field inspection of the release (Document No. 689100032) and observed an area of approximately 4,000 square feet that was impacted. Vegetation including sagebrush was dead. GE personnel stated that they did not know when the release started. The subject pipeline traverses an area mapped by Colorado Parks and Wildlife as sensitive wildlife habitat for critical winter range for mule deer--adequate winter vegetative forage is one reason mule deer rely on this area. GE submitted an Initial and a Supplemental Form 27 Site Investigation and Remediation Workplanon August 16 and October 19, 2017, respectively, (Document Nos. 401378136 and 401435733). According to the disposal manifests (Document No. 401435770) GE submitted with the October 2017 Form 27, GE excavated approximately 463 tons of E&P waste impacted material between August 31 and September 27, 2017, for offsite disposal. After this remediation effort, electrical conductivity (“EC”) and sodium adsorption ratio (“SAR”) levels remained at concentrations above COGCC Table 910-1, as documented by samples collected on September 8 and 21, 2017 (Document Nos. 401378235 and 401435733). On the August 16, 2017, Supplemental Form 19, GE documented a plan to prevent future spills: “to prevent future pipeline spills, we have implemented the following: 1) Purchased a drone with a high resolution camera and GPS, plus established a quarterly schedule for visual surveillance of our gas and water gathering pipelines; 2) Established a schedule of monthly inspection of all pipeline risers by our pumpers; 3) Established an operator training program to train our pumpers in pipeline maintenance and monitoring” (Document No. 401378136). COGCC Staff evaluated this plan and determined that the three precautions are reasonable, not cost prohibitive, and any one of them could have and should have been implemented prior to this event to prevent its occurrence. GE failed to manage its E&P Waste in a manner to prevent threatened or actual significant adverse environmental impacts to air, water, soil or biological resources or to the extent necessary to Enforcement Action: Corrective Action Description: GE shall submit to COGCC a Supplemental Form 27 – Site Investigation and Remediation Workplan containing and implementing plans for completing a sensitive area determination in accordance with Rule 901.e. GE also shall monitor remediated and reclaimed area for revegetation, weeds, and stormwater erosion on a monthly basis until the the reclaimed area is reclaimed in accordance with Rule 1003. Final Resolution Comment:

Document No.: 401840466 Rule: 1102 Rule Description: Operations, Maintenance, and Repair Alleged Violation Description: Pursuant to Rule 1102.i.(1), Gunnison Energy LLC (“GE”) must take reasonable precautions to prevent failures and leakage, and minimize corrosion of flowlines. On May 16, 2018, GE discovered an area of dead and stressed vegetation near a produced water gathering line hi-vent. GE submitted an Initial and a Supplemental Form 19 Spill/Release Report for the spill (Spill/Release ID 455150) on May 18 and May 31, 2018, respectively (Doc. Nos. 401645742 and 401658336, respectively). GE excavated the gathering line to expose the lower valve, which was intact. GE stated that the hi-vent valve separated due to ice formation. GE replaced the upper valve and added a new bull plug and an insulating blanket. GE failed to take reasonable precautions, such as adequately insulating the valve, to prevent a failure of or leakage from the hi-vent valve, resulting in a release, thereby violating Rule 1102.i.(1). Enforcement Action: Corrective Action Description: GE shall develop and submit to COGCC written documentation of the following: (1) Root cause analysis of the valve failure, to include (1.1) Make, model, pressure rating, and temperature rating of the failed valve; (1.2) All available pressure testing and maintenance records pertaining to the failed valve; and (1.3) Determination of the root cause of the valve failure; and (2) Prevention plan that addresses how this problem will be avoided in the future by use of engineering, pressure testing of this flowline, management, and training actions as necessary. This plan shall include: (2.1) GE’s standard operating procedure for conducting “routine inspections”; (2.2) Specifics of the frequency of “routine inspections” both as of the discovery of this failed valve and as of the present; (2.3) Determination of how reoccurrence of the failure of this and similar pipeline gate valves in use by GE will be prevented; and (2.4) Pipeline valve maintenance and inspection program in accordance with manufacturer’s recommendations, industry standards and best practices. GE shall develop and submit a map of their produced water gathering system showing all connections, risers, valves, et cetera, and covering their operations in the various Sections of Townships 11 and 12 South, Range 90 West and in the various Sections of Township 12 South, Range 89 West. Final Resolution Comment:

Document No.: 401840466 Rule: 1102 Rule Description: Operations, Maintenance, and Repair Alleged Violation Description: Pursuant to Rule 1102.c., Gunnison Energy LLC (“GE”) must design each component of a flowline to: prevent failure by minimizing internal or external corrosion and the effects of transported fluids; and withstand anticipated external pressures and loads that will be imposed on the pipe after installation. On May 16, 2018, GE discovered an area of dead and stressed vegetation near a produced water gathering line hi-vent. GE submitted an Initial and a Supplemental Form 19 Spill/Release Report for the spill (Spill/Release ID 455150) on May 18 and May 31, 2018, respectively (Document Nos. 401645742 and 401658336, respectively). GE excavated the gathering line to expose the lower valve, which was intact. GE stated that the hi-vent valve separated due to ice formation. GE replaced the upper valve and added a new bull plug and an insulating blanket. GE failed to design the vent and valve to prevent failure by minimizing the effects of transported fluids, resulting in a release, thereby violating Rule 1102.c. Enforcement Action: Corrective Action Description: GE shall develop and submit to COGCC written documentation of the following: (1) Root cause analysis of the valve failure, to include (1.1) Make, model, pressure rating, and temperature rating of the failed valve; (1.2) All available pressure testing and maintenance records pertaining to the failed valve; and (1.3) Determination of the root cause of the valve failure; and (2) Prevention plan that addresses how this problem will be avoided in the future by use of engineering, pressure testing of this flowline, management, and training actions as necessary. This plan shall include: (2.1) GE’s standard operating procedure for conducting “routine inspections”; (2.2) Specifics of the frequency of “routine inspections” both as of the discovery of this failed valve and as of the present; (2.3) Determination of how reoccurrence of the failure of this and similar pipeline gate valves in use by GE will be prevented; and (2.4) Pipeline valve maintenance and inspection program in accordance with manufacturer’s recommendations, industry standards and best practices. Final Resolution Comment:

Document No.: 401840466 Rule: 324A.a Rule Description: General Environmental Protection Alleged Violation Description: Pursuant to Rule 324A.a, Gunnison Energy LLC (“GE”) shall take precautions to prevent significant adverse environmental impacts to air, water, soil, or biological resources to the extent necessary to protect public health, safety and welfare, including the environment and wildlife resources, taking into consideration cost-effectiveness and technical feasibility to prevent the unauthorized discharge or disposal of oil, gas, E&P waste, chemical substances, trash, discarded equipment or other oil field waste. On May 16, 2018, GE discovered an area of dead and stressed vegetation near a produced water gathering line hi-vent. GE submitted an Initial and a Supplemental Form 19 Spill/Release Report for the spill (Spill/Release ID 455150) on May 18 and May 31, 2018, respectively (Document Nos. 401645742 and 401658336, respectively). GE excavated the gathering line to expose the lower valve, which was intact. GE stated that the hi-vent valve separated due to ice formation. GE replaced the upper valve and added a new bull plug. On June 14, 2018, COGCC Staff conducted an environmental inspection (Document No. 688800160) and observed an approximate 200’ by 20’ area of stressed and dead vegetation. No fluids were observed during the inspection. Staff observed an open excavation around the valve sets. Staff conducted a second environmental inspection of the site on October 9, 2018 (Document No. 688800313). During this inspection, Staff observed that the gas valve was closed and had a bull plug in it. Staff also observed an insulating blanket covering the water line vent valve. On June 8, 2018, GE submitted its initial Form 27, Site Investigation and Remediation Workplan (Document No. 401666950). Sampling conducted by GE on May 17, 2018, indicated that electrical conductivity and sodium adsorption ratio were above standards in COGCC Table 910-1 (Document No. 401658357). GE failed to take reasonable precautions to prevent the unauthorized discharge of E&P waste from the vent valve, in violation of Rule 324A.a. The resultant discharge resulted in significant adverse environmental impacts to soil, biological resources and exceedances of Table 910-1 concentration levels. Enforcement Action: Corrective Action Description: GE shall submit an eForm 27 Site Investigation and Remediation Workplan for the investigation of environmental impacts, and remediation of the impacted area. If initial sampling results exceed Table 910-1, GE shall provide a written plan for remediation of impacted material. GE shall monitor any remediated and/or reclaimed area for revegetation, weeds, and storm water erosion monthly at a minimum until the remediated and reclaimed areas meet the final reclamation threshold of Rule 1004.c. Final Resolution Comment:

Document No.: 401840466 Rule: 605.d Rule Description: O&G Facilities - Mechanical Conditions Alleged Violation Description: Pursuant to Rule 605.d.; Gunnison Energy LLC (“GE”) shall keep all valves, pipes and fittings securely fastened, inspected at regular intervals, and maintained in good mechanical condition. On May 16, 2018, GE discovered an area of dead and stressed vegetation near a produced water gathering line hi-vent. GE submitted an Initial and a Supplemental Form 19 Spill/Release Report for the spill (Spill/Release ID 455150) on May 18 and May 31, 2018, respectively (Document Nos. 401645742 and 401658336, respectively). GE excavated the gathering line to expose the lower valve, which was intact. GE stated that the hi-vent valve separated due to ice formation. GE replaced the upper valve and added a new bull plug. GE failed to inspect the vent valve at regular intervals and maintain the valve in good mechanical condition, in violation of Rule 605.d. Enforcement Action: Corrective Action Description: GE shall submit an eForm 27 Site Investigation and Remediation Workplan for the investigation of environmental impacts, and remediation of the impacted area. GE shall develop and submit a prevention plan that addresses how this problem will be avoided in the future by use of engineering, pressure testing of this flowline, management, and training actions as necessary. This plan shall include: (1) GE’s standard operating procedure for conducting “routine inspections”; (2) Specifics of the frequency of “routine inspections” both as of the discovery of this failed valve and as of the present; (3) Determination of how reoccurrence of the failure of this and similar pipeline vent valves in use by GE will be prevented; and (4) Pipeline valve maintenance and inspection program in accordance with manufacturer’s recommendations, industry standards and best practices. Final Resolution Comment:

Document No.: 401840466 Rule: 907.a Rule Description: General E&P Waste management Requirements Alleged Violation Description: Pursuant to Rule 907.a.; Gunnison Energy LLC (“GE”) shall ensure that E&P waste is properly stored, handled, transported, treated, recycled, or disposed to prevent threatened or actual significant adverse environmental impacts to air, water, soil or biological resources or to the extent necessary to ensure compliance with the concentration levels in Table 910-1, with consideration to WQCC groundwater standards and classifications. On May 16, 2018, GE discovered an area of dead and stressed vegetation near a produced water gathering line hi-vent. GE submitted an Initial and a Supplemental Form 19 Spill/Release Report for the spill (Spill/Release ID 455150) on May 18 and May 31, 2018, respectively (Document Nos. 401645742 and 401658336, respectively). GE excavated the gathering line to expose the lower valve, which was intact. GE stated that the hi-vent valve separated due to ice formation. GE replaced the upper valve and added a new bull plug. On June 14, 2018, COGCC Staff conducted an environmental inspection (Document No. 688800160) and observed an approximate 200’ by 20’ area of stressed and dead vegetation. No fluids were observed during the inspection. Staff observed an open excavation around the valve sets. Staff conducted a second environmental inspection of the site on October 9, 2018, (Document No. 688800313). During this inspection, Staff observed that the gas valve was closed and had a bull plug in it. Staff also observed an insulating blanket covering the water line vent valve. On June 8, 2018, GE submitted its initial Form 27, Site Investigation and Remediation Workplan (Document No. 401666950). Sampling conducted by GE on May 17, 2018, indicated that electrical conductivity and sodium adsorption ratio were above standards in COGCC Table 910-1 (Document No. 401658357). GE failed to manage its E&P waste in a manner to prevent threatened or actual significant adverse environmental impacts to air, water, soil, or biological resources or to the extent necessary to ensure compliance with the concentration levels in Table 910-1, in violation of Rule 907.a. Enforcement Action: Corrective Action Description: GE shall submit an eForm 27 Site Investigation and Remediation Workplan for the investigation of environmental impacts, and remediation of the impacted area. GE also shall monitor any remediated and/or reclaimed area for revegetation, weeds, and stormwater erosion on a monthly basis until the reclaimed area is reclaimed in accordance with Rule 1003. Final Resolution Comment:

Document No.: 200437638 Enforcement Action: Final Resolution Comment:

Document No.: 401840466 Rule: 1102 Rule Description: Operations, Maintenance, and Repair Alleged Violation Description: Pursuant to Rule 1102.c., Gunnison Energy LLC (“GE”) must design each component of a flowline to: prevent failure by minimizing internal or external corrosion and the effects of transported fluids; and withstand anticipated external pressures and loads that will be imposed on the pipe after installation. On May 16, 2018, GE discovered an area of dead and stressed vegetation near a produced water gathering line hi-vent. GE submitted an Initial and a Supplemental Form 19 Spill/Release Report for the spill (Spill/Release ID 455150) on May 18 and May 31, 2018, respectively (Document Nos. 401645742 and 401658336, respectively). GE excavated the gathering line to expose the lower valve, which was intact. GE stated that the hi-vent valve separated due to ice formation. GE replaced the upper valve and added a new bull plug and an insulating blanket. GE failed to design the vent and valve to prevent failure by minimizing the effects of transported fluids, resulting in a release, thereby violating Rule 1102.c. Enforcement Action: Corrective Action Description: GE shall develop and submit to COGCC written documentation of the following: (1) Root cause analysis of the valve failure, to include (1.1) Make, model, pressure rating, and temperature rating of the failed valve; (1.2) All available pressure testing and maintenance records pertaining to the failed valve; and (1.3) Determination of the root cause of the valve failure; and (2) Prevention plan that addresses how this problem will be avoided in the future by use of engineering, pressure testing of this flowline, management, and training actions as necessary. This plan shall include: (2.1) GE’s standard operating procedure for conducting “routine inspections”; (2.2) Specifics of the frequency of “routine inspections” both as of the discovery of this failed valve and as of the present; (2.3) Determination of how reoccurrence of the failure of this and similar pipeline gate valves in use by GE will be prevented; and (2.4) Pipeline valve maintenance and inspection program in accordance with manufacturer’s recommendations, industry standards and best practices. Final Resolution Comment:

Document No.: 401840466 Rule: 1102 Rule Description: Operations, Maintenance, and Repair Alleged Violation Description: Pursuant to Rule 1102.i.(1), Gunnison Energy LLC (“GE”) must take reasonable precautions to prevent failures and leakage, and minimize corrosion of flowlines. On May 16, 2018, GE discovered an area of dead and stressed vegetation near a produced water gathering line hi-vent. GE submitted an Initial and a Supplemental Form 19 Spill/Release Report for the spill (Spill/Release ID 455150) on May 18 and May 31, 2018, respectively (Doc. Nos. 401645742 and 401658336, respectively). GE excavated the gathering line to expose the lower valve, which was intact. GE stated that the hi-vent valve separated due to ice formation. GE replaced the upper valve and added a new bull plug and an insulating blanket. GE failed to take reasonable precautions, such as adequately insulating the valve, to prevent a failure of or leakage from the hi-vent valve, resulting in a release, thereby violating Rule 1102.i.(1). Enforcement Action: Corrective Action Description: GE shall develop and submit to COGCC written documentation of the following: (1) Root cause analysis of the valve failure, to include (1.1) Make, model, pressure rating, and temperature rating of the failed valve; (1.2) All available pressure testing and maintenance records pertaining to the failed valve; and (1.3) Determination of the root cause of the valve failure; and (2) Prevention plan that addresses how this problem will be avoided in the future by use of engineering, pressure testing of this flowline, management, and training actions as necessary. This plan shall include: (2.1) GE’s standard operating procedure for conducting “routine inspections”; (2.2) Specifics of the frequency of “routine inspections” both as of the discovery of this failed valve and as of the present; (2.3) Determination of how reoccurrence of the failure of this and similar pipeline gate valves in use by GE will be prevented; and (2.4) Pipeline valve maintenance and inspection program in accordance with manufacturer’s recommendations, industry standards and best practices. GE shall develop and submit a map of their produced water gathering system showing all connections, risers, valves, et cetera, and covering their operations in the various Sections of Townships 11 and 12 South, Range 90 West and in the various Sections of Township 12 South, Range 89 West. Final Resolution Comment:

Document No.: 401840466 Rule: 324A.a Rule Description: General Environmental Protection Alleged Violation Description: Pursuant to Rule 324A.a, Gunnison Energy LLC (“GE”) shall take precautions to prevent significant adverse environmental impacts to air, water, soil, or biological resources to the extent necessary to protect public health, safety and welfare, including the environment and wildlife resources, taking into consideration cost-effectiveness and technical feasibility to prevent the unauthorized discharge or disposal of oil, gas, E&P waste, chemical substances, trash, discarded equipment or other oil field waste. On May 16, 2018, GE discovered an area of dead and stressed vegetation near a produced water gathering line hi-vent. GE submitted an Initial and a Supplemental Form 19 Spill/Release Report for the spill (Spill/Release ID 455150) on May 18 and May 31, 2018, respectively (Document Nos. 401645742 and 401658336, respectively). GE excavated the gathering line to expose the lower valve, which was intact. GE stated that the hi-vent valve separated due to ice formation. GE replaced the upper valve and added a new bull plug. On June 14, 2018, COGCC Staff conducted an environmental inspection (Document No. 688800160) and observed an approximate 200’ by 20’ area of stressed and dead vegetation. No fluids were observed during the inspection. Staff observed an open excavation around the valve sets. Staff conducted a second environmental inspection of the site on October 9, 2018 (Document No. 688800313). During this inspection, Staff observed that the gas valve was closed and had a bull plug in it. Staff also observed an insulating blanket covering the water line vent valve. On June 8, 2018, GE submitted its initial Form 27, Site Investigation and Remediation Workplan (Document No. 401666950). Sampling conducted by GE on May 17, 2018, indicated that electrical conductivity and sodium adsorption ratio were above standards in COGCC Table 910-1 (Document No. 401658357). GE failed to take reasonable precautions to prevent the unauthorized discharge of E&P waste from the vent valve, in violation of Rule 324A.a. The resultant discharge resulted in significant adverse environmental impacts to soil, biological resources and exceedances of Table 910-1 concentration levels. Enforcement Action: Corrective Action Description: GE shall submit an eForm 27 Site Investigation and Remediation Workplan for the investigation of environmental impacts, and remediation of the impacted area. If initial sampling results exceed Table 910-1, GE shall provide a written plan for remediation of impacted material. GE shall monitor any remediated and/or reclaimed area for revegetation, weeds, and storm water erosion monthly at a minimum until the remediated and reclaimed areas meet the final reclamation threshold of Rule 1004.c. Final Resolution Comment:

Document No.: 401840466 Rule: 605.d Rule Description: O&G Facilities - Mechanical Conditions Alleged Violation Description: Pursuant to Rule 605.d.; Gunnison Energy LLC (“GE”) shall keep all valves, pipes and fittings securely fastened, inspected at regular intervals, and maintained in good mechanical condition. On May 16, 2018, GE discovered an area of dead and stressed vegetation near a produced water gathering line hi-vent. GE submitted an Initial and a Supplemental Form 19 Spill/Release Report for the spill (Spill/Release ID 455150) on May 18 and May 31, 2018, respectively (Document Nos. 401645742 and 401658336, respectively). GE excavated the gathering line to expose the lower valve, which was intact. GE stated that the hi-vent valve separated due to ice formation. GE replaced the upper valve and added a new bull plug. GE failed to inspect the vent valve at regular intervals and maintain the valve in good mechanical condition, in violation of Rule 605.d. Enforcement Action: Corrective Action Description: GE shall submit an eForm 27 Site Investigation and Remediation Workplan for the investigation of environmental impacts, and remediation of the impacted area. GE shall develop and submit a prevention plan that addresses how this problem will be avoided in the future by use of engineering, pressure testing of this flowline, management, and training actions as necessary. This plan shall include: (1) GE’s standard operating procedure for conducting “routine inspections”; (2) Specifics of the frequency of “routine inspections” both as of the discovery of this failed valve and as of the present; (3) Determination of how reoccurrence of the failure of this and similar pipeline vent valves in use by GE will be prevented; and (4) Pipeline valve maintenance and inspection program in accordance with manufacturer’s recommendations, industry standards and best practices. Final Resolution Comment:

Document No.: 401840466 Rule: 907.a Rule Description: General E&P Waste management Requirements Alleged Violation Description: Pursuant to Rule 907.a.; Gunnison Energy LLC (“GE”) shall ensure that E&P waste is properly stored, handled, transported, treated, recycled, or disposed to prevent threatened or actual significant adverse environmental impacts to air, water, soil or biological resources or to the extent necessary to ensure compliance with the concentration levels in Table 910-1, with consideration to WQCC groundwater standards and classifications. On May 16, 2018, GE discovered an area of dead and stressed vegetation near a produced water gathering line hi-vent. GE submitted an Initial and a Supplemental Form 19 Spill/Release Report for the spill (Spill/Release ID 455150) on May 18 and May 31, 2018, respectively (Document Nos. 401645742 and 401658336, respectively). GE excavated the gathering line to expose the lower valve, which was intact. GE stated that the hi-vent valve separated due to ice formation. GE replaced the upper valve and added a new bull plug. On June 14, 2018, COGCC Staff conducted an environmental inspection (Document No. 688800160) and observed an approximate 200’ by 20’ area of stressed and dead vegetation. No fluids were observed during the inspection. Staff observed an open excavation around the valve sets. Staff conducted a second environmental inspection of the site on October 9, 2018, (Document No. 688800313). During this inspection, Staff observed that the gas valve was closed and had a bull plug in it. Staff also observed an insulating blanket covering the water line vent valve. On June 8, 2018, GE submitted its initial Form 27, Site Investigation and Remediation Workplan (Document No. 401666950). Sampling conducted by GE on May 17, 2018, indicated that electrical conductivity and sodium adsorption ratio were above standards in COGCC Table 910-1 (Document No. 401658357). GE failed to manage its E&P waste in a manner to prevent threatened or actual significant adverse environmental impacts to air, water, soil, or biological resources or to the extent necessary to ensure compliance with the concentration levels in Table 910-1, in violation of Rule 907.a. Enforcement Action: Corrective Action Description: GE shall submit an eForm 27 Site Investigation and Remediation Workplan for the investigation of environmental impacts, and remediation of the impacted area. GE also shall monitor any remediated and/or reclaimed area for revegetation, weeds, and stormwater erosion on a monthly basis until the reclaimed area is reclaimed in accordance with Rule 1003. Final Resolution Comment:

Document No.: 401562370 Rule: 605.d Rule Description: O&G Facilities - Mechanical Conditions Alleged Violation Description: Pursuant to Rule 605.d., Gunnison Energy LLC (“GE”) shall keep all valves, pipes, and fittings securely fastened; inspected at regular intervals; and maintained in good mechanical condition. During a walkthrough on July 27, 2017, in anticipation of an upcoming flow pattern change, GE personnel noted that a gate valve on a pipeline riser had leaked (Spill/Release ID 451553) for an unknown period of time. Dead grass and shrubs were observed (Document Nos. 401358421 and 401378235) where produced water periodically sprayed from the valve. On August 10, 2017, COGCC Staff conducted an environmental field inspection of the release (Document No. 689100032) and observed an area of approximately 4,000 square feet that was impacted. Vegetation including sagebrush was dead. GE personnel stated that the valve was partially open and they did not know when the release started. GE failed to keep this pipeline riser gate valve securely fastened and maintained in good mechanical condition, in violation of Rule 605.d. Enforcement Action: Corrective Action Description: GE shall develop and submit to COGCC written documentation of the following: (1) Root cause analysis of the valve failure, to include (1.1) Make, model, pressure rating, and temperature rating of the failed valve; (1.2) All available pressure testing and maintenance records pertaining to the failed valve; and (1.3) Determination of the root cause of the valve failure; and (2) Prevention plan that addresses how this problem will be avoided in the future by use of engineering, pressure testing of this flowline, management, and training actions as necessary. This plan shall include: (2.1) GE’s standard operating procedure for conducting “routine inspections”; (2.2) Specifics of the frequency of “routine inspections” both as of the discovery of this failed valve and as of the present; (2.3) Determination of how reoccurrence of the failure of this and similar pipeline gate valves in use by GE will be prevented; and (2.4) Pipeline valve maintenance and inspection program in accordance with manufacturer’s recommendations, industry standards and best practices. Final Resolution Comment:

Document No.: 401562370 Rule: 907.a Rule Description: General E&P Waste management Requirements Alleged Violation Description: Pursuant to Rule 907.a.(1), Gunnison Energy LLC (“GE”) shall ensure that E&P waste is properly stored, handled, transported, treated, recycled, or disposed to prevent threatened or actual significant adverse environmental impacts to air, water, soil or biological resources or to the extent necessary to ensure compliance with the concentration levels in Table 910-1, with consideration to WQCC groundwater standards and classifications. During a walkthrough on July 27, 2017, in anticipation of an upcoming flow pattern change, GE personnel noted that a gate valve on a pipeline riser had leaked (Spill/Release ID 451553) for an unknown period of time. Dead grass and shrubs were observed (Document Nos. 401358421 and 401378235) where produced water periodically sprayed from the valve. The subject pipeline transports produced water pumped from the Deadman Gulch U Hotchkiss Fed #20-12D (API No. 05-051-06082) to the injection well Hotchkiss 1289 #18-22D (API No. 05-051-06073) GE submitted an Initial and two Supplemental Form 19 Spill Reports between July 28 and August 16, 2017. Analytical results from a July 31, 2017, sampling event indicated that soil was impacted with hydrocarbons above Table 910-1. Additionally, electrical conductivity (“EC”) and sodium adsorption ratio (“SAR”) exceeded COGCC Table 910-1 concentration levels. (Document Nos. 401358421, 401367007, and 401378136) On August 10, 2017, COGCC Staff conducted an environmental field inspection of the release (Document No. 689100032) and observed an area of approximately 4,000 square feet that was impacted. Vegetation including sagebrush was dead. GE personnel stated that they did not know when the release started. The subject pipeline traverses an area mapped by Colorado Parks and Wildlife as sensitive wildlife habitat for critical winter range for mule deer--adequate winter vegetative forage is one reason mule deer rely on this area. GE submitted an Initial and a Supplemental Form 27 Site Investigation and Remediation Workplanon August 16 and October 19, 2017, respectively, (Document Nos. 401378136 and 401435733). According to the disposal manifests (Document No. 401435770) GE submitted with the October 2017 Form 27, GE excavated approximately 463 tons of E&P waste impacted material between August 31 and September 27, 2017, for offsite disposal. After this remediation effort, electrical conductivity (“EC”) and sodium adsorption ratio (“SAR”) levels remained at concentrations above COGCC Table 910-1, as documented by samples collected on September 8 and 21, 2017 (Document Nos. 401378235 and 401435733). On the August 16, 2017, Supplemental Form 19, GE documented a plan to prevent future spills: “to prevent future pipeline spills, we have implemented the following: 1) Purchased a drone with a high resolution camera and GPS, plus established a quarterly schedule for visual surveillance of our gas and water gathering pipelines; 2) Established a schedule of monthly inspection of all pipeline risers by our pumpers; 3) Established an operator training program to train our pumpers in pipeline maintenance and monitoring” (Document No. 401378136). COGCC Staff evaluated this plan and determined that the three precautions are reasonable, not cost prohibitive, and any one of them could have and should have been implemented prior to this event to prevent its occurrence. GE failed to manage its E&P Waste in a manner to prevent threatened or actual significant adverse environmental impacts to air, water, soil or biological resources or to the extent necessary to Enforcement Action: Corrective Action Description: GE shall submit to COGCC a Supplemental Form 27 – Site Investigation and Remediation Workplan containing and implementing plans for completing a sensitive area determination in accordance with Rule 901.e. GE also shall monitor remediated and reclaimed area for revegetation, weeds, and stormwater erosion on a monthly basis until the the reclaimed area is reclaimed in accordance with Rule 1003. Final Resolution Comment:

Document No.: 401562370 Rule: 1101 Rule Description: Installation and Reclamation Alleged Violation Description: Pursuant to Rule 1101., Gunnison Energy LLC (“GE”) is required to install pipelines with materials, design, and cover sufficient to maintain structural integrity and prevent failure. Operator is also required to pressure test flowline segments at the maximum anticipated operating pressure prior to operating that segment. During a walkthrough on July 27, 2017, in anticipation of an upcoming flow pattern change, GE personnel noted that a gate valve on a pipeline riser had leaked (Spill/Release ID 451553) for an unknown period of time. Dead grass and shrubs were observed (Document Nos. 401358421 and 401378235) where produced water periodically sprayed from the valve. GE failed to install this pipeline riser gate valve with materials and design sufficient to maintain structural integrity and prevent failure, in violation of Rule 1101. Enforcement Action: Corrective Action Description: GE shall develop and submit to COGCC written documentation of the following: (1) Root cause analysis of the valve failure, to include (1.1) Make, model, pressure rating, and temperature rating of the failed valve; (1.2) All available pressure testing and maintenance records pertaining to the failed valve; and (1.3) Determination of the root cause of the valve failure; and (2) Prevention plan that addresses how this problem will be avoided in the future by use of engineering, pressure testing of this flowline, management, and training actions as necessary. This plan shall include: (2.1) GE’s standard operating procedure for conducting “routine inspections”; (2.2) Specifics of the frequency of “routine inspections” both as of the discovery of this failed valve and as of the present; (2.3) Determination of how reoccurrence of the failure of this and similar pipeline gate valves in use by GE will be prevented; and (2.4) Pipeline valve maintenance and inspection program in accordance with manufacturer’s recommendations, industry standards and best practices. Final Resolution Comment:

Document No.: 401562370 Rule: 324A.a Rule Description: General Environmental Protection Alleged Violation Description: Pursuant to Rule 324A.a., Gunnison Energy LLC (“GE”), shall take precautions to prevent significant adverse environmental impacts to air, water, soil, or biological resources to the extent necessary to protect public health, safety and welfare, including the environment and wildlife resources, taking into consideration cost-effectiveness and technical feasibility to prevent the unauthorized discharge or disposal of oil, gas, E&P waste, chemical substances, or other oilfield waste. During a walkthrough on July 27, 2017, in anticipation of an upcoming flow pattern change, GE personnel noted that a gate valve on a pipeline riser had leaked (Spill/Release ID 451553) for an unknown period of time. Dead grass and shrubs were observed (Document Nos. 401358421 and 401378235) where produced water periodically sprayed from the valve. The subject pipeline transports produced water pumped from the Deadman Gulch U Hotchkiss Fed #20-12D (API No. 05-051-06082) to the injection well Hotchkiss 1289 #18-22D (API No. 05-051-06073) GE reported the spill to COGCC on Initial Form 19 on July, 28, 2018, and filed supplemental Form 19s on August 7, 2017 and August 16, 2017, (Document Nos. 401358421, 401367007, and 401378136). On August 10, 2017, COGCC Staff conducted an environmental field inspection of the release (Document No. 689100032) and observed an area of approximately 4,000 square feet that was impacted. Vegetation including sagebrush was dead. GE personnel stated that the valve was partially open and they did not know when the release started. The subject pipeline traverses an area mapped by Colorado Parks and Wildlife as sensitive wildlife habitat for critical winter range for mule deer--adequate winter vegetative forage is one reason mule deer rely on this area. GE submitted an Initial and a Supplemental Form 27 Site Investigation and Remediation Workplan on August 16 and October 19, 2017, respectively, (Document Nos. 401378136 and 401435733). According to the disposal manifests (Document No. 401435770) GE submitted with the October 2017 Form 27, GE excavated approximately 463 tons of E&P waste impacted material between August 31 and September 27, 2017, for offsite disposal. After this remediation effort, electrical conductivity (“EC”) and sodium adsorption ratio (“SAR”) levels remained at concentrations above COGCC Table 910-1, as documented by samples collected on September 8 and 21, 2017 (Document Nos. 401378235 and 401435733). On the August 16, 2017, Supplemental Form 19, GE documented a plan to prevent future spills: “to prevent future pipeline spills, we have implemented the following: 1) Purchased a drone with a high resolution camera and GPS, plus established a quarterly schedule for visual surveillance of our gas and water gathering pipelines; 2) Established a schedule of monthly inspection of all pipeline risers by our pumpers; 3) Established an operator training program to train our pumpers in pipeline maintenance and monitoring” (Document No. 401378136). COGCC Staff evaluated this plan and determined that the three precautions are reasonable, not cost prohibitive, and any one of them could have and should have been implemented prior to this event to prevent its occurrence. GE failed to take reasonable precautions to prevent the unauthorized discharge of E&P waste from this gate valve, in violation of Rule 324A.a. This discharge resulted in loss of vegetation in critical winter range for mule deer and exceedances of pollutant concentration standards that persist even after the removal of over 460 tons of Enforcement Action: Corrective Action Description: GE shall submit to COGCC a Supplemental Form 27 – Site Investigation and Remediation Workplan containing and implementing plans for completing a sensitive area determination in accordance with Rule 901.e. GE shall comply with Rule 901.f. for operations in sensitive areas. GE shall incorporate adequate measures and controls to prevent significant adverse environmental impacts. GE shall review all similar gate valves throughout their entire operations incorporating adequate measures and controls to prevent significant environmental impacts.. GE shall provide to the COGCC the specific measure and controls they have implemented. GE shall submit an annual summary of results of quarterly visual or drone monitoring, monthly inspections of pipeline risers, and evidence of operator training program at a mutually agreed upon calendar date. GE shall monitor the remediated and reclaimed area for revegetation, weeds, and stormwater erosion monthly at a minimum until the remediated and reclaimed area meets the final reclamation threshold of Rule 1004.c. Final Resolution Comment:

Document No.: 401562370 Rule: 1102 Rule Description: Operations, Maintenance, and Repair Alleged Violation Description: Pursuant to Rule 1102.a.(1), Gunnison Energy LLC (“GE”) shall take reasonable precautions to prevent failures, leakage and corrosion of pipelines. During a walkthrough on July 27, 2017, in anticipation of an upcoming flow pattern change, GE personnel noted that a gate valve on a pipeline riser had leaked (Spill/Release ID 451553) for an unknown period of time. Dead grass and shrubs were observed (Document Nos. 401358421 and 401378235) where produced water periodically sprayed from the valve. The subject pipeline transports produced water pumped from the Deadman Gulch U Hotchkiss Fed #20-12D (API No. 05-051-06082) to the injection well Hotchkiss 1289 #18-22D (API No. 05-051-06073) GE reported the spill to COGCC on Initial Form 19 on July, 28, 2018, and filed supplemental Form 19s on August 7, 2017 and August 16, 2017, (Document Nos. 401358421, 401367007, and 401378136). On August 10, 2017, COGCC Staff conducted an environmental field inspection of the release (Document No. 689100032) and observed an area of approximately 4,000 square feet that was impacted. Vegetation including sagebrush was dead. GE personnel stated that the valve was cracked open and they did not know when the release started. On the August 16, 2017, Supplemental Form 19, GE documented a plan to prevent future spills: “to prevent future pipeline spills, we have implemented the following: 1) Purchased a drone with a high resolution camera and GPS, plus established a quarterly schedule for visual surveillance of our gas and water gathering pipelines; 2) Established a schedule of monthly inspection of all pipeline risers by our pumpers; 3) Established an operator training program to train our pumpers in pipeline maintenance and monitoring” (Document No. 401378136). COGCC Staff evaluated this plan and determined that the three precautions are reasonable, not cost prohibitive, and any one of them could have and should have been implemented prior to this event to prevent its occurrence. Operator failed to take reasonable precautions to prevent the failure and leakage discovered on July 27, 2017, in violation of Rule 1102. Enforcement Action: Corrective Action Description: GE shall develop and submit to COGCC written documentation of the following: (1) Root cause analysis of the valve failure, to include (1.1) Make, model, pressure rating, and temperature rating of the failed valve; (1.2) All available pressure testing and maintenance records pertaining to the failed valve; and (1.3) Determination of the root cause of the valve failure; and (2) Prevention plan that addresses how this problem will be avoided in the future by use of engineering, pressure testing of this flowline, management, and training actions as necessary. This plan shall include: (2.1) GE’s standard operating procedure for conducting “routine inspections”; (2.2) Specifics of the frequency of “routine inspections” both as of the discovery of this failed valve and as of the present; (2.3) Determination of how reoccurrence of the failure of this and similar pipeline gate valves in use by GE will be prevented; and (2.4) Pipeline valve maintenance and inspection program in accordance with manufacturer’s recommendations, industry standards and best practices. GE shall develop and submit a map of their produced water gathering system showing all connections, risers, valves, et cetera, and covering their operations in Sections 7, 8, 17, 18, 19, 20, 21, and 30, Township 12 South, Range 89 West. Final Resolution Comment:

Air Quality (PM2.5 ug/m3)

EPA has taken no air quality samples in Gunnison County, Colorado.