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Huerfano County, ... Oil & Gas

Huerfano 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 45 complaint(s) have been assigned to Huerfano County, Colorado:

  • Date Received: Jan. 28, 2010 Document No.: 200229485 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: STATE Description: Mrs. Andexler expressed concerns regarding water quality at her domestic well and continued operation of the MIMMP system. Resolution: No impacts from nearby CBM operations observed in analytical results. Methane concentration is currently less than 5µg/l. No impacts observed in this groundwater source as in some Poison Canyon aquifer wells a mile or 2 to the west.
  • Date Received: Jan. 28, 2010 Document No.: 200229485 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: STATE Description: Mrs. Andexler expressed concerns regarding water quality at her domestic well and continued operation of the MIMMP system. Resolution: No impacts from nearby CBM operations observed in analytical results. Methane concentration is currently less than 5µg/l. No impacts observed in this groundwater source as in some Poison Canyon aquifer wells a mile or 2 to the west.
  • Date Received: Jan. 28, 2010 Document No.: 200229485 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: STATE Description: Mrs. Andexler expressed concerns regarding water quality at her domestic well and continued operation of the MIMMP system. Resolution: No impacts from nearby CBM operations observed in analytical results. Methane concentration is currently less than 5µg/l. No impacts observed in this groundwater source as in some Poison Canyon aquifer wells a mile or 2 to the west.
  • Date Received: Feb. 16, 2010 Document No.: 200230972 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mr. and Mrs. Derowitsch have noted increased odor of hydrogen sulfide in water from thier domestic well and are concerned about general water quality and possible impacts from MIMMP operations. Resolution: MIMMP operations by Petroglyph in the immediate vicinity of the Derowitsch domestic well have not had an adverse impact on water quality produced by the well. Dissolved methane concentrations are at levels that may pose a explosion risk even though the homeowner has installed an aerator system in the vented outdoodr cistern. Petroglyph has installed methane alarm system in the home.
  • Date Received: Feb. 16, 2010 Document No.: 200230972 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mr. and Mrs. Derowitsch have noted increased odor of hydrogen sulfide in water from thier domestic well and are concerned about general water quality and possible impacts from MIMMP operations. Resolution: MIMMP operations by Petroglyph in the immediate vicinity of the Derowitsch domestic well have not had an adverse impact on water quality produced by the well. Dissolved methane concentrations are at levels that may pose a explosion risk even though the homeowner has installed an aerator system in the vented outdoodr cistern. Petroglyph has installed methane alarm system in the home.
  • Date Received: Feb. 16, 2010 Document No.: 200230972 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mr. and Mrs. Derowitsch have noted increased odor of hydrogen sulfide in water from thier domestic well and are concerned about general water quality and possible impacts from MIMMP operations. Resolution: MIMMP operations by Petroglyph in the immediate vicinity of the Derowitsch domestic well have not had an adverse impact on water quality produced by the well. Dissolved methane concentrations are at levels that may pose a explosion risk even though the homeowner has installed an aerator system in the vented outdoodr cistern. Petroglyph has installed methane alarm system in the home.
  • Date Received: Sept. 7, 2010 Document No.: 200269713 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mrs. Angely is concerned about continuing and possible new impacts from CBM and remediation activities to groundwater quality in her domestic well. Resolution: Letter summarizing results of continued depth to water monitoring and gas flow monitoring mailed to Mrs. Angely. Gas flow has been neglible for most of the past two years and dpeth to water remained stabel except when well is used. Water quality is still not as good as when first sampled in 2007. No new impacts noted in data.
  • Date Received: Sept. 7, 2010 Document No.: 200269713 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mrs. Angely is concerned about continuing and possible new impacts from CBM and remediation activities to groundwater quality in her domestic well. Resolution: Letter summarizing results of continued depth to water monitoring and gas flow monitoring mailed to Mrs. Angely. Gas flow has been neglible for most of the past two years and dpeth to water remained stabel except when well is used. Water quality is still not as good as when first sampled in 2007. No new impacts noted in data.
  • Date Received: Sept. 7, 2010 Document No.: 200269714 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: STATE Description: Mr. and Mrs. Bounds are concerned about contiuing and possible further impacts to gorundwater quality from nearby CBM and remediation activities. Resolution: No further imapcts to groundwater noted in analyses and data available from mitigation activities in the area to the north of the Bounds property.
  • Date Received: Sept. 7, 2010 Document No.: 200269714 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: STATE Description: Mr. and Mrs. Bounds are concerned about contiuing and possible further impacts to gorundwater quality from nearby CBM and remediation activities. Resolution: No further imapcts to groundwater noted in analyses and data available from mitigation activities in the area to the north of the Bounds property.
  • Date Received: Sept. 7, 2010 Document No.: 200269714 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: STATE Description: Mr. and Mrs. Bounds are concerned about contiuing and possible further impacts to gorundwater quality from nearby CBM and remediation activities. Resolution: No further imapcts to groundwater noted in analyses and data available from mitigation activities in the area to the north of the Bounds property.
  • Date Received: May 10, 2011 Document No.: 200309903 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: STATE Description: Mr. and Mrs. Bounds are concerned regarding possible continuing impacts to groundwater accessed by their well from past CBM and ongoing mitigation activities. Resolution: Summary letter mailed and e-mailed to the Bounds. Overall water quality is consistent with previous sampling events and water quality is of overall good quality with the exception of possible safety hazards associated with the elevated concentration of dissolved methane.
  • Date Received: May 10, 2011 Document No.: 200309902 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mrs. Angely is concerned about possible impacts to groundwater quality resulting from Petroglyph's operations nearby, including MIMMP Resolution: Results of most recent sampling of Angely water well mailed to Mrs. Angely. No new impacts as a result of Phase 2 of the MIMMP were observed at this time.
  • Date Received: June 24, 2011 Document No.: 200314762 WILDFIRE HUERFANO Operator: Swepi Lp Facility: KLIKUS Description: Fire Hazard The small rural fire department at La Veta, and even Walsenburg, is not equipped to handle a fire associated with leaking gas that may ignite by accident. At a natural gas site recently, two welders were killed and the ensuing fire could not be extinguished for two days because the rural fire department did not have the kind of equipment needed to handle that type of fire. We all take extraordinary precautions these days and I am sure no one will be negligent, however, accidents happen. The services needed to handle potential fire hazards is simple not sufficient for this type of operation. Resolution: Regarding Fire Hazard: The COGCC understands the fear of fire risk, especially in light of current hot and dry conditions, however, flaring is a controlled event, engineered for safety. The well pad itself also creates a buffer area free of combustible vegetation. While many local and volunteer fire departments are not equipped to fight fires associated with production facilities, they do play a vital role in protecting public safety during such emergencies, primarily by preventing public access to a developing situation, providing information to the public, and coordinating resources to aid specialized oil field emergency response contractors who are trained and equipped to respond to catastrophic events and can mobilize to a location within hours.
  • Date Received: June 24, 2011 Document No.: 200314762 OTHER HUERFANO Operator: Swepi Lp Facility: KLIKUS Description: Unique Geology/Hydrology To my knowledge, no one has ever drilled to 14,500 in this basin. There are over 1500 radial dikes that run through the formations. To think that Shell will be able to maintain the fluids in the target area is a bit implausible. Especially since we really don’t know what the target formation is. Again, Shell does not know what they will encounter, they are keeping their options open. If they have to frack at 7,000 feet BGS, is that a target area? Resolution: Regarding the Unique Geology/Hydrology: The operator in this case is able to rely on seismic studies conducted in close proximity to the location and on data from a 10,000 foot deep well recently drilled approximately 3 miles to the southwest. Moreover, this is an exploratory well, so the operator will be constantly assessing information gathered during the drilling and completion of the well. The data gathered during the logging of the well will aid in developing a better understanding of the basin characteristics.
  • Date Received: June 24, 2011 Document No.: 200314762 STORMWATER BMPs HUERFANO Operator: Swepi Lp Facility: KLIKUS Description: The well site occupies an area with documented surface water during rains and winter run-off, and soil profiles are extremely unstable. The following is the soil profile from Natural Resources and Conservation Service. Report—Roads and Streets, Shallow Excavations, and Lawns and Landscaping [Onsite investigation may be needed to validate the interpretations in this table and to confirm the identity of the soil on a given site. The numbers in the value columns range from 0.01 to 1.00. The larger the value, the greater the potential limitation. The table shows only the top five limitations for any given soil. The soil may have additional limitations] Roads and Streets, Shallow Excavations, and Lawns and Landscaping– Huerfano County Area, Colorado Map symbol and soil name Pct. of map unit Local roads and streets Shallow excavations Lawns and landscaping Rating class and limiting features Value Rating class and limiting features Value Rating class and limiting features Value 52—Noden sandy loam, 1 to 8 percent slopes Noden 95 Very limited Somewhat limited Not limited Low strength 1.00 Unstable excavation walls 0.10 Shrink-swell 0.50 I have personally documented water and soil run-off from the intermittent drainage along CR 430 at the very site of the well. If you note the topography of the following map you will see where the well site occupies a low spot in the terrain, along an intermittent water course. THE SOILS MOVE. I don’t know how to put this more plainly. To think of placing an evaporation pond on that sight is foolhardy, the runoff will end up in Middle Creek. Resolution: Regarding Protected Areas and Buffers: The map included with your comments indicates that landowners and easement holders may not have been notified by the operator. If the operator was required to submit notifications, by Rule, but did not, we would appreciate the offended party contact us directly, so that we may take enforcement action, if warranted. The requirements for notifications and consultations are covered in Rules 305 and 306. Regarding local soil instability, our review of the available data indicated that the thickness of the unstable soil was 60 inches and that such soil will not be used for road building. The operator’s site plan which includes cut and fill information accounts for the removal of topsoil prior to pad construction; this upper soil horizon was also evaluated to be the least stable. In our review of current and recent historic aerial photographs, we observed numerous pits and ponds proximate to this location that have been in use for many years. The operator has a stormwater management plan that includes run on control above proposed cut slopes and run off controls to limit erosion and sedimentation.
  • Date Received: June 24, 2011 Document No.: 200314762 GROUND WATER HUERFANO Operator: Swepi Lp Facility: KLIKUS Description: Water Protection and Testing While the proposed well will drill to depth of 14,500 feet BGS, the actual fracking may take place multiple places along the drill course. This is a directional well, not a vertical bore, and Shell does not know what they will encounter. Shell has not committed to fracking in any identified area. Therefore, the distance to nearby wells cannot be determined. Also, there is a new agriculture structure (barn & stable) less than 2,000 feet from the proposed well. Baseline testing of well water should not be “the nearest two wells to which they have access.” The nearest two wells may or may not be domestic wells, and if the water monitors do not have full and unconditional access then testing will not take place. This must be amended to include testing within a radius of three to five miles. This is crucial and not a negotiable item for reasons of ground water movement identified further in this response. Resolution: Regarding Water Protection and Testing: The COGCC has no evidence that would support a requirement to test all wells within 3 to 5 miles of the Klikus 2-19 well. Even in cases where this agency has documented cases of water well contamination, the contaminants have not migrated such a distance. The requirement for the two nearest wells has been used throughout the state, and is appropriate, because the nearest wells are the most likely to show the first signs of impact if it were to occur. Further, we do not specify the type of well that should be considered, because it may be equally appropriate to test a shallow alluvial aquifer as a deep drinking water aquifer. Further, upon allegation of impact to a domestic water well, the COGCC will always investigate.
  • Date Received: July 14, 2011 Document No.: 200316955 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: PASSOW Description: Mr. McEntee claims that yield of water from his well has been impacted by the CBM operations of Petroglyph in Huerfano County. Resolution: Summary letter and analytical data mailed to Mr. McEntee. No meaningful measurement of well yield prior to 2010. No impact could be determined and static water level in Mcentee well is approximatley 40 feet higher than the regional Vemrjo formation wells with drawdown from CBM operations and not thought that McEntee well in good hydraulic connection with the coals produced by Petroglyph.
  • Date Received: Aug. 5, 2012 Document No.: 200358376 BASELINE WATER REQUEST HUERFANO Operator: Swepi Lp Facility: Fortune Description: Operator of the municipal supply water wells in Gardner requested baseline sampling and analysis of groundwater from two wells. Resolution: Baseline analysis results and summary letter mailed to Mr. Stephen.
  • Date Received: Sept. 28, 2012 Document No.: 200364930 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mr. and Mrs. Bounds are concerned about levels of methane and molybdenum present in water from their doemstic water well. Resolution: Concentration of Mo in samples was less than in samples collected in the spring of 2012. Source of increased Mo not determined at this point but may be from some parts or products used in installation of treatment system in the past year. Overall water quality is acceptable with safety concerns at well head due to concentration of dissolved methane. Methane was not detected in one sample from the tap in house with methane at wellhead four orders of magnitude greater concentration (before treatment).
  • Date Received: Sept. 28, 2012 Document No.: 200364929 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mrs. Angely is concerned regarding levels of sulfate and TDS present in groundwater at her domestic water well. Resolution: Water quality simialr to some previous sampling and analysis events with lower TDS and sulfate than in several previous samplings. Isotopic composition changes of methane shows signs of oxidative degradtion over the last few years. Microbial analysis indicates methanotrophic bacteria are present and in larger populations that methanogenic bacteria.
  • Date Received: Nov. 7, 2012 Document No.: 200373869 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mr. Hopke is concerned about posible changes to groundwater accessed by his domestic water well in relation to cessation of the MIMMP by Petroglyph. Resolution: Summary letter mailed to Mr. Hopke.
  • Date Received: Nov. 7, 2012 Document No.: 200373973 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mr.Smith is concerned about groundwater quality in his domestic water well following the cessation of active remediation as part of the Petroglyph MIMMP. Resolution: Summary letter mailed to Mr. Smith.
  • Date Received: Nov. 12, 2012 Document No.: 200369478 LIGHTING HUERFANO Operator: Swepi Lp Facility: Freeman Description: Rosalyn McCain called stating the lights from the drilling rig were coming into her bedroom window at night Resolution: I contacted the rig manager to ensure the lighting was in the correct postion. He agreed to check on all lighting.
  • Date Received: Dec. 13, 2012 Document No.: 200371689 GROUND WATER HUERFANO Operator: Swepi Lp Facility: Freeman Description: a) Sundry approving the change of bottom hole location was not viewable to public. b) Complainant is concerned about potential environmental impacts because the new well path is going to approach mapped volcanic dikes visible on 1:250 scale geology of COGIS MapGuide. Resolution: Staff and Director explained our opinion that the well design, and the drilling permit and location assessment are protective of water resources and the environment in general. SWEPI is aware of the mapped dikes and they do not believe they will hit any. Even if they do COGCC does not believe it would be likely to cause an environmental problem. In regard to the referenced commission order against Petroglyph Energy, it was suspected but not proven that dikes contributed to the groundwater impacts. The related investigations are posted in the Library on our website under Raton Basin. The geological situation at that location is substantially different from the Freeman 3-24 location. In addition there are many examples of CBM wells in Raton Basin that logged igneous intrusions and no problems have occurred. At present COGCC has no substantial reason to prevent SWEPI from drilling in the proposed direction. SWEPI does not plan to frac the well initially, however they have the right to do so. We explained the Sundry was not posted on the public site due to a document management mechanism within the COGCC database to keep from releasing confidential information.
  • Date Received: April 30, 2013 Document No.: 200381500 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mr. Hopke is concerned about possible changes to groundwater quality accessed by his well following the cessation of the remediation activities in his area. Resolution: No impacts from methane remediation system observed and no adverse impacts after end of mitigation operations after plugging of all CBM wells in area under order 1C-8
  • Date Received: April 30, 2013 Document No.: 200381496 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mrs. Angely is concerned about possible impacts to groundwater from the cessation of the remediation efforts with respect to the Poison Canyon aquifer. Resolution: No significant changes in groundwater quality upon cessation of methane mitigation project (Order 1C-6). No further impacts to groundwater quality observed in data from sampling and analysis.
  • Date Received: April 30, 2013 Document No.: 200381495 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: LIVELY Description: Mr. Smith is concerned about possible changes in groundwater quality from the remdiation and subsequent closure of the remediation of Poison Canyon aquifer in his area. Resolution: Cessation of groundwater mitigation efforts by Petroglyph have not adversely impacted the quality of groundwater in Mr. Smith's domestic water well.
  • Date Received: April 30, 2013 Document No.: 200381497 GROUND WATER HUERFANO Operator: Petroglyph Operating Co Inc Adba Petroglyph Energy Facility: ROHR Description: Mr. and Mrs Bounds are concerned about possible impacts to groudnwater quality in their water well following the cessation of the remediation. Resolution: No impacts in groundwater quality after cessation of methane mitigation operations (Order 1C-6) and plugging of all CBM wells in area.
  • Date Received: April 11, 2014 Document No.: 200401979 OTHER HUERFANO Operator: Swepi Lp Facility: Freeman Description: At 12:55pm,on (04/02/14) I got a call from Mike Leonard/COGCC asking me to look into a complaint on HOUSEKEEPING (hay blowing at this well site) from Mr. Redman. Resolution: On May 5, 2014 I got a call from Steve Compton of Shell. He told me the HOUSEKEEPING issues had been fixed. On May 6, 2014 (12:30pm) I went to the Freeman 3-24. The HOUSEKEEPING issues with the hay bales, that blew off well pad, have been taken care of. The unused wooden pallet has been removed. Off site at 1:00pm. On May 9, 2014 (3:00pm) I call and speak with Mrs. Redman. I told her the HOUSEKEEPING issues had been addressed. She thanked me and I told her , if Mr. Redman had any questions to give me a call.
  • Date Received: Aug. 4, 2014 Document No.: 200409835 BASELINE WATER REQUEST HUERFANO Operator: Swepi Lp Facility: State Description: Mrs. Fariss requested baseline water well sampling Resolution: Summary letter mailed to the Fariss household. Major ion water quality is similar to many shallow groundwater sources in the Raton Basin. Baseline complaint closed with submission of results to Mr. and Mrs. Fariss.
  • Date Received: Aug. 19, 2014 Document No.: 200410625 LAND USE CONFLICT HUERFANO Operator: Oxy Usa Inc Facility: Sheep Mountain Unit Description: (08/15/14) @ 7:45 am :I got a call from Carrol Koscove asking me to meet her at 10:00 am on (08/27/14). She was not happy with the way Oxy was using her land. She said her trees were gone and according to Aaron Richter/BLM, Oxy had cut the trees before permits were issued. Where the trees were, now there is knapweed. Also there was some type of (creekbed or spring) in area. Resolution: Oxy had started construction of one pad prior to approval of the 2A for that location which resulted in an NOAV and subsequently 1V-527 was brought before the Commission in September of 2015. Operator was given to this spring to resolve weed problems. Other issues were not subject to COGCC rules.
  • Date Received: Oct. 29, 2014 Document No.: 200416010 WEEDS HUERFANO Operator: Oxy Usa Inc Facility: Sheep Mountain Unit Description: "Noxious weeds have increased 90% since OXY took over operation at Sheep Mountain Unit. I first contacted OXY June 2011. Since then the noxious weeds have spread 90% more." Resolution: The COGCC implemented a new public complaint process on January 8, 2015. This complaint was received prior to the new process and was either investigated and resolved without formal documentation or was not fully investigated. COGCC staff reviewed historical documents and could not find information on the complaint investigation and due to time will now close the complaint.
  • Date Received: Oct. 29, 2014 Document No.: 200416010 FENCING HUERFANO Operator: Oxy Usa Inc Facility: Sheep Mountain Unit Description: "Damaged cattle guards." Resolution: The COGCC implemented a new public complaint process on January 8, 2015. This complaint was received prior to the new process and was either investigated and resolved without formal documentation or was not fully investigated. COGCC staff reviewed historical documents and could not find information on the complaint investigation and due to time will now close the complaint.
  • Date Received: Oct. 29, 2014 Document No.: 200416010 OTHER HUERFANO Operator: Oxy Usa Inc Facility: Sheep Mountain Unit Description: "Crushed 15000 tons of rock from my property. Did not have a permit to crush the rock." Resolution: The COGCC implemented a new public complaint process on January 8, 2015. This complaint was received prior to the new process and was either investigated and resolved without formal documentation or was not fully investigated. COGCC staff reviewed historical documents and could not find information on the complaint investigation and due to time will now close the complaint.
  • Date Received: Oct. 29, 2014 Document No.: 200416010 PROPERTY DAMAGE HUERFANO Operator: Oxy Usa Inc Facility: Sheep Mountain Unit Description: "On 4/28/2014 and 4/30/2014 OXY cut down approximately 400 of my trees from DS 6-15 and DS 7-15 before they had the required permits. They lied to COGCC and BLM and told them that they had paid me for the trees (27 Aug 2014). On 18 Sept 2014 I was paid for the trees. To date they have not cleaned up the area. Tree stumps are still stand. They are not sure if they will drill at these locations now." Resolution: issues raised previously in complaint 200410625 and will be addressed in that complaint so closed in this complaint
  • Date Received: Oct. 29, 2014 Document No.: 200416010 ROADS HUERFANO Operator: Oxy Usa Inc Facility: Sheep Mountain Unit Description: “After 100’s of vehicles drove over my surface land for DS# 1-12B Oxy left my road (SEE ATTACHED PHOTOS). I asked that the road be graded and new gravel put on surface road by 9 Oct 2014. This work was not done.” Resolution: The COGCC implemented a new public complaint process on January 8, 2015. This complaint was received prior to the new process and was either investigated and resolved without formal documentation or was not fully investigated. COGCC staff reviewed historical documents and could not find information on the complaint investigation and due to time will now close the complaint.
  • Date Received: Nov. 28, 2014 Document No.: 200418332 BASELINE WATER REQUEST HUERFANO Operator: Oxy Usa Inc Facility: Sheep Mountain Unit Description: Ms. Koscove requested baseline sampling of spring to NW of location Resolution: No impacts to water quality from nearby oil and gas operations observed in data from lab. Mailed summary letter to Mrs. Koscove.
  • Date Received: June 30, 2016 Document No.: 200439862 NOISE HUERFANO Operator: Invalid Operator Facility: Freeman Description: flaring very noisy lasts until 0200 am family cannot sleep due to noise even with windows closed Resolution: I take my first noise readings on (07/08/16). I let Jerry Johnson (Alta Mesa) know that the 52-54 dbs are out of compliance for A-scale(nighttime readings), and that they must bring it below 50 dbs at nighttime. The Noise Baffling Walls show up the weekend of (07/09/16) for the work over rig. When they were finished swabbing the well, the noise baffling walls were taken from rig and put around flare box. At 7:00 pm on (07/10/16), started flaring the final time to (07/14/16)till 2:00 pm. For more information see Documents (Doc.# 668004603 and Doc.# 668004626). At 8:45 am on (07/20/16), I was at well site. Jerry Johnson (Alta Mesa) tells me that they had got the information and samples they needed and were packing up and would be off location by this evening (07/20/16). By (07/21/16) the location would be locked up and all personnel gone. Off site at 10:00 am.
  • Date Received: June 2, 2017 Document No.: 200442883 OTHER HUERFANO Operator: Invalid Operator Facility: Freeman Description: Location: Huerfano County freeman well location 429618 Freeman 3-24 Operator: ALTA MESA SERVICES LP 10630 Issue: there is a new access road made off of county road 530 which is not noted on the form 2A and no sundry notice was submitted. The concern is noxious weed invasion and dust. The weed contol plan does not include this area. Dust, new road and piles of dirt possible noxious weed invasion. Resolution: COGCC Staff inspected the Freeman 3-24 location on June 5, 2017 (Document No. 673504379) and observed that Operator had recently commenced a surface disturbance including access road (“Disturbed Area”) and that there were no stormwater control BMPs in place at the Disturbed Area. Soil stockpiles were not stabilized, vehicle tracking control practices were not implemented at the access road, and there were no stormwater controls along the perimeter of the Disturbed Area. Document No. 673504379 instructed Operator to install required BMPs per Rule 1002.f by June 10, 2017. Additionally, staff observed that Operator had recently commenced a surface disturbance constituting construction or major change. The total area of the recent disturbance, including a new access road that enters the west side of the Location and additional pad disturbance contiguous to the Location, is 1.41 acres. Document No. 673504379 instructed Operator to submit, by June 10, 2017, a Form 42 notice with the date on which construction of the disturbance commenced. On June 8, 2017, Operator submitted the Form 42 construction notice (Document # 401303826) indicating a construction or major change start date of June 1, 2017. Based on this reported start date, the Operator failed to submit a Form 42 Notice of Construction or Major Change at least 48 hours in advance of commencing construction, in violation of Rule 316C.c. and in violation of the Condition of Approval in Form 2A. COGCC Staff re-inspected the Location on June 12, 2017 (Document No. 673504439) and observed that no stormwater controls had been installed, beyond the corrective action deadline of June 10, 2017. Further observations were; “The segregated soil stockpiles at the recently constructed area were in the process of being replaced and contoured. The disturbed soils are susceptible to wind and stormwater erosion. The soils will need to be stabilized with a certified weed free mulch or equivalent method until vegetation has re-established.” An additional Stormwater corre
  • Date Received: June 6, 2017 Document No.: 200442914 OTHER HUERFANO Operator: Invalid Operator Facility: Freeman Description: Location: Well Name/No: Freeman #3-24 Operator: ALTA MESA SERVICES LP - 10630 #429618 Issue: I drove on County Road 530 yesterday, and just past the road into the Freeman 3-24 Alta Mesa site, I saw large piles of dirt being blown by the wind. I turned to visit a friend on the first road past the entrance to the site and found myself on a newly constructed road into the site and past a large newly cleared area. Upon reviewing their approved Form 2A, this was on their approved site plan. I question whether this is appropriate activity at this site and request a site visit to inspect the site. Complainant has also contacted Huerfano County LGD Dale Lyons Resolution: COGCC Staff inspected the Freeman 3-24 location on June 5, 2017 (Document No. 673504379) and observed that Operator had recently commenced a surface disturbance including access road (“Disturbed Area”) and that there were no stormwater control BMPs in place at the Disturbed Area. Soil stockpiles were not stabilized, vehicle tracking control practices were not implemented at the access road, and there were no stormwater controls along the perimeter of the Disturbed Area. Document No. 673504379 instructed Operator to install required BMPs per Rule 1002.f by June 10, 2017. Additionally, staff observed that Operator had recently commenced a surface disturbance constituting construction or major change. The total area of the recent disturbance, including a new access road that enters the west side of the Location and additional pad disturbance contiguous to the Location, is 1.41 acres. Document No. 673504379 instructed Operator to submit, by June 10, 2017, a Form 42 notice with the date on which construction of the disturbance commenced. On June 8, 2017, Operator submitted the Form 42 construction notice (Document # 401303826) indicating a construction or major change start date of June 1, 2017. Based on this reported start date, the Operator failed to submit a Form 42 Notice of Construction or Major Change at least 48 hours in advance of commencing construction, in violation of Rule 316C.c. and in violation of the Condition of Approval in Form 2A. COGCC Staff re-inspected the Location on June 12, 2017 (Document No. 673504439) and observed that no stormwater controls had been installed, beyond the corrective action deadline of June 10, 2017. Further observations were; “The segregated soil stockpiles at the recently constructed area were in the process of being replaced and contoured. The disturbed soils are susceptible to wind and stormwater erosion. The soils will need to be stabilized with a certified weed free mulch or equivalent method until vegetation has re-established.” An additional Stormwater correcti
  • Date Received: June 8, 2017 Document No.: 200442942 OTHER HUERFANO Operator: Invalid Operator Facility: Freeman Description: Location: Freeman #3 well, County Road 530 Walsenburg Issue: I live next to the site. In the past Shell notified me of work on the site. Now there is excavation and a new road outside of the original site. There are are also a dozen water tanks that I'm assuming will be used for more fracking. Dirt has been piled up in mounds that blow around with our frequent valley winds. I'm also concerned that the additional changes to the property will cause even more erosion on our private road to the West of the site. The original site plan called for a much reduced size to the pad after the well was installed. What does the new site plan specify? Resolution: COGCC Staff inspected the Freeman 3-24 location on June 5, 2017 (Document No. 673504379) and observed that Operator had recently commenced a surface disturbance including access road (“Disturbed Area”) and that there were no stormwater control BMPs in place at the Disturbed Area. Soil stockpiles were not stabilized, vehicle tracking control practices were not implemented at the access road, and there were no stormwater controls along the perimeter of the Disturbed Area. Document No. 673504379 instructed Operator to install required BMPs per Rule 1002.f by June 10, 2017. Additionally, staff observed that Operator had recently commenced a surface disturbance constituting construction or major change. The total area of the recent disturbance, including a new access road that enters the west side of the Location and additional pad disturbance contiguous to the Location, is 1.41 acres. Document No. 673504379 instructed Operator to submit, by June 10, 2017, a Form 42 notice with the date on which construction of the disturbance commenced. On June 8, 2017, Operator submitted the Form 42 construction notice (Document # 401303826) indicating a construction or major change start date of June 1, 2017. Based on this reported start date, the Operator failed to submit a Form 42 Notice of Construction or Major Change at least 48 hours in advance of commencing construction, in violation of Rule 316C.c. and in violation of the Condition of Approval in Form 2A. COGCC Staff re-inspected the Location on June 12, 2017 (Document No. 673504439) and observed that no stormwater controls had been installed, beyond the corrective action deadline of June 10, 2017. Further observations were; “The segregated soil stockpiles at the recently constructed area were in the process of being replaced and contoured. The disturbed soils are susceptible to wind and stormwater erosion. The soils will need to be stabilized with a certified weed free mulch or equivalent method until vegetation has re-established.” An additional Stormwater correcti
  • Date Received: June 9, 2017 Document No.: 200443044 RECLAMATION HUERFANO Operator: Invalid Operator Facility: Freeman Description: Alta Mesa has removed a large area of native grass and topsoil adjacent to the original well site drilled by Shell. Also a road has been carved from the county road leavening rocks on the county road. I am concerned about the area growing noxious weed, as when the native gamma grass is disturbed, only weeds will grow back, also a new road which leaves the area, in time with a new arroyo, due to water runoff. There is a pad already constructed with an entrance, why more destruction of native habitat. Resolution: COGCC Staff inspected the Freeman 3-24 location on June 5, 2017 (Document No. 673504379) and observed that Operator had recently commenced a surface disturbance including access road (“Disturbed Area”) and that there were no stormwater control BMPs in place at the Disturbed Area. Soil stockpiles were not stabilized, vehicle tracking control practices were not implemented at the access road, and there were no stormwater controls along the perimeter of the Disturbed Area. Document No. 673504379 instructed Operator to install required BMPs per Rule 1002.f by June 10, 2017. Additionally, staff observed that Operator had recently commenced a surface disturbance constituting construction or major change. The total area of the recent disturbance, including a new access road that enters the west side of the Location and additional pad disturbance contiguous to the Location, is 1.41 acres. Document No. 673504379 instructed Operator to submit, by June 10, 2017, a Form 42 notice with the date on which construction of the disturbance commenced. On June 8, 2017, Operator submitted the Form 42 construction notice (Document # 401303826) indicating a construction or major change start date of June 1, 2017. Based on this reported start date, the Operator failed to submit a Form 42 Notice of Construction or Major Change at least 48 hours in advance of commencing construction, in violation of Rule 316C.c. and in violation of the Condition of Approval in Form 2A. COGCC Staff re-inspected the Location on June 12, 2017 (Document No. 673504439) and observed that no stormwater controls had been installed, beyond the corrective action deadline of June 10, 2017. Further observations were; “The segregated soil stockpiles at the recently constructed area were in the process of being replaced and contoured. The disturbed soils are susceptible to wind and stormwater erosion. The soils will need to be stabilized with a certified weed free mulch or equivalent method until vegetation has re-established.” An additional Stormwater correcti
  • Date Received: June 15, 2017 Document No.: 200443041 PRODUCTION HUERFANO Operator: Invalid Operator Facility: Freeman Description: Location: API# 05-055-06309 NWSW 24 27S 69W 6 Field: WIldcat Facility Name: Freeman Operator: Alta Mesa Services Facility#:3-24 Operator#:10630 Issue: Looking at 2016 Monthly Well Production, in July the report indicates that 426 barrels of water were put into an onsite pit (P). Looking at the COGCC GIS map I see no permitted pit for the Freeman site. In November 2016 with 29 production days there was no produced water reported at all. Alta Mesa is a new operator to our area, so we have been checking things out. Thank you. Resolution: Confirmed that the disposal was incorrect, corrected internally to reflect "M" code.
  • Date Received: Nov. 15, 2017 Document No.: 200444665 PRODUCTION HUERFANO Operator: Tabula Rasa Energy Llc Facility: LA VETA GAS PLANT Description: La Veta Gas Plant 412177 Tabula Rasa is reporting 80% (eighty per cent) shrinkage over the past year according to COGCC production reporting. Where is this gas going, flared, leaked???? Absent Form 4 report per 900 Rules on flaring. Resolution: COGCC Production Supervisor reviewed production data. Lower production volumes were reported with no indications of non-compliance with COGCC rules.

NOAVs

COGCC has issued 25 NOAVs in Huerfano County, Colorado:

Document No.: 200429162 Enforcement Action: Final Resolution Comment:

Document No.: 401201222 Rule: 1004 Rule Description: Final Reclamation of Well Sites and Associated Production Facilities Alleged Violation Description: Pursuant to Rule 1004.e., Petroglyph Operating Co Inc ADBA Petroglyph Energy (Operator) is required to keep areas being reclaimed as free of all undesirable plant species designated to be noxious weeds as practicable. It is the responsibility of the operator to monitor affected and reclaimed lands for noxious weed infestations. COGCC may require a weed control plan. During an inspection of the State 7W well, API 055-06219, (Well) September 1, 2016 (Document #673503721), COGCC staff observed noxious weeds present at the location. Document #673503721 required Operator to remove and control noxious weed growth by October 14, 2016. During an inspection of the Well location on December 1, 2016 (Document #673503909) COGCC staff observed that the required work to remove and control noxious weeds was not completed, violating Rule 1004.e. Enforcement Action: AOC Corrective Action Description: Operator shall submit a weed control plan and completed weed control at the Well location. Final Resolution Comment: Resolved by Order 1V-638. Reclamation efforts are ongoing.

Document No.: 401201222 Rule: 1004.a Rule Description: Final Reclamation - Well Sites Reclamation Alleged Violation Description: Pursuant to Rule 1004.a., Petroglyph Operating Co Inc ADBA Petroglyph Energy (Operator) is required to revegetate impacted areas at well locations in preparation for completing Final Reclamation. During an inspection of the State 7W well, API 055-06219, (Well) September 1, 2016 (Document #673503721), COGCC staff observed vegetation has not been established. Document #673503721 required Operator to reseed and stabilize areas of the Well location to facilitate vegetation establishment by November 30, 2016. During an inspection of the Well location on December 1, 2016 (Document #673503909) COGCC staff observed that the required Corrective Actions were not completed, violating Rule 1004.a. Enforcement Action: AOC Corrective Action Description: Operator shall reseed and stabilize areas of the Well location to facilitate vegetation establishment. Final Resolution Comment: Resolved by Order 1V-638. Reclamation efforts are ongoing.

Document No.: 401201229 Rule: 1002.f Rule Description: Stormwater Management Alleged Violation Description: Pursuant to Rule 1002.f.(2), Petroglyph Operating Co Inc ADBA Petroglyph Energy (Operator) is required to implement and maintain Best Management Practices (BMPs) at the State 2W well, API 055-06214, (Well) to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation until Final Reclamation has been achieved. During an inspection of the Well location on September 1, 2016 (Document #673503719), COGCC staff observed minor signs of erosion occurring off the west side of the location. Document #673503719 required corrective action to stabilize areas of the Well location to facilitate vegetation by November 30, 2016. During an inspection of the Well location on December 1, 2016 (Document #673503915) COGCC staff observed that the required Corrective Actions were not completed, violating Rule 1002.f.(2). Enforcement Action: AOC Corrective Action Description: Operator shall immediately install or repair required BMPs in a manner that minimizes erosion, transport of sediment offsite, and site degradation to return the Well location to compliance. Final Resolution Comment: Resolved by Order 1V-638. Reclamation efforts are ongoing.

Document No.: 401201229 Rule: 1004.a Rule Description: Final Reclamation - Well Sites Reclamation Alleged Violation Description: Pursuant to Rule 1004.a., Petroglyph Operating Co Inc ADBA Petroglyph Energy (Operator) is required to revegetate impacted areas at well locations in preparation for completing Final Reclamation. During an inspection of the State 2W well, API 055-06214, (Well) September 1, 2016 (Document #673503719), COGCC staff observed vegetation has not been established. Document #673503719 required Operator to reseed and stabilize areas of the Well location to facilitate vegetation establishment by November 30, 2016. During an inspection of the Well location on December 1, 2016 (Document #673503915) COGCC staff observed that the required Corrective Actions were not completed, violating Rule 1004.a. Enforcement Action: AOC Corrective Action Description: Operator shall reseed and stabilize areas of the Well location to facilitate vegetation establishment. Final Resolution Comment: Resolved by Order 1V-638. Reclamation efforts are ongoing.

Document No.: 401201230 Rule: 1002.f Rule Description: Stormwater Management Alleged Violation Description: Pursuant to Rule 1002.f.(2), Petroglyph Operating Co Inc ADBA Petroglyph Energy (Operator) is required to implement and maintain Best Management Practices (BMPs) at the State 9W well, API 055-06221, (Well) to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation until Final Reclamation has been achieved. During an inspection of the Well location on September 1, 2016 (Document #673503723), COGCC staff observed erosion occurring along the access road and at the southeast and south side of the location. Document #673503723 required corrective action to install or repair stormwater BMPs by October 14, 2016. During an inspection of the Well location on December 1, 2016 (Document #673503911), COGCC staff observed that the signs of erosion were still present and BMPs were not installed or repaired. Operator failed to install or repair BMPs to bring the Well location to compliance, violating Rule 1002.f.(2). Enforcement Action: AOC Corrective Action Description: Operator shall immediately install or repair required BMPs in a manner that minimizes erosion, transport of sediment offsite, and site degradation to return the Well location to compliance. Final Resolution Comment: Resolved by Order 1V-638. Reclamation efforts ongoing.

Document No.: 401201207 Rule: 1004.a Rule Description: Final Reclamation - Well Sites Reclamation Alleged Violation Description: Pursuant to Rule 1004.a., upon plugging and abandonment of a well, Petroglyph Operating Co Inc ADBA Petroglyph Energy (Operator) is required to close, grade, recontour, remove culverts, and reclaim all access roads to plugged and abandoned wells and associated production facilities. This work must be completed within twelve (12) months after plugging on non-crop lands. The Passow 22-08 well, API 055-06202, (Well) was plugged and abandoned on September 29, 2011 (Document #2507693) and the access road to this Well and associated production facilities should have been closed, regraded and recontoured, culverts removed, and reclaimed by September 29, 2012. During an inspection of the Well location on February 9, 2016 (Document #673503141), COGCC staff observed the access road to the Well is not reclaimed. Gravel/culverts remain and there is still an electrical box/panel along the access road and at the location. The location is not recontoured. Document #673503141 required Operator to submit a detailed reclamation plan, attached to a Form 4, Sundry Notice, with a schedule of the planned work activities. The deadline for submission of the reclamation plan was March 21, 2016. It was required that reclamation commence no later than spring of 2016. During inspections of the Well location on July 11, 2016 (Document #673503493); September 1, 2016 (Document #673503713); and December 1, 2016 (Document #673503921); COGCC staff observed that the required work to reclaim the access road was not commenced and the required reclamation plan was never submitted. Document #673503493, Document #673503713, and Document #673503921 required the removal of gravel, culverts, equipment, utilities, and to reclaim the access road and location as required. The operator was requested to submit a Form 4, Sundry Notice, including photographs and documentation to demonstrate completion of the required corrective actions, but no Form 4, Sundry Notice, documenting any work has been submitted to date. To date, Operator has not reclaimed the access road or the location, violating Rule 1004. Enforcement Action: AOC Corrective Action Description: Operator shall close, grade, recontour, remove culverts, remove equipment, remove utilities, and reclaim the access road and location. Final Resolution Comment: Resolved by Order 1V-638. Reclamation efforts are ongoing.

Document No.: 401201207 Rule: 1004 Rule Description: Final Reclamation of Well Sites and Associated Production Facilities Alleged Violation Description: Pursuant to Rule 1004.e., Petroglyph Operating Co Inc ADBA Petroglyph Energy (Operator) is required to keep areas being reclaimed as free of all undesirable plant species designated to be noxious weeds as practicable. It is the responsibility of the operator to monitor affected and reclaimed lands for noxious weed infestations. COGCC may require a weed control plan. During an inspection of the Passow 22-08 well, API 055-06202, (Well) February 9, 2016 (Document #673503141), COGCC staff observed List B noxious weeds present in disturbed areas at the location. Document #673503141 required Operator to submit a detailed weed control plan, attached to a Form 4, Sundry Notice, with a schedule of the planned work activities. The deadline for submission of the weed control plan was March 21, 2016 and required that weed control commence no later than spring of 2016. During inspections of the Well location on July 11, 2016 (Document #673503493); September 1, 2016 (Document #673503713); and December 1, 2016 (Document #673503921); COGCC staff observed that the required work to keep disturbed areas free of noxious weeds was not completed, and a weed control plan was never submitted. Document #673503493, Document #673503713, and Document #673503921 required removal and control of noxious weed growth. The operator was requested to submit a Form 4, Sundry Notice, including photographs and documentation to demonstrate completion of the required corrective actions, but no Form 4, Sundry Notice, documenting any work has been submitted to date. To date, Operator has not submitted a weed control plan or completed weed control at the Well location, violating Rule 1004.e. Enforcement Action: AOC Corrective Action Description: Operator shall submit a weed control plan and complete weed control at the Well location. Final Resolution Comment: Resolved by Order 1V-638. Reclamation efforts are ongoing.

Document No.: 401201222 Rule: 1002.f Rule Description: Stormwater Management Alleged Violation Description: Pursuant to Rule 1002.f.(2), Petroglyph Operating Co Inc ADBA Petroglyph Energy (Operator) is required to implement and maintain Best Management Practices (BMPs) at the State 7W well, API 055-06219, (Well) to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation until Final Reclamation has been achieved. During an inspection of the Well location on September 1, 2016 (Document #673503721), COGCC staff observed erosion occurring off the northwest side of the location. Document #673503721 required corrective action to install stormwater BMPs to return the location to compliance by October 14, 2016. During an inspection of the Well location on December 1, 2016 (Document #673503909), COGCC staff observed that the signs of erosion at the northwest side of the location and BMPs were not installed. Operator failed to install required BMPs to return the Well location to compliance, violating Rule 1002.f.(2). Enforcement Action: AOC Corrective Action Description: Operator shall immediately install or repair required BMPs in a manner that minimizes erosion, transport of sediment offsite, and site degradation to return the Well location to compliance. Final Resolution Comment: Resolved by Order 1V-638. Reclamation efforts are ongoing.

Document No.: 401201230 Rule: 1004 Rule Description: Final Reclamation of Well Sites and Associated Production Facilities Alleged Violation Description: Pursuant to Rule 1004.e., Petroglyph Operating Co Inc ADBA Petroglyph Energy (Operator) is required to keep areas being reclaimed as free of all undesirable plant species designated to be noxious weeds as practicable. It is the responsibility of the operator to monitor affected and reclaimed lands for noxious weed infestations. COGCC may require a weed control plan. During an inspection of the State 9W well, API 055-06221, (Well) September 1, 2016 (Document #673503723), COGCC staff observed noxious weeds present along the access road at the location. Document #673503723 required Operator to remove and control noxious weed growth by November 30, 2016. During an inspection of the Well location on December 1, 2016 (Document #673503911) COGCC staff observed that the required work to remove and control noxious weeds was not completed, violating Rule 1004.e. Enforcement Action: AOC Corrective Action Description: Operator shall remove and control noxious weed growth. Final Resolution Comment: Resolved by Order 1V-638. Reclamation efforts ongoing.

Document No.: 401201230 Rule: 1004.a Rule Description: Final Reclamation - Well Sites Reclamation Alleged Violation Description: Pursuant to Rule 1004.a., Petroglyph Operating Co Inc ADBA Petroglyph Energy (Operator) is required to remove all debris and revegetate impacted areas at well locations in preparation for completing Final Reclamation. During an inspection of the State 9W well, API 055-06221, (Well) September 1, 2016 (Document #673503723), COGCC staff observed vegetation has not been established and there were piles of straw debris at the west side of the location and plastic debris along the southeast side. Document #673503723 required Operator to remove plastic debris and piles of straw debris and reseed and stabilize areas of the Well location to facilitate vegetation establishment by November 30, 2016. During an inspection of the Well location on December 1, 2016 (Document #673503911) COGCC staff observed that the required Corrective Actions were not completed, violating Rule 1004.a. Enforcement Action: AOC Corrective Action Description: Operator shall remove plastic debris and piles of straw debris and reseed and stabilize areas of the Well location to facilitate vegetation establishment. Final Resolution Comment: Resolved by Order 1V-638. Reclamation efforts ongoing.

Document No.: 401201232 Rule: 1004.a Rule Description: Final Reclamation - Well Sites Reclamation Alleged Violation Description: Pursuant to Rule 1004.a., Petroglyph Operating Co Inc ADBA Petroglyph Energy (Operator) is required to remove all debris and revegetate impacted areas at well locations in preparation for completing Final Reclamation. During an inspection of the State 10WB well, API 055-06261, (Well) September 1, 2016 (Document #673503726), COGCC staff observed areas of the location that have little to no vegetation establishment, trash debris at the northwest side of the location, and plastic debris along the northeast side of the location. Document #673503726 required Operator to reseed and stabilize areas of the Well location to facilitate vegetation and remove debris by November 30, 2016. During an inspection of the Well location on December 1, 2016, (Document #673503913) COGCC staff observed that the required Corrective Actions were not completed, violating Rule 1004.a. Enforcement Action: AOC Corrective Action Description: Operator shall reseed and stabilize areas of the Well location to facilitate vegetation and remove debris. Final Resolution Comment: Resolved by Order 1V-638. Reclamtion efforts are ongoing.

Document No.: 401435153 Rule: 1002.f Rule Description: Stormwater Management Alleged Violation Description: Pursuant to Rule 1002.f., Alta Mesa Services LP (“Operator”) shall implement and maintain Best Management Practices (“BMPs”) at all oil and gas locations to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation. BMPs shall be maintained until the facility is abandoned and final reclamation is achieved pursuant to Rule 1004. Operators shall employ BMPs, as necessary to comply with this rule, at all oil and gas locations, including, but not limited to, well pads, soil stockpiles, access roads, tank batteries, compressor stations, and pipeline rights of way. BMPs shall be selected based on site-specific conditions, such as slope, vegetation cover, and proximity to water bodies, and may include maintaining in-place some or all of the BMPs installed during the construction phase of the facility. Best Management Practices indicate that Operator shall implement such protection upon commencement of construction. Following complaints made on June 2 and June 5, 2017 (Document Nos. 200442833 and 200442914), COGCC Staff inspected the Freeman 3-24 location (“Location”) on June 5, 2017 (Document No. 673504379), and observed that Operator had recently commenced a surface disturbance including access road (“Disturbed Area”) and that there were no stormwater control BMPs in place at the Disturbed Area. Soil stockpiles were not stabilized, vehicle tracking control practices were not implemented at the access road, and there were no stormwater controls along the perimeter of the Disturbed Area. Document No. 673504379 instructed Operator to install required BMPs per Rule 1002.f by June 10, 2017. COGCC Staff re-inspected the Location on June 12, 2017 (Document No. 673504439) and observed that no stormwater controls had been installed, beyond the corrective action deadline of June 10, 2017. Further observations were; “The segregated soil stockpiles at the recently constructed area were in the process of being replaced and contoured. The disturbed soils are susceptible to wind and stormwater erosion. The soils will need to be stabilized with a certified weed free mulch or equivalent method until vegetation has re-established.” An additional Stormwater corrective action instructed the Operator to install required BMP’s per Rule 1002.f. by June 27, 2017. COGCC staff re-inspected the Location on July 18, 2017 (Document No. 673504379) and observed that no stormwater controls had been installed, beyond the corrective action deadline of June 10, 2017 and beyond the additional corrective action deadline of June 27, 2017. Operator failed to implement and maintain best management practices to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation, in violation of Rule 1002.f. Enforcement Action: Corrective Action Description: Corrective Action #1 --> Operator shall comply with Rule 1002.f. and implement and maintain stormwater controls, as well as implement site-specific best management practices to control stormwater erosion across the entire location. --> Deadline: 6/10/2017 Corrective Action #2 --> Operator shall comply with Rule 1002.f. and implement and maintain Best Management Practices to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation. --> Deadline: 6/27/2017 Final Resolution Comment:

Document No.: 401435153 Rule: 1003 Rule Description: Interim Reclamation Alleged Violation Description: Pursuant to Rule 1003., Alta Mesa Services LP (“Operator”) shall reclaim, within six months on non-crop land, as early and as nearly as practicable to their original condition or final land use all disturbed areas affected by drilling or subsequent operations, except areas reasonably needed for production operations or for subsequent drilling operations to be commenced within twelve (12) months; shall restore and revegetate as soon as practicable. Following a complaint made on June 2, 2017 (Document No. 200442833), COGCC Staff inspected the Freeman 3-24 location (“Location”) on June 5, 2017 (Document No. 673504379) and observed that the unused areas of the Location had not been reclaimed. The approved Form 2A for this Location (Document No. 400256794, “Form 2A”) categorizes both current and future land use as Non-Crop Land: Rangeland, and specifies the size of the Location after Interim Reclamation must be 1.2 acres. The total area of the location as of June 5, 2017, was 4.42 acres excluding recent additional disturbance. During an inspection of the Location on April 3, 2014 (Document No. 668002019) COGCC Staff observed that the pump was inactive, and followed up with a review of production records to determine that the well was shut in as of December 2013/January 2014, after a date of first production of September 25, 2013. This means interim reclamation was due to commence as early as practicable but no later than March 25, 2014 (six months after September 25, 2013). Document No. 673504379 comments that the Location has been out of compliance for Interim Reclamation since 2014, and instructs Operator to perform interim reclamation and reduce the size of the location as specified in Form 2A by June 12, 2014. COGCC Staff re-inspected the Location on June 12 and July 18, 2017 (Document Nos. 673504439 and 689900032) and observed that interim reclamation of the unused areas had not commenced as of July 18, 2017. Operator submitted a Sundry Notice Form 4 (Document No. 401331736, “Form 4”) submitted on 7/05/2017 to request to delay interim reclamation until September 30, 2018. On July 5, 2017, COGCC Staff sent an email directing Operator to the Notice to Operators: Interim Reclamation Procedures for Delayed Operations (“NTO”) on the COGCC website and included a spreadsheet to assist in estimating some of the information required by the NTO. Operator did not supply required information, and on July 10, 2017, COGCC Staff denied the Form 4 request due to insufficient documentation. In the absence of an approved Form 4 request to delay interim reclamation operations, Operator failed to commence interim reclamation within six months after drilling or production operations, in violation of Rule 1003. Enforcement Action: Corrective Action Description: Operator shall comply with Rule 1003. and perform interim reclamation to reduce the size of the Location as specified in Form 2A. Final Resolution Comment:

Document No.: 401435153 Rule: 303 Rule Description: Requirements for Form 2, Application for Permit-to-Drill, Deepen, Re-enter, or Recomplete and Operate; Form 2A, Oil and Gas Location Assessment Alleged Violation Description: Pursuant to Rule 303.b.(1)B., Alta Mesa Services LP (“Operator”) is required to secure an approved Form 2A, Oil and Gas Location Assessment, prior to commencing a surface disturbance for purposes of modifying or expanding an existing oil and gas location. The original Form 2A for the Freeman 3-24 location (Document No. 400256794, Location ID No. 429619) was approved July 17, 2012. Following complaints made on June 2 and June 5, 2017 (Document Nos. 200442833 and 200442914), COGCC Staff inspected the Freeman 3-24 location (“Location”) on June 5, 2017 (Document No. 673504379) and observed that Operator had recently commenced a new surface disturbance. The total area of the new disturbance, including a new access road that enters the west side of the Location and additional pad disturbance contiguous to the Location, is 1.41 acres. Operator failed to submit and receive approval of a Form 2A Oil and Gas Location Assessment to Amend Existing Location prior to commencing the surface disturbance, in violation of Rule 303.b.(1)B. Enforcement Action: Corrective Action Description: Submit and receive Commission approval for a completed Form 2A, Oil and Gas Location Assessment, prior to commencing the surface disturbance. Final Resolution Comment:

Document No.: 401435153 Rule: 316C Rule Description: Notice of Intent to Conduct Hydraulic Fracturing Treatment Alleged Violation Description: Pursuant to Rule 316C., Alta Mesa Services LP (“Operator”) is required to submit a Form 42, Field Operations Notice, in accordance with the Condition of Approval on Form 2A, Oil and Gas Location Assessment (Document No. 400256794), and as designated in Rule 316C.c. The Condition of Approval in Document No. 400256794 and Rule 316C.c. each require Operator to give at least 48 hours advance written notice of intent to commence construction or major change at any well, oil and gas location, or oil and gas facility. Such notice shall be provided on a field Operations Notice, Form 42 - Notice of Construction or Major Change. Following complaints made on June 2 and June 5, 2017 (Document Nos. 200442833 and 200442914), COGCC Staff inspected the Freeman 3-24 location (“Location”) on June 5, 2017 (Document No. 673504379) and observed that Operator had recently commenced a surface disturbance constituting construction or major change. The total area of the recent disturbance, including a new access road that enters the west side of the Location and additional pad disturbance contiguous to the Location, is 1.41 acres. Document No. 673504379 instructed Operator to submit, by June 10, 2017, a Form 42 notice with the date on which construction of the disturbance commenced. On June 8, 2017, Operator submitted the Form 42 construction notice (Document # 401303826) indicating a construction or major change start date of June 1, 2017. Based on this reported start date, the Operator failed to submit a Form 42 Notice of Construction or Major Change at least 48 hours in advance of commencing construction, in violation of Rule 316C.c. and in violation of the Condition of Approval in Form 2A. Enforcement Action: Corrective Action Description: Operator shall submit a Form 42 notice with the date on which construction of the disturbance commenced. Final Resolution Comment:

Document No.: 401435153 Rule: 603.f Rule Description: Statewide Equipment, Weeds, Waste, and Trash Requirements Alleged Violation Description: Pursuant to Rule 603.f., Alta Mesa Services LP (“Operator”) is required to keep Freeman 3-24 location (“Location”) free of the following: equipment, vehicles, and supplies not necessary for use on that lease; weeds; rubbish, and other waste material. Following complaints made on June 2 and June 5, 2017 (Document Nos. 200442833 and 200442914), COGCC Staff inspected the Freeman 3-24 location (“Location”) on June 5, 2017 (Document No. 673504379) and observed degraded hay bales, debris remains from wattles, and List B noxious weeds (Scotch thistle) around the perimeter of the Location. Document No. 673504379 instructed Operator to comply with Rule 603.f. by removing the degraded hay bales, debris remains from wattles, and weeds by June 22, 2017. COGCC Staff re-inspected the Location on June 8, June 12, and July 18, 2017 (Document Nos. 682600318, 673504439, and 689900032) and observed that the debris remains from the wattles and some but not all of the noxious weeds had been removed by June 12, but that noxious weeds and the degraded hay bales remained as of July 18, 2017, beyond the corrective action deadline of June 22, 2017. Operator failed to keep the Location free of weeds, unused supplies, and other waste material, in violation of Rule 603.f. Enforcement Action: Corrective Action Description: Operator shall remove the degraded hay bales and remaining noxious weeds as required by Rule 603.f. Final Resolution Comment:

Document No.: 401781685 Rule: 319.b Rule Description: Temporary Abandonment Alleged Violation Description: COGCC Rule 100 defines a well as temporarily abandoned (“TA”) if the well becomes incapable of production (for example, through the removal of necessary production equipment or a well that has all downhole completed intervals isolated with a plug set above the highest perforation). Pursuant to Rule 319.b., a well may be temporarily abandoned after passing a successful mechanical integrity test upon approval of the Director, for a period not to exceed six months. A well which is incapable of production shall be abandoned within six months thereafter unless the time is extended by the Director upon application by the Operator (Rule 319.b.(3)). To maintain TA status in excess of six months, TABULA RASA ENERGY LLC ("Operator") is required to annually submit a Sundry Notice ("Form 4-TA") (Rule 319.b.(1)). COGCC Staff had reason to believe Operator had committed one or more violations of COGCC Rules, and issued Warning Letter No. 401237551 to Operator on March 20, 2017, requiring Operator to conduct MIT or plug and abandon delinquent wells and submit delinquent Form 4-TAs by April 21, 2017. On September 25, 2018, COGCC Staff conducted an audit (“Audit”) of Operator's records for the well(s) in the attached table. The Audit included reviewing records such as Operator's Form 7 Monthly Reports of Operations and Field Inspection Reports filed by COGCC Staff after inspecting the Well to determine the dates the Well was TA, and the COGCC database to determine whether Operator had submitted required reports and notices for the Well. Through this Audit, COGCC Staff determined that the HARRY WILLIS #3 (API No. 055-06144, "Well") was TA at least since 2001, that Operator had begun operating the Well in 2013, and that Operator had not submitted any Form 4-TA for the Well as of September 25, 2018. Operator failed to timely submit Form 4-TA for a TA Well, violating Rule 319.b. Enforcement Action: Corrective Action Description: In its Rule 522.d.(2) Answer, due within 28 days of the Operator’s receipt of the NOAV, Operator shall provide the following to COGCC:   - Operator shall perform an audit of its Mechanical Integrity Testing and MIT reporting for all its wells in Colorado. Operator shall submit a detailed report to COGCC which shows the following information for each of its wells which has been in SI or TA status for at least one month starting 24 months prior to September 13, 2018 . Operator shall email a copy of this report as an unlocked (editable) spreadsheet to the COGCC Enforcement email address indicated in the Answer section below.     (1.) API and Well name     (2.) SI or TA status by month, for each month the Well was SI or TA     (3.) Date of last MIT (“n/a” if no MIT performed for that Well)     (4.) Due date of next required MIT, according to Rules 319 and 326. If the Well is delinquent on required MIT as of NOAV issuance, indicate the due date of the most recent missed MIT.     (5.) Date Operator has scheduled to resolve the delinquency (such as by MIT or plug and abandon), if applicable. (“n/a” if the Well is not delinquent; “none” if Well is delinquent, but Operator has not yet scheduled operations to resolve the delinquency)     (6.) (If TA) Whether Operator is current on the Form 4 TA Sundry submittal required by Rule 319.b.(1) & (3).  - A proposed compliance plan to resolve all delinquencies identified in Operator’s audit. The proposed compliance plan will be subject to modification by the COGCC Engineering unit. By the Corrective Action Due Date, Operator shall submit all delinquent Form 4 TA Sundry requests. Final Resolution Comment:

Document No.: 200429162 Enforcement Action: Final Resolution Comment:

Document No.: 401435153 Rule: 603.f Rule Description: Statewide Equipment, Weeds, Waste, and Trash Requirements Alleged Violation Description: Pursuant to Rule 603.f., Alta Mesa Services LP (“Operator”) is required to keep Freeman 3-24 location (“Location”) free of the following: equipment, vehicles, and supplies not necessary for use on that lease; weeds; rubbish, and other waste material. Following complaints made on June 2 and June 5, 2017 (Document Nos. 200442833 and 200442914), COGCC Staff inspected the Freeman 3-24 location (“Location”) on June 5, 2017 (Document No. 673504379) and observed degraded hay bales, debris remains from wattles, and List B noxious weeds (Scotch thistle) around the perimeter of the Location. Document No. 673504379 instructed Operator to comply with Rule 603.f. by removing the degraded hay bales, debris remains from wattles, and weeds by June 22, 2017. COGCC Staff re-inspected the Location on June 8, June 12, and July 18, 2017 (Document Nos. 682600318, 673504439, and 689900032) and observed that the debris remains from the wattles and some but not all of the noxious weeds had been removed by June 12, but that noxious weeds and the degraded hay bales remained as of July 18, 2017, beyond the corrective action deadline of June 22, 2017. Operator failed to keep the Location free of weeds, unused supplies, and other waste material, in violation of Rule 603.f. Enforcement Action: Corrective Action Description: Operator shall remove the degraded hay bales and remaining noxious weeds as required by Rule 603.f. Final Resolution Comment:

Document No.: 401435153 Rule: 1002.f Rule Description: Stormwater Management Alleged Violation Description: Pursuant to Rule 1002.f., Alta Mesa Services LP (“Operator”) shall implement and maintain Best Management Practices (“BMPs”) at all oil and gas locations to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation. BMPs shall be maintained until the facility is abandoned and final reclamation is achieved pursuant to Rule 1004. Operators shall employ BMPs, as necessary to comply with this rule, at all oil and gas locations, including, but not limited to, well pads, soil stockpiles, access roads, tank batteries, compressor stations, and pipeline rights of way. BMPs shall be selected based on site-specific conditions, such as slope, vegetation cover, and proximity to water bodies, and may include maintaining in-place some or all of the BMPs installed during the construction phase of the facility. Best Management Practices indicate that Operator shall implement such protection upon commencement of construction. Following complaints made on June 2 and June 5, 2017 (Document Nos. 200442833 and 200442914), COGCC Staff inspected the Freeman 3-24 location (“Location”) on June 5, 2017 (Document No. 673504379), and observed that Operator had recently commenced a surface disturbance including access road (“Disturbed Area”) and that there were no stormwater control BMPs in place at the Disturbed Area. Soil stockpiles were not stabilized, vehicle tracking control practices were not implemented at the access road, and there were no stormwater controls along the perimeter of the Disturbed Area. Document No. 673504379 instructed Operator to install required BMPs per Rule 1002.f by June 10, 2017. COGCC Staff re-inspected the Location on June 12, 2017 (Document No. 673504439) and observed that no stormwater controls had been installed, beyond the corrective action deadline of June 10, 2017. Further observations were; “The segregated soil stockpiles at the recently constructed area were in the process of being replaced and contoured. The disturbed soils are susceptible to wind and stormwater erosion. The soils will need to be stabilized with a certified weed free mulch or equivalent method until vegetation has re-established.” An additional Stormwater corrective action instructed the Operator to install required BMP’s per Rule 1002.f. by June 27, 2017. COGCC staff re-inspected the Location on July 18, 2017 (Document No. 673504379) and observed that no stormwater controls had been installed, beyond the corrective action deadline of June 10, 2017 and beyond the additional corrective action deadline of June 27, 2017. Operator failed to implement and maintain best management practices to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation, in violation of Rule 1002.f. Enforcement Action: Corrective Action Description: Corrective Action #1 --> Operator shall comply with Rule 1002.f. and implement and maintain stormwater controls, as well as implement site-specific best management practices to control stormwater erosion across the entire location. --> Deadline: 6/10/2017 Corrective Action #2 --> Operator shall comply with Rule 1002.f. and implement and maintain Best Management Practices to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation. --> Deadline: 6/27/2017 Final Resolution Comment:

Document No.: 401435153 Rule: 303 Rule Description: Requirements for Form 2, Application for Permit-to-Drill, Deepen, Re-enter, or Recomplete and Operate; Form 2A, Oil and Gas Location Assessment Alleged Violation Description: Pursuant to Rule 303.b.(1)B., Alta Mesa Services LP (“Operator”) is required to secure an approved Form 2A, Oil and Gas Location Assessment, prior to commencing a surface disturbance for purposes of modifying or expanding an existing oil and gas location. The original Form 2A for the Freeman 3-24 location (Document No. 400256794, Location ID No. 429619) was approved July 17, 2012. Following complaints made on June 2 and June 5, 2017 (Document Nos. 200442833 and 200442914), COGCC Staff inspected the Freeman 3-24 location (“Location”) on June 5, 2017 (Document No. 673504379) and observed that Operator had recently commenced a new surface disturbance. The total area of the new disturbance, including a new access road that enters the west side of the Location and additional pad disturbance contiguous to the Location, is 1.41 acres. Operator failed to submit and receive approval of a Form 2A Oil and Gas Location Assessment to Amend Existing Location prior to commencing the surface disturbance, in violation of Rule 303.b.(1)B. Enforcement Action: Corrective Action Description: Submit and receive Commission approval for a completed Form 2A, Oil and Gas Location Assessment, prior to commencing the surface disturbance. Final Resolution Comment:

Document No.: 401435153 Rule: 1003 Rule Description: Interim Reclamation Alleged Violation Description: Pursuant to Rule 1003., Alta Mesa Services LP (“Operator”) shall reclaim, within six months on non-crop land, as early and as nearly as practicable to their original condition or final land use all disturbed areas affected by drilling or subsequent operations, except areas reasonably needed for production operations or for subsequent drilling operations to be commenced within twelve (12) months; shall restore and revegetate as soon as practicable. Following a complaint made on June 2, 2017 (Document No. 200442833), COGCC Staff inspected the Freeman 3-24 location (“Location”) on June 5, 2017 (Document No. 673504379) and observed that the unused areas of the Location had not been reclaimed. The approved Form 2A for this Location (Document No. 400256794, “Form 2A”) categorizes both current and future land use as Non-Crop Land: Rangeland, and specifies the size of the Location after Interim Reclamation must be 1.2 acres. The total area of the location as of June 5, 2017, was 4.42 acres excluding recent additional disturbance. During an inspection of the Location on April 3, 2014 (Document No. 668002019) COGCC Staff observed that the pump was inactive, and followed up with a review of production records to determine that the well was shut in as of December 2013/January 2014, after a date of first production of September 25, 2013. This means interim reclamation was due to commence as early as practicable but no later than March 25, 2014 (six months after September 25, 2013). Document No. 673504379 comments that the Location has been out of compliance for Interim Reclamation since 2014, and instructs Operator to perform interim reclamation and reduce the size of the location as specified in Form 2A by June 12, 2014. COGCC Staff re-inspected the Location on June 12 and July 18, 2017 (Document Nos. 673504439 and 689900032) and observed that interim reclamation of the unused areas had not commenced as of July 18, 2017. Operator submitted a Sundry Notice Form 4 (Document No. 401331736, “Form 4”) submitted on 7/05/2017 to request to delay interim reclamation until September 30, 2018. On July 5, 2017, COGCC Staff sent an email directing Operator to the Notice to Operators: Interim Reclamation Procedures for Delayed Operations (“NTO”) on the COGCC website and included a spreadsheet to assist in estimating some of the information required by the NTO. Operator did not supply required information, and on July 10, 2017, COGCC Staff denied the Form 4 request due to insufficient documentation. In the absence of an approved Form 4 request to delay interim reclamation operations, Operator failed to commence interim reclamation within six months after drilling or production operations, in violation of Rule 1003. Enforcement Action: Corrective Action Description: Operator shall comply with Rule 1003. and perform interim reclamation to reduce the size of the Location as specified in Form 2A. Final Resolution Comment:

Document No.: 401435153 Rule: 316C Rule Description: Notice of Intent to Conduct Hydraulic Fracturing Treatment Alleged Violation Description: Pursuant to Rule 316C., Alta Mesa Services LP (“Operator”) is required to submit a Form 42, Field Operations Notice, in accordance with the Condition of Approval on Form 2A, Oil and Gas Location Assessment (Document No. 400256794), and as designated in Rule 316C.c. The Condition of Approval in Document No. 400256794 and Rule 316C.c. each require Operator to give at least 48 hours advance written notice of intent to commence construction or major change at any well, oil and gas location, or oil and gas facility. Such notice shall be provided on a field Operations Notice, Form 42 - Notice of Construction or Major Change. Following complaints made on June 2 and June 5, 2017 (Document Nos. 200442833 and 200442914), COGCC Staff inspected the Freeman 3-24 location (“Location”) on June 5, 2017 (Document No. 673504379) and observed that Operator had recently commenced a surface disturbance constituting construction or major change. The total area of the recent disturbance, including a new access road that enters the west side of the Location and additional pad disturbance contiguous to the Location, is 1.41 acres. Document No. 673504379 instructed Operator to submit, by June 10, 2017, a Form 42 notice with the date on which construction of the disturbance commenced. On June 8, 2017, Operator submitted the Form 42 construction notice (Document # 401303826) indicating a construction or major change start date of June 1, 2017. Based on this reported start date, the Operator failed to submit a Form 42 Notice of Construction or Major Change at least 48 hours in advance of commencing construction, in violation of Rule 316C.c. and in violation of the Condition of Approval in Form 2A. Enforcement Action: Corrective Action Description: Operator shall submit a Form 42 notice with the date on which construction of the disturbance commenced. Final Resolution Comment:

Document No.: 401781685 Rule: 319.b Rule Description: Temporary Abandonment Alleged Violation Description: COGCC Rule 100 defines a well as temporarily abandoned (“TA”) if the well becomes incapable of production (for example, through the removal of necessary production equipment or a well that has all downhole completed intervals isolated with a plug set above the highest perforation). Pursuant to Rule 319.b., a well may be temporarily abandoned after passing a successful mechanical integrity test upon approval of the Director, for a period not to exceed six months. A well which is incapable of production shall be abandoned within six months thereafter unless the time is extended by the Director upon application by the Operator (Rule 319.b.(3)). To maintain TA status in excess of six months, TABULA RASA ENERGY LLC ("Operator") is required to annually submit a Sundry Notice ("Form 4-TA") (Rule 319.b.(1)). COGCC Staff had reason to believe Operator had committed one or more violations of COGCC Rules, and issued Warning Letter No. 401237551 to Operator on March 20, 2017, requiring Operator to conduct MIT or plug and abandon delinquent wells and submit delinquent Form 4-TAs by April 21, 2017. On September 25, 2018, COGCC Staff conducted an audit (“Audit”) of Operator's records for the well(s) in the attached table. The Audit included reviewing records such as Operator's Form 7 Monthly Reports of Operations and Field Inspection Reports filed by COGCC Staff after inspecting the Well to determine the dates the Well was TA, and the COGCC database to determine whether Operator had submitted required reports and notices for the Well. Through this Audit, COGCC Staff determined that the HARRY WILLIS #3 (API No. 055-06144, "Well") was TA at least since 2001, that Operator had begun operating the Well in 2013, and that Operator had not submitted any Form 4-TA for the Well as of September 25, 2018. Operator failed to timely submit Form 4-TA for a TA Well, violating Rule 319.b. Enforcement Action: Corrective Action Description: In its Rule 522.d.(2) Answer, due within 28 days of the Operator’s receipt of the NOAV, Operator shall provide the following to COGCC:   - Operator shall perform an audit of its Mechanical Integrity Testing and MIT reporting for all its wells in Colorado. Operator shall submit a detailed report to COGCC which shows the following information for each of its wells which has been in SI or TA status for at least one month starting 24 months prior to September 13, 2018 . Operator shall email a copy of this report as an unlocked (editable) spreadsheet to the COGCC Enforcement email address indicated in the Answer section below.     (1.) API and Well name     (2.) SI or TA status by month, for each month the Well was SI or TA     (3.) Date of last MIT (“n/a” if no MIT performed for that Well)     (4.) Due date of next required MIT, according to Rules 319 and 326. If the Well is delinquent on required MIT as of NOAV issuance, indicate the due date of the most recent missed MIT.     (5.) Date Operator has scheduled to resolve the delinquency (such as by MIT or plug and abandon), if applicable. (“n/a” if the Well is not delinquent; “none” if Well is delinquent, but Operator has not yet scheduled operations to resolve the delinquency)     (6.) (If TA) Whether Operator is current on the Form 4 TA Sundry submittal required by Rule 319.b.(1) & (3).  - A proposed compliance plan to resolve all delinquencies identified in Operator’s audit. The proposed compliance plan will be subject to modification by the COGCC Engineering unit. By the Corrective Action Due Date, Operator shall submit all delinquent Form 4 TA Sundry requests. Final Resolution Comment:

Air Quality (PM2.5 ug/m3)

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