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Washington County... Oil & Gas

Washington 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 25 complaint(s) have been assigned to Washington County, Colorado:

  • Date Received: March 30, 2018 Document No.: 200445680 WATER WELL WASHINGTON Operator: Hrm Resources Ii Llc Facility: MARICK-63S52W Description: ,We received a letter from the operator HRM Resources dated May 29 2015 stating they were going to start reclamation of the skim pit of the Marick 1-A. Roughly a week after receiving the letter, and without permission from us the land owner. They pushed dirt up on the east and west sides of the open air pits, destroying approximately 2 acres of growing corn. I contacted the crew on site and they referred me to Terry Pape the owner of HRM. Explained the situation he apologized and told me that HRM wanted to be good neighbors moving forward. We decided that there was $3000.00 of damage witch I received a check for that amount on 6/12/15. I also asked for a copy of the lease agreement at this time. We did not realize that this reclamation project was a 3 year process. We have contacted HRM at least 3 times about keeping on the lease road and not driving or backing trailers into our field. In February of 18 I happened by chance to speak with Susan Sherman at the Marick location and she told me of process to solve our concerns. We now have tanks and cat walks placed on our stubble field, as well as a new pile of oily dirt. We have tried to be reasonable in this whole process and do not think that one time compensation buys you unlimited access to something that isn't yours. Our concerns are: We want the reclamation dirt removed by May 31 2018, as I understand to be the agreement with the state, and put back to the way it was before. A lease agreement stating clear boundaries for the access road and tank battery, since none can be found on file with the state. Once the boundaries are established there will be no pushing the limit of those boundaries. Test my water well. Resolution: Water quality results letter dated 5/10/18 mailed to complainant. No oil and gas impacts to water well observed.
  • Date Received: March 30, 2018 Document No.: 200445680 PROPERTY DAMAGE WASHINGTON Operator: Hrm Resources Ii Llc Facility: MARICK-63S52W Description: SEE DETAILS Resolution: Resolution letter sent May 18, 2018, NOAV issued 6/7/2018. Landfarm is associated with Rem #9015. Final landfarm removal confirmation soil samples collected June 13, 2018.
  • Date Received: March 30, 2018 Document No.: 200445680 GROUND WATER WASHINGTON Operator: Hrm Resources Ii Llc Facility: MARICK-63S52W Description: ,We received a letter from the operator HRM Resources dated May 29 2015 stating they were going to start reclamation of the skim pit of the Marick 1-A. Roughly a week after receiving the letter, and without permission from us the land owner. They pushed dirt up on the east and west sides of the open air pits, destroying approximately 2 acres of growing corn. I contacted the crew on site and they referred me to Terry Pape the owner of HRM. Explained the situation he apologized and told me that HRM wanted to be good neighbors moving forward. We decided that there was $3000.00 of damage witch I received a check for that amount on 6/12/15. I also asked for a copy of the lease agreement at this time. We did not realize that this reclamation project was a 3 year process. We have contacted HRM at least 3 times about keeping on the lease road and not driving or backing trailers into our field. In February of 18 I happened by chance to speak with Susan Sherman at the Marick location and she told me of process to solve our concerns. We now have tanks and cat walks placed on our stubble field, as well as a new pile of oily dirt. We have tried to be reasonable in this whole process and do not think that one time compensation buys you unlimited access to something that isn't yours. Our concerns are: We want the reclamation dirt removed by May 31 2018, as I understand to be the agreement with the state, and put back to the way it was before. A lease agreement stating clear boundaries for the access road and tank battery, since none can be found on file with the state. Once the boundaries are established there will be no pushing the limit of those boundaries. Test my water well. Resolution:
  • Date Received: Jan. 2, 2018 Document No.: 200444987 RECLAMATION WASHINGTON Operator: Declar Oil & Gas Inc Facility: BLAKE Description: Location: Foster 2-31 & 1-31 other unknown. E1/2 Sect 31 T1S-R55W Issue: damage to land (roads, tanks & pit). The road to the tank needs to be leveled, the tank removed and the pit closed. Pit was not filled, Tank needs to be removed and road to tank leveled. Wells have not been plugged and abandon and land has not been reclaimed. Contacts: Daniel Foster 23436 CR 60.5 Greeley, CO 970-353-1714 Dawson Cramer Oil Corp. Resolution: Resolved VIA FIR #682503015
  • Date Received: Aug. 11, 2016 Document No.: 200440055 ROADS WASHINGTON Operator: Lilis Energy Inc Facility: PIEPER LEO Description: The access road is poorly maintained. In some areas the road became so rutted and unusable that the trucks just moved over and made new tracks. Resolution:
  • Date Received: Aug. 11, 2016 Document No.: 200440055 FENCING WASHINGTON Operator: Lilis Energy Inc Facility: PIEPER LEO Description: Fencing around the equipment, pits, and battery is in poor condition. Today two calves were in the tank battery fencing. The access road has poor drainage which causes the cattle guard to fill with sediment and makes it so cattle will walk right over it. Resolution:
  • Date Received: Aug. 11, 2016 Document No.: 200440055 TRASH WASHINGTON Operator: Lilis Energy Inc Facility: PIEPER LEO Description: Workers have left trash, equipment, t-posts on the location. Landowner has cleaned up some trash on his own. Resolution:
  • Date Received: Aug. 11, 2016 Document No.: 200440055 FENCING WASHINGTON Operator: Lilis Energy Inc Facility: PIEPER LEO Description: Fencing around the equipment, pits, and battery is in poor condition. Today two calves were in the tank battery fencing. The access road has poor drainage which causes the cattle guard to fill with sediment and makes it so cattle will walk right over it. Resolution:
  • Date Received: Aug. 11, 2016 Document No.: 200440055 TRASH WASHINGTON Operator: Lilis Energy Inc Facility: PIEPER LEO Description: Workers have left trash, equipment, t-posts on the location. Landowner has cleaned up some trash on his own. Resolution:
  • Date Received: Aug. 11, 2016 Document No.: 200440055 ROADS WASHINGTON Operator: Lilis Energy Inc Facility: PIEPER LEO Description: The access road is poorly maintained. In some areas the road became so rutted and unusable that the trucks just moved over and made new tracks. Resolution:
  • Date Received: June 10, 2016 Document No.: 2097 PROPERTY DAMAGE Operator: Invalid Operator Facility: Description: Location is reported as: Location legal is on Sec 5 2S 56W. Located on county Rd B between county Rd 23 and 24 in Washington county.Complainant reports: The issue is power lines that are to low to get farm equipment under. I have been dealing with the problem for 2 years now. It is a private line owned by Magpie operating. I used to be able to drive under them but no longer can. They had someone do some work to them and ever since they have been to low. We now have to try and harvest and manage our property by hanging equipment under the line and come with in inches of hitting them with the farm equipment Resolution: if someone was to hit them it will spark a fire
  • Date Received: June 6, 2016 Document No.: 200439653 ROYALTY WASHINGTON Operator: Fritzler Resources Inc Facility: SCOTT-FEDERAL Description: Complainant states: Fritzler Resources has not paid Royalties on this well since 2011, even though it is still producing through pumping rods. We have tried contacting Fritzler Resources for several months using ALL of the phone numbers listed on the COGCC website. Every single phone number has a "mailbox full" message, and it has been this way since January 2016. My Sister, Linda Merritt and I are Successor Co-Trustees of my Mother's Trust (Julianne Merritt - JAM Trust). Julianne Merritt passed away on December 3, 2015. We are now owners of this mineral interest and we are trying to resolve this change of ownership and collect past-due Royalties. Any help the COGCC can give us will be greatly appreciated! Complainant indicates royalty payments ceased in August 2011. Resolution: I contacted Ms. Merritt on June 7 and provided her with all of the phone numbers we had for Gene Fritzler and Fritzler Resources. Additionally, I verbally explained the Form 37 and 38 processes for payment of proceeds. I followed up with Ms. Merritt on July 25 and she reported that she sent him the Form 37 and finally received a call from him. Although there had been a misunderstanding in the last payment that had been made to her mother, no proceeds have been paid since sometime in 2014. She is waiting to hear from Mr. Fritzler regarding payment. She is waiting for the 60 days to run. The new numbers she has for Gene Fritzler is 970-867-1268 and personal cell 970-768-0845.
  • Date Received: July 13, 2015 Document No.: 200435650 VEGETATION WASHINGTON Operator: Invalid Operator Facility: N. KEJR UNIT Description: Aerial photos provided by complainant and verified by site aerial photos show areas of stressed vegetation at PA well locations. Resolution:
  • Date Received: July 13, 2015 Document No.: 200435650 SOIL CONTAMINATION WASHINGTON Operator: Invalid Operator Facility: N. KEJR UNIT Description: OLD EQUIPMENT NOT CLEANED UP FROM ABANDONED WELL SITE AND CONTAMINATED SOIL AT OLD WELL SITES. WE HAVE BEEN UNABLE TO GROW CROPS ON SUBJECT AREAS. SEE ATTACHED MAP FOR DIRECTIONS. Three wells are nearby: 121-06098, 121-06083, and 121-06099 Resolution:
  • Date Received: July 13, 2015 Document No.: 200435650 ORPHANED EQUIPMENT WASHINGTON Operator: Invalid Operator Facility: N. KEJR UNIT Description: OLD EQUIPMENT NOT CLEANED UP FROM ABANDONED WELL SITE AND CONTAMINATED SOIL AT OLD WELL SITES. WE HAVE BEEN UNABLE TO GROW CROPS ON SUBJECT AREAS. SEE ATTACHED MAP FOR DIRECTIONS. Three wells are nearby: 121-06098, 121-06083, and 121-06099 Resolution:
  • Date Received: Dec. 2, 2013 Document No.: 200390716 PITS WASHINGTON Operator: Cm Production Llc Facility: OLIVER-WARREN Description: Former employee of CM Production, LLC contacted COGCC and said he was directed by CM Production, to bury two skim pits at the production facility. former employee indicated that no samples were collected, that E&P waste (oily) was in pit, no Form 27s filled out. Resolution: Based on the complaint, COGCC Environmental Protection Specialist John Noto inspected the location on 11/20/13 (Document #670600080). The field inspection documented that the skim pits were not present. A review of aerial photographs documented that the pits had been closed during the time CM Production was the operator of the well and associated production facilities. Based on the inspection, a Notice of Alleged Violation (Document #200390913) was issued to CM Production on 12/3/13 alleging pit closure and exploration & production waste violations of COGCC rules. On 1/29/14, CM Production submitted a Form 27 (Document #2147680) Remediation Work Plan to investigate the former skim pit. On 3/27/14, CM Production’s consultant performed the site investigation. The investigation verified that oily waste had been left in place in the former skim pit. The NOAV remains part of a pending enforcement action and COGCC is seeking a fine and corrective actions requiring removal and appropriate treatment or disposal of all oily waste.
  • Date Received: Dec. 2, 2013 Document No.: 200390828 PITS WASHINGTON Operator: Cm Production Llc Facility: WARREN*S J Description: Former employee of CM Productions contacted COGCC and said he was directed by CM Production, to bury a skim pit at the production facility. The former employee indicated that no samples were collected, that E&P waste (oily) was in pit, and a Form 27 was not filled out. Resolution: Based on the complaint, COGCC Environmental Protection Specialist John Noto inspected the location on 11/20/13 (Document #670600098). The field inspection documented that the skim pit was not present. A review of aerial photographs documented that the pit had been closed during the time CM Production was the operator of the well and associated production facilities. Based on the inspection, a Notice of Alleged Violation (Document #200390941) was issued to CM Production on 12/3/13 alleging pit closure and exploration & production waste violations of COGCC rules. On 1/29/14, CM Production submitted a Form 27 (Document #2147593) Remediation Work Plan to investigate the former skim pit. On 3/24/14, CM Production’s consultant performed the site investigation. The investigation verified that oily waste had been left in place in the former skim pit. The NOAV remains part of a pending enforcement action and COGCC is seeking a fine and corrective actions requiring appropriate treatment or disposal of all oily waste.
  • Date Received: Dec. 2, 2013 Document No.: 200390716 SPILLS WASHINGTON Operator: Cm Production Llc Facility: OLIVER-WARREN Description: J. Noto phone conversation with Mr. Parks on 11/25/13. A reportable spill from top of treater occurred in the spring of 2013. The oil was sucked up and oil contaminated soil was placed in a bermed area. COGCC does not have record of spill on a Form 19. Resolution: Based on the complaint, COGCC inspected the location on 11/20/13 (Document #670600080). A pile of oily waste was documented on location. COGCC had no record of a Form 19 submitted for a spill resulting in the oily waste or a Form 27 for land treatment of oily waste as required by Rule 909.c.(3). CM Production had no way to verify the spill volume, but maintained the spill volume did not exceed reportable volumes. COGCC issued a Notice of Alleged Violation (Document #200390913) for exploration and production waste violations and improper closure of the skim pit. The NOAV remains part of a pending enforcement action and COGCC is seeking a fine and corrective actions requiring removal and appropriate treatment or disposal of all oily waste.
  • Date Received: Nov. 7, 2013 Document No.: 200389278 SPILLS WASHINGTON Operator: Magpie Operating, Inc Facility: LITTLE BEAVER UNIT Description: Surface owner contacted COGCC to complain that an "injection line" on cropland has broken several times and that spills have occurred that has rendered the land "useless for future agricultural planning". Email with description of concerns was sent to COGCC and is filed under this complaint Resolution:
  • Date Received: Oct. 18, 2013 Document No.: 200388345 PROPERTY DAMAGE WASHINGTON Operator: Magpie Operating, Inc Facility: LITTLE BEAVER UNIT Description: Surface-Owner (Mr.Jack Duvall) contacted COGCC NE Field Inspector (Kym Schure) regarding ongoing alleged damages to property resulting from underground line repairs due to leaks causing releases in the soils. Mr. Duvall wrote a letter describing the Surface-Owners negative history with the Operator (Magpie Operating). Letter is attached to inspection Doc.#664001353. Mr. Duvall states numerous leaks have been discovered by the surface leasee (Mr.Justin Wagers)over a period of years and each time the Operator was notified. Resulting in unsatisfactory responses from the Operator regarding the surface/soils concerns by the Surface-Owner and Leasee (Mr.Jack Duvall and Mr.Justin Wagers). Resolution: COGCC Environmental issued NOAV - Compliance performance has commenced
  • Date Received: Oct. 1, 2012 Document No.: 200364942 ORPHANED EQUIPMENT WASHINGTON Operator: Kimbark Oil & Gas Company Facility: ADKINS Description: Karen Spray received a call this afternoon from a Mr. Joe Klausner in Washington County. He has brine water bubbling to the surface in the middle of his wheat field in W ½ Sec 24 T1S R56W. It’s about 3 miles south of Woodrow. I pulled this location up on COGIS and we do have some old PA wells in this location. He would like for someone(s) to give him a call at 970-768-6093 (cell) and he will meet them to show the exact location. There are no currently active wells in his field, but at least 4 apparent PA (see below). He has a salt kill in his wheat field due to this and would like to see it addressed if it is an old well. Can someone(s) please schedule a time to meet with him? He is very polite and just looking for some answers. Resolution: This is a duplicate of Complaint #200364943 and is closed.
  • Date Received: Oct. 1, 2012 Document No.: 200364943 ORPHANED EQUIPMENT WASHINGTON Operator: Kimbark Oil & Gas Company Facility: ADKINS Description: Karen Spray received a call this afternoon from a Mr. Joe Klausner in Washington County. He has brine water bubbling to the surface in the middle of his wheat field in W ½ Sec 24 T1S R56W. It’s about 3 miles south of Woodrow. I pulled this location up on COGIS and we do have some old PA wells in this location. He would like for someone(s) to give him a call at 970-768-6093 (cell) and he will meet them to show the exact location. There are no currently active wells in his field, but at least 4 apparent PA (see below). He has a salt kill in his wheat field due to this and would like to see it addressed if it is an old well. Resolution: Well re-plugged see COGCC Document #663300887
  • Date Received: Feb. 17, 2010 Document No.: 200231280 SPILLS WASHINGTON Operator: Petro-Canada Resources (Usa) Inc Facility: XENIA WEST UNIT Description: Landowner (Larry Grooms) claims a pit release flooded a small portion of his corn pivot. Resolution: Noble Energy took location over from PetroCanada and performed corrective actions required by NOAV that were documented in Remediaiton Projects #5016 and #5200. Results of groundwater sample collected from irrigation water well were submitted to landowner (Document #2608457)on 8/3/10. Results were inconclusive for impacts related to Oil & Gas operations. Noble Energy volunteered to perform additional groundwater characterization but were denied access by land owner to perform the work.
  • Date Received: Feb. 17, 2010 Document No.: 200231280 SPILLS WASHINGTON Operator: Petro-Canada Resources (Usa) Inc Facility: XENIA WEST UNIT Description: Landowner (Larry Grooms) claims a pit release flooded a small portion of his corn pivot. Resolution: Noble Energy took location over from PetroCanada and performed corrective actions required by NOAV that were documented in Remediaiton Projects #5016 and #5200. Results of groundwater sample collected from irrigation water well were submitted to landowner (Document #2608457)on 8/3/10. Results were inconclusive for impacts related to Oil & Gas operations. Noble Energy volunteered to perform additional groundwater characterization but were denied access by land owner to perform the work.
  • Date Received: Feb. 17, 2010 Document No.: 200231280 SPILLS WASHINGTON Operator: Petro-Canada Resources (Usa) Inc Facility: XENIA WEST UNIT Description: Landowner (Larry Grooms) claims a pit release flooded a small portion of his corn pivot. Resolution: Noble Energy took location over from PetroCanada and performed corrective actions required by NOAV that were documented in Remediaiton Projects #5016 and #5200. Results of groundwater sample collected from irrigation water well were submitted to landowner (Document #2608457)on 8/3/10. Results were inconclusive for impacts related to Oil & Gas operations. Noble Energy volunteered to perform additional groundwater characterization but were denied access by land owner to perform the work.

NOAVs

COGCC has issued 112 NOAVs in Washington County, Colorado:

Document No.: 2465139 Enforcement Action: Final Resolution Comment:

Document No.: 1770053 Enforcement Action: Final Resolution Comment:

Document No.: 1770039 Enforcement Action: Final Resolution Comment:

Document No.: 2001135 Enforcement Action: Final Resolution Comment: Well passed MIT.

Document No.: 2559352 Enforcement Action: Final Resolution Comment:

Document No.: 2618002 Enforcement Action: Final Resolution Comment:

Document No.: 200226304 Enforcement Action: Final Resolution Comment: Resolution is satisfactory. No further action required.

Document No.: 200226557 Enforcement Action: Final Resolution Comment: Resolution is satisfactory. No further action required.

Document No.: 200226556 Enforcement Action: Final Resolution Comment: Resolution is satisfactory. No further action required.

Document No.: 200226575 Enforcement Action: Final Resolution Comment: Resolution is satisfactory. No further action required.

Document No.: 200242471 Enforcement Action: Final Resolution Comment: Corrective actions were documented in remediation project #5016 and skim pit closure remediation project #5200 performed by Noble Energy. COGCC also sampled nearby irrigation well to determine if there had been impacts to groundwater in area. Results reported to landowner (Document # 2608457) on 8

Document No.: 200257756 Enforcement Action: Final Resolution Comment: Corrective action complete. No further action required

Document No.: 200273766 Enforcement Action: Final Resolution Comment: Corrective actions were completed. Pit complex was closed and oily waste properly disposed off site. Tanks were installed for produced water to be properly disposed off site. See remediation #7091 for additional information regarding pit closure/remediation.

Document No.: 200390770 Enforcement Action: Final Resolution Comment:

Document No.: 200308970 Enforcement Action: Final Resolution Comment: Notice of Alleged Violation was resolved by Administrative Order by Consent - Cause No. 1V, Docket No. 1108-OV-22. Refer to COGCC Project #6845 (document #1761329) for additional information regarding remediation.

Document No.: 200337810 Enforcement Action: Final Resolution Comment: Resulted in Administrative Order by Consent (reference Order No. 1V-398, Docket No. 1205-OV-04) whereby Beren Corporation was fined $25,000 for violation of Rules 906.a., 906.b. & 907.a. and ordered to complete all corrective actions set forth in the NOAV. Refer to Remediation #7036 for information

Document No.: 200390773 Enforcement Action: Final Resolution Comment:

Document No.: 200350687 Enforcement Action: Final Resolution Comment: All corrective actions were completed. Refer to Remediation Project #7094, which verified no impact to shallow groundwater. Refer to Remediation Project #7366 for skim pit closure documentation. Skim pit was properly closed, all oily waste was properly disposed off site and a skim vessel was inst

Document No.: 200353921 Enforcement Action: Final Resolution Comment: Operator submitted Form 19 - spill tracking #2231937. Performed spill cleanup and confirmation sampling that verified remaining soils comply with Table 910-1 standards - reference Doc #2145341. Also repaired piping on east side of injection plant and investigated area of concern in field south of

Document No.: 200390780 Enforcement Action: Final Resolution Comment:

Document No.: 200390785 Enforcement Action: Final Resolution Comment:

Document No.: 200390786 Enforcement Action: Final Resolution Comment:

Document No.: 200390787 Enforcement Action: Final Resolution Comment:

Document No.: 200358023 Enforcement Action: Final Resolution Comment: OPERATOR SUBMITTED REQUESTED DOCUMENTS AND CLOSED THE WORKOVER PIT - SEE REMEDIATION PROJECT 7364.

Document No.: 200369845 Enforcement Action: Final Resolution Comment: No Action

Document No.: 200369844 Enforcement Action: Final Resolution Comment: No Action

Document No.: 200369846 Enforcement Action: Final Resolution Comment: No Further Action

Document No.: 200369847 Enforcement Action: Final Resolution Comment: No Action-Well Plugged and Abandoned July 1, 2013.

Document No.: 200370949 Enforcement Action: Final Resolution Comment: Well was repaired and MIT passed. Operator was advised to be compliant with COGCC's rules in the future.

Document No.: 200378586 Enforcement Action: Final Resolution Comment: Resulted in Administrative Order by Consent (Order No. 1V-420) approved by the Commission on 10/28/13. Caerus was fined $70,000 for documented rule violations and required to complete all corrective actions outlined in the NOAV. Refer to Project #7886 for remediation information.

Document No.: 200376557 Enforcement Action: Final Resolution Comment: Corrective actions completed. See Project #7796 for remediation details.

Document No.: 200390941 Enforcement Action: Final Resolution Comment:

Document No.: 200390913 Enforcement Action: Final Resolution Comment:

Document No.: 200390769 Enforcement Action: Final Resolution Comment:

Document No.: 200390788 Enforcement Action: Final Resolution Comment:

Document No.: 200390793 Enforcement Action: Final Resolution Comment:

Document No.: 200426372 Enforcement Action: Final Resolution Comment:

Document No.: 200428452 Enforcement Action: Final Resolution Comment:

Document No.: 200393001 Enforcement Action: Final Resolution Comment:

Document No.: 200392590 Enforcement Action: Final Resolution Comment:

Document No.: 200393545 Enforcement Action: Final Resolution Comment:

Document No.: 200409794 Enforcement Action: Final Resolution Comment:

Document No.: 200436605 Enforcement Action: Final Resolution Comment:

Document No.: 200433400 Enforcement Action: Final Resolution Comment:

Document No.: 200413930 Enforcement Action: Final Resolution Comment:

Document No.: 200419274 Enforcement Action: Final Resolution Comment:

Document No.: 200420089 Enforcement Action: Final Resolution Comment:

Document No.: 401083039 Rule: 309 Rule Description: Operator's Monthly Production Report Alleged Violation Description: Pursuant to Rule 309, Fritzler Resources Inc (Operator) is required to submit Form 7, Monthly Reports of Operations, for all existing oil and gas wells that are not plugged and abandoned within 45 days after the end of each month. Operator is required to report each formation that is completed in a well every month from the time that it is completed until one month after abandonment. Operator has not submitted Form 7, Monthly Reports of Operation for the Agnas Friedly #1 well, API 121-11023, (Well) since December 2015, violating Rule 309. Enforcement Action: AOC Corrective Action Description: Operator shall submit Form 7, Monthly Reports of Operation, for the Well for January 2016 through August 2016. Final Resolution Comment: Resolved by Order 1V-620.

Document No.: 401226306 Rule: 326.b Rule Description: Shut-in Wells Alleged Violation Description: Pursuant to Rules 326.b., operator is required to perform a mechanical integrity test (MIT) on shut-in (SI) wells within two years of the initial shut-in date and then at five year intervals after an initial successful MIT. Based on Operator’s Form 7s – Operator’s Monthly Report of Operations, the CRISWELL 1 (API # 05-121-09558) (Well) has been SI since October 2014. Based on the well file, the Well is past due for a MIT. Enforcement Action: OFV Corrective Action Description: Operator shall immediately schedule and complete either an MIT of the Well or plug and abandon the Well. Rule 316B requires notice to the Director on a Form 42 at least ten days prior to conducting an MIT, and submission of MIT results on a Form 21, within 30 days after the test. A pressure chart shall accompany this Form 21 report. Rule 311 requires Operator to submit a Form 6, Notice of Intent to Abandon, and secure Director approval prior to plugging and abandonment of a well, and to submit a Form 6, Subsequent Report of Abandonment, within 30 days after plugging and abandonment of the well has been completed. Final Resolution Comment: Resolved by Order 1V-636.

Document No.: 401238912 Rule: 1004 Rule Description: Final Reclamation of Well Sites and Associated Production Facilities Alleged Violation Description: Pursuant to Rule 1004, upon the plugging and abandonment of a well, Geotech Production Inc (Operator) shall: 1) backfill all pits, mouse and rat holes, and cellars; 2) remove all debris and surface equipment within three (3) months; 3) reclaim well locations, access roads, and associated facilities; and 4) as applicable, perform restoration and revegetation work at well sites, associated production facilities, and access roads to the same standards established for interim reclamation under Rule 1003. All such reclamation work shall be completed within twelve (12) months on non-crop land after plugging a well or final closure of associated production facilities. Operator plugged and abandoned the State #1X-16 well, API 121-09694, (Well) at Location #403644 on June 1, 2007 (Document #1917446). During an inspection of Location #403644 on July 28, 2010 (Document #200264573), COGCC staff observed that three pits remained open, fencing remained around the pits in disrepair, and trash remained on the location in the pasture. Document #200264573 required Operator to secure COGCC approval, through a Form 27, Site Investigation and Remediation Workplan, and close the pits by October 1, 2010. During an inspection of Location #403644 on July 5, 2012 (Document #668700036), COGCC staff observed that the pits and fencing were still present on the location. Document 668700036 required Operator to secure COGCC approval, through a Form 27, Site Investigation and Remediation Workplan, and close the pits by July 26, 2012. During an inspections of the Location #403644 on March 16, 2016 (Document #682500508), COGCC staff observed that the site has inadequate vegetative cover; fence, pipe, and other debris remained on location; and the pit has not been reclaimed. Document #682500508 noted the passed due corrective action deadline of October 1, 2010, and required Operator to secure COGCC approval, through a Form 27, Site Investigation and Remediation Workplan, and close the pit as required by Rule 909. Document #682500508 also required Operator to remove debris and remaining equipment; establish vegetation with total perennial non-invasive plant cover of at least 80% of pre-disturbance or reference area levels using a seed mixture matching adjacent pastureland or a seed mixture requested by the landowner; and ensure erosion controls are implemented and maintained until Final Reclamation has been passed. All of these Final Reclamation activities were required to begin immediately as of the date Document #682500508 was entered, March 18, 2016. During an inspection of Location #403644 on August 31, 2016 (Document #682501283), COGCC staff observed the fence around the pit and the pipe within the pit was removed but debris, gravel, and stained soil remain on location, and no other reclamation work appeared to have been conducted. Document #682501283 required Operator to secure COGCC approval, through a Form 27, Site Investigation and Remediation Workplan, and close the pit as required by Rule 909. Document #682501283 also required Operator to remove debris and remaining equipment; establish vegetation with total perennial non-invasive plant cover of at least 80% of pre-disturbance or reference area levels using a seed mixture matching adjacent pastureland or a seed mixture requested by the landowner; and ensure erosion controls are implemented and maintained until Final Reclamation has been passed. Document #682501283 restated the requirement for all of these Final Reclamation activities to begin immediately as of the date Document #682500508 was entered, March 1 Enforcement Action: AOC Corrective Action Description: Operator shall submit a Form 27, Site Investigation and Remediation Workplan, for COGCC approval prior to closing the pit (Facility ID #119830) as required by Rule 909. The remediation plan shall also address the removal and proper treatment or disposal of any other remaining E&P waste on location. Operator shall remove debris and remaining equipment; establish vegetation with total perennial non-invasive plant cover of at least 80% of pre-disturbance or reference area levels using a seed mixture matching adjacent pastureland or a seed mixture requested by the landowner; and ensure erosion controls are implemented and maintained until Final Reclamation has been passed. Final Resolution Comment: Resolved by Order 1V-640. Reclamation efforts ongoing.

Document No.: 401083039 Rule: 311 Rule Description: Well Abandonment Report Alleged Violation Description: Pursuant to Rule 311, Fritzler Resources Inc (Operator) is required to submit a Form 6, Notice of Intent to Abandon, and secure Director approval prior to plugging and abandonment of a well and to submit a Form 6, Subsequent Report of Abandonment, within 30 days after plugging and abandonment of the well has been completed. Based on Operator’s Form 7 Monthly Reports of Operations stating the well has been SI since May 2013, COGCC staff had reason to believe the Agnas Friedly #1, API 121-11023, (Well) was past due for performance of an MIT. Warning Letter #2193080 was issued to Operator on December 15, 2015 and required corrective action to resolve the delinquent MIT by April 30, 2016. Operator submitted a Form 6, Notice of Intent to Abandon the Well on January 20, 2016 (Document #2211505), which was approved by COGCC staff on February 26, 2016. On March 8, 2016, Operator submitted a Form 42 Field Operations Notice stating Operator’s intent to plug the Well on March 10, 2016 (Document #401002098). A COGCC inspection on April 4, 2016 noted that the well is now plugged (Document # 673713037), but No Form 6, Subsequent Report of Abandonment, has been submitted to COGCC to date to document that plugging activity, violating Rule 311. Enforcement Action: AOC Corrective Action Description: Operator shall immediately submit a Form 6, Subsequent Report of Abandonment, to COGCC. Final Resolution Comment: Resolved by Order 1V-620.

Document No.: 401082382 Rule: 309 Rule Description: Operator's Monthly Production Report Alleged Violation Description: Pursuant to Rule 309, Alfred Ward & Son Operating Company (Ward) (Operator No. 94300) is required to submit Form 7 Monthly Reports of Operations for all existing oil and gas wells that are not plugged and abandoned. Ward is required to report each formation that is completed in a well every month from the time that it is completed until one month after abandonment. Warning Letter #2193171 was issued to Operator on February 2, 2016, and required corrective action to resolve the delinquent Form 7 monthly reporting issue within 30 days of the issuance of that letter. Ward failed to submit Form 7, Monthly Reports of Operations, for the Blomenkamp #1 well (API 121-08878), from December 2015 to June 2016, violating Rule 309. Enforcement Action: AOC Corrective Action Description: Ward shall submit Form 7 reports for API 121-08878 for December 2015 to June 2016. Final Resolution Comment: Resolved via Order Number 1V-626, entered on March 20, 2017.

Document No.: 401082382 Rule: 326.c.(1) Rule Description: MIT - Temporarily Abandoned Wells - Performance Within 30 Days Alleged Violation Description: Pursuant to Rules 326.c.(1) and (2), Operator is required to perform a mechanical integrity test (MIT) on temporarily abandoned (TA) wells within 30 days of temporarily abandoning the well and then at five (5) year intervals after an initial successful MIT. COGCC staff conducted inspections of Blomenkamp #1, API 121-08878, (Well) on July 14, 2015 (Document #678200223) and August 18, 2014 (Document #673705592) and observed that the wells status was TA on both occasions. Form 7, Monthly Reports of Operation, submitted by Operator have reported the Well has been shut-in (SI) since July 2012. COGCC has no record of an MIT ever being performed on the Well. Warning Letter #2193171 was issued to Operator on February 2, 2016, and required corrective action to resolve the delinquent MIT issue by April 30, 2016. To date, Operator has not conducted an MIT for the Well, violating Rules 326.c.(1) and (2). Enforcement Action: AOC Corrective Action Description: Operator shall immediately schedule and complete either an MIT of the Well or plugging and abandonment of the Well. Rule 316B requires notice to the Director on a Form 42 at least ten (10) days prior to conducting an MIT and submission of MIT results on a Form 21, within thirty (30) days after the test. A pressure chart shall accompany this Form 21 report. Rule 311 requires Operator to submit a Form 6, Notice of Intent to Abandon and secure Director approval prior plugging and abandonment of a well and to submit a Form 6, Subsequent Report of Abandonment, within 30 days after plugging and abandonment of the well has been completed. Final Resolution Comment: Resolved via Order Number 1V-626, entered on March 20, 2017.

Document No.: 401149390 Rule: 309 Rule Description: Operator's Monthly Production Report Alleged Violation Description: Pursuant to Rule 309, High Plains Energy LLC (Operator) is required to submit Form 7, Monthly Reports of Operations, for all existing oil and gas wells that are not plugged and abandoned. Operator is required to report every month from the time the well is spud until one month after abandonment. Operator spud the State Hone #16-1 well, API 121-11019, (Well) on February 10, 2014. Operator failed to submit Form 7, Monthly Reports of Operations, for the DSND formation of the Well from February 2014 through September 2016, violating Rule 309. Enforcement Action: Corrective Action Description: Operator shall submit Form 7 reports for the DSND formation of the Well for February 2014 through September 2016. Final Resolution Comment:

Document No.: 401149390 Rule: 319.b.(1) Rule Description: Temporary Abandonment - Notice Required Alleged Violation Description: Pursuant to Rule 319.b.(1), for wells temporarily abandoned (TA), High Plains Energy LLC (Operator) is required to submit a Form 4, Sundry Notice, to the Director to request TA status and state plans for future operation. Additional Form 4, Sundry Notices, are required to be submitted annually stating the method by which the well is closed to atmosphere and plans for future operation. Operator submitted a Form 5A, Completed Interval Report, for the State Hone #16-1 well, API 121-11019, (Well) on August 13, 2015 (Document #400884334) indicating the D Sand Formation of the Well was recompleted in August 2015, but was found to be dry and incapable of production. Wells that are incapable of production without the addition of one or more pieces of wellhead or other equipment, including valves, tubing, rods, pumps, heater-treaters, separators, dehydrators, compressors, piping or tanks are by COGCC Rule classified as Temporarily Abandoned (TA). Operator has not submitted a Form 4, Sundry Notice, requesting continued TA status, violating Rule 319.b.(1). Enforcement Action: Corrective Action Description: Operator shall submit a Form 4, Sundry Notice, requesting extended TA status for the Well and stating the method by which the well is closed to atmosphere and plans for future operation. Final Resolution Comment:

Document No.: 401149390 Rule: 326 Rule Description: Mechanical Integrity Testing Alleged Violation Description: Pursuant to Rule 326, High Plains Energy LLC (Operator) is required to conduct a mechanical integrity test (MIT) on Temporarily Abandoned (TA) wells within 30 days of temporary abandonment. Operator submitted a Form 5A, Completed Interval Report, for the State Hone #16-1 well, API 121-11019, (Well) on August 13, 2015 (Document #400884334) indicating the D Sand Formation of the Well was recompleted in August 2015, but was found to be dry and incapable of production. Wells that are incapable of production without the addition of one or more pieces of wellhead or other equipment, including valves, tubing, rods, pumps, heater-treaters, separators, dehydrators, compressors, piping or tanks are by COGCC Rule classified as Temporarily Abandoned (TA).To date the COGCC has received no evidence that an MIT has been conducted on the Well, violating Rule 326. Enforcement Action: Corrective Action Description: Operator shall immediately schedule and complete either an MIT of the Well or plugging and abandonment of the Well. Rule 316B requires notice to the Director on a Form 42 at least ten (10) days prior to conducting an MIT and submission of MIT results on a Form 21, within thirty (30) days after the test. A pressure chart shall accompany this Form 21 report. Rule 311 requires Operator to submit a Form 6, Notice of Intent to Abandon and secure Director approval prior plugging and abandonment of a well and to submit a Form 6, Subsequent Report of Abandonment, within 30 days after plugging and abandonment of the well has been completed. Final Resolution Comment:

Document No.: 401541541 Rule: 210 Rule Description: Signs and Markers Alleged Violation Description: Pursuant to Rule 210., Magpie Operating, Inc. (“Operator”) shall mark each and every well in a conspicuous place, from the time of initial drilling until final abandonment, as follows: 210.b. Operator shall install a tank battery sign that provides Operator’s name, a phone number at which Operator can be reached at all times, and the names of the wells associated with the battery or the lease name for the associated wells; 210.d. Operator shall label storage containers with specified information, including NFPA label; and 210.e. Operator shall maintain all signs in a legible condition and shall replace damaged signs within 60 days. On July 25, 2017, COGCC Staff conducted an inspection of Operator’s Little Beaver Unit Injection Plant (ID 451505, “Location”) and took photographs showing that the operator information provided on a sign at the main injection building is illegible and that the NFPA placard attached to the horizontal crude oil tank (“AST”) located northwest of the vertical heater treater (“VHT”) sheds is in need of replacement. In the associated Field Inspection Report (Document No. 681700672), COGCC Staff instructed Operator to repair or replace the signs to comply with Rule 210. by October 1, 2017. COGCC Staff conducted a follow up inspection on December 19, 2017, and photographed the conditions of signs and labels at the main injection building and horizontal crude oil AST, showing that they had not been replaced or repaired. In the associated Field Inspection Report (Document No. 681700966) COGCC Staff again instructed Operator to immediately repair or replace the signs to comply with Rule 210., retaining the original corrective action deadline of October 1, 2017. Operator failed to maintain in legible condition and failed to repair or replace required signage at the main injection building and on the ASTs, in violation of Rule 210. Enforcement Action: Corrective Action Description: Operator shall repair or replace signs at the main injection building and the horizontal crude oil AST. Final Resolution Comment:

Document No.: 401226274 Rule: 326.b Rule Description: Shut-in Wells Alleged Violation Description: Pursuant to Rules 326.b., operator is required to perform a mechanical integrity test (MIT) on shut-in (SI) wells within two years of the initial shut-in date and then at five year intervals after an initial successful MIT. Based on Operator’s Form 7s – Operator’s Monthly Report of Operations, the RESLER 22-27 (API # 05-121-10345) (Well) has been SI since August 2014. Based on the well file, the Well is past due for a MIT. Enforcement Action: OFV Corrective Action Description: Operator shall immediately schedule and complete either an MIT of the Well or plug and abandon the Well. Rule 316B requires notice to the Director on a Form 42 at least ten days prior to conducting an MIT, and submission of MIT results on a Form 21, within 30 days after the test. A pressure chart shall accompany this Form 21 report. Rule 311 requires Operator to submit a Form 6, Notice of Intent to Abandon, and secure Director approval prior to plugging and abandonment of a well, and to submit a Form 6, Subsequent Report of Abandonment, within 30 days after plugging and abandonment of the well has been completed. Final Resolution Comment: Resolved by Order 1V-636.

Document No.: 401226283 Rule: 326.b Rule Description: Shut-in Wells Alleged Violation Description: Pursuant to Rules 326.b., operator is required to perform a mechanical integrity test (MIT) on shut-in (SI) wells within two years of the initial shut-in date and then at five year intervals after an initial successful MIT. Based on Operator’s Form 7s – Operator’s Monthly Report of Operations, the RESLER 12-27 (API # 05-121-10323) (Well) has been SI since September 2014. Based on the well file, the Well is past due for a MIT. Enforcement Action: OFV Corrective Action Description: Operator shall immediately schedule and complete either an MIT of the Well or plug and abandon the Well. Rule 316B requires notice to the Director on a Form 42 at least ten days prior to conducting an MIT, and submission of MIT results on a Form 21, within 30 days after the test. A pressure chart shall accompany this Form 21 report. Rule 311 requires Operator to submit a Form 6, Notice of Intent to Abandon, and secure Director approval prior to plugging and abandonment of a well, and to submit a Form 6, Subsequent Report of Abandonment, within 30 days after plugging and abandonment of the well has been completed. Final Resolution Comment: Resolved by Order 1V-636.

Document No.: 401226297 Rule: 326.b Rule Description: Shut-in Wells Alleged Violation Description: Pursuant to Rules 326.b., operator is required to perform a mechanical integrity test (MIT) on shut-in (SI) wells within two years of the initial shut-in date and then at five year intervals after an initial successful MIT. Based on Operator’s Form 7s – Operator’s Monthly Report of Operations, the FASSLER 42-28 (API # 05-121-10338) (Well) has been SI since February 2015. Based on the well file, the Well is past due for a MIT. Enforcement Action: OFV Corrective Action Description: Operator shall immediately schedule and complete either an MIT of the Well or plug and abandon the Well. Rule 316B requires notice to the Director on a Form 42 at least ten days prior to conducting an MIT, and submission of MIT results on a Form 21, within 30 days after the test. A pressure chart shall accompany this Form 21 report. Rule 311 requires Operator to submit a Form 6, Notice of Intent to Abandon, and secure Director approval prior to plugging and abandonment of a well, and to submit a Form 6, Subsequent Report of Abandonment, within 30 days after plugging and abandonment of the well has been completed. Final Resolution Comment: Resolved by Order 1V-636.

Document No.: 401541541 Rule: 603.f Rule Description: Statewide Equipment, Weeds, Waste, and Trash Requirements Alleged Violation Description: Pursuant to Rule 603.f., Magpie Operating, Inc. (“Operator”) shall keep all locations free of weeds, trash, debris and other rubbish. Rule 603.f. also applies to unused flowline risers (as unused equipment). On July 25, 2017, COGCC Staff conducted an inspection of Operator’s Little Beaver Unit Injection Plant (ID 451505, “Location”) and photographed wood debris, empty boxes, broken pipes, and other trash at the crude oil tank battery and the vertical heater treater (“VHT”) sheds. In the associated Field Inspection Report (Document No. 681700672), COGCC Staff instructed Operator to comply with Rule 603.f. by August 10, 2017. COGCC Staff also observed multiple unused flowlines throughout the Location, and in the Field Inspection Report instructed Operator to contact COGCC Engineering Integrity section by August 10, 2017, to discuss flowline abandonment requirements and a resolution plan. COGCC Staff conducted a follow up inspection on December 19, 2017, and photographed the continued presence of trash and debris at both the crude oil tank battery and VHT sheds, as well as unused flowline risers throughout the Location. In the associated Field Inspection Report (Document No. 681700966) COGCC Staff again instructed Operator to comply with Rule 603.f. and to contact the COGCC Engineering Integrity section by the original corrective action deadline of August 10, 2017. During the December 2017 inspection, COGCC Staff also observed the presence of a concrete slab with wood debris approximately 50’ east of the building located on the east side of the Location. In the associated Field Inspection Report, COGCC Staff instructed Operator to remove this slab to comply with Rule 603.f no later than March 26, 2018. Operator failed keep this location free of trash and debris, and failed to abandon unused flowlines, in violation of Rule 603.f. Enforcement Action: Corrective Action Description: Operator shall immediately remove wood debris and trash from locations listed in Field Inspection Report Nos. 681700672 and 681700966, and shall contact the COGCC Engineering Integrity section to plan abandonment of unused flowlines, by the Corrective Action Due Date indicated here. Operator shall also comply with the March 26, 2018, corrective action date for removal of the concrete slab. Final Resolution Comment:

Document No.: 401541541 Rule: 605.a.(4) Rule Description: Oil & Gas Facilities- Berms Alleged Violation Description: Pursuant to Rule 605.a.(4), Magpie Operating, Inc. (“Operator”) shall construct, inspect at regular intervals, and maintain berms or other secondary containment devices around crude oil, condensate, and produced water tanks (“ASTs”). On July 25, 2017, COGCC Staff conducted an inspection of Operator’s Little Beaver Unit Injection Plant (ID 451505, “Location”) and observed shallow and eroded earthen berms surrounding crude oil and produced water ASTs. In the associated Field Inspection Report (Document No. 681700672), COGCC Staff instructed Operator to repair or install berms or other secondary containment devices by September 1, 2017. COGCC Staff conducted a follow up inspection on December 19, 2017, and photographed the unrepaired earthen berms for crude oil and produced water ASTs and observed they that these berms were still shallow and eroded. COGCC Staff also observed that the berms shared by a horizontal AST and the vertical heater treater (“VHT”) sheds at the Location were shallow and eroded. In the associated Field Inspection Report (Document No. 681700966) COGCC Staff again instructed Operator to repair or install berms or other secondary containment devices for the crude oil and produced water ASTs by the original corrective action deadline of September 1, 2017; and to repair the earthen berms shared by a horizontal AST and VHT sheds by January 26, 2018. Operator failed to maintain adequate earthen berms or other secondary containment surrounding crude oil and produced water ASTs, in violation of Rule 605.a.(4). Enforcement Action: Corrective Action Description: Operator shall immediately repair earthen berms surrounding crude oil and produced water ASTs and around the VHT sheds, and provide photo documentation of the repaired berms to the COGCC Environmental Protection Specialist. Final Resolution Comment:

Document No.: 401541541 Rule: 906.b Rule Description: Spill Reporting Alleged Violation Description: Pursuant to Rule 906.b., Magpie Operating, Inc. (“Operator”) shall make a supplemental spill report to the director not more than ten (10) calendar days after the spill/release is discovered. On October 28, 2014, Operator submitted an initial Form 19 Spill/Release Report (Document No. 400718966) to document a release of produced water and crude oil from a produced water tank into its containment berm that had occurred on October 26, 2014. The spill was assigned a Spill/Release point ID of #439500 (“Spill”). In comments on the approved form, Operator is instructed to provide waste disposal manifests and a topographic map along with the required supplemental spill report. Pursuant to Rule 906.b., Operator was required to submit a supplemental Form 19 Spill/Release Report no later than November 5, 2014, for this Spill. As of January 9, 2018, no supplemental Form 19 Spill/Release Report has been received by the COGCC for this Spill. Operator’s failure to file a supplemental spill report to the Director within 10 days of the discovery of the Spill is a violation of Rule 906.b reporting requirements. Enforcement Action: Corrective Action Description: Operator shall immediately file a Supplemental Form 19 Spill Report to request closure of the Spill record, if appropriate, or to document additional remediation of the impacted area. Operator’s supplemental report shall include documentation of disposition of impacted soil and/or groundwater. Final Resolution Comment:

Document No.: 401541541 Rule: 605.d Rule Description: O&G Facilities - Mechanical Conditions Alleged Violation Description: Pursuant to Rule 605.d, Magpie Operating, Inc. (“Operator”) shall securely fasten and maintain in good mechanical condition all valves, pipes and fittings. On January 28, 2014, COGCC Staff conducted an inspection of Operator’s Little Beaver Unit Injection Plant (ID 451505, “Location”) and photographed localized oil-stained soil associated with flowline valves and manifolds inside of the building located on the east side of this Location. This inspection report included a corrective action instructing Operator to remove and remediate stained soils at the battery with a corrective action due date of February 1, 2014. Follow up inspections conducted by COGCC Staff observed additional accumulations of oily waste associated with production equipment at the tank battery, most notably underlying unlabeled storage containers and inside of treater sheds (Document No. 673706779, October 9, 2014); and fluid leaking from a valve attached to the southern crude oil tank, as well as numerous historical accumulations underlying production equipment (Document No. 673713319, June 13, 2016). With each of these inspections, COGCC Staff required Operator to perform corrective action(s) to remove or remediate stained soils, carrying forward due dates when a previous corrective action had not been performed, and assigning new due dates for new or recurring stains and oily waste accumulations. Operator filed a Form 42 Notice of Corrective Actions Performed (Document No. 400792517) on February 13, 2015, certifying that the corrective actions required by the October 2014 Field Inspection Report (Document No. 673706779) had been completed as of December 16, 2014, and the July 2016 Field Inspection Report (Document No. 673713633) states that the corrective actions from the June 2016 inspection (Document No. 673713319) were completed. Starting with a follow up inspection in July 2017, COGCC Staff again observed significant accumulations of oily waste inside of the building located on the east side of the facility, as well as a continued leak from the red valve attached to the southern crude oil tank (Document No. 681700672, July 25, 2017); and the enduring conditions of oily waste underlying production equipment, inside of vertical heater treater sheds, and underlying the leaking red valve attached to the southern crude oil tank (Document No. 681700966, December 19, 2017). In the July 2017 Field Inspection Report, COGCC Staff gave Operator corrective action due dates of 8/3/2017 to remediate stained soils and 9/1/2017 to ensure mechanical integrity of production equipment; those corrective action due dates were retained in the December 2017 Field Inspection Report. COGCC Field Inspection Reports dating back to January 2014, document repeated instances of localized environmental impacts associated with production equipment demonstrating Operator’s failure to maintain equipment and to ensure good mechanical conditions. Dating back to July 25, 2017, COGCC Field Inspection Reports document sustained failures to maintain equipment and ensure good mechanical conditions, in violation of Rule 605.d. Enforcement Action: Corrective Action Description: Operator shall immediately inspect and repair equipment listed in Field Inspection Report Nos. 681700672 and 681700966 to ensure mechanical integrity. Operator shall provide to COGCC documentation of repairs or replacements made in response to this Corrective Action. Final Resolution Comment:

Document No.: 401541541 Rule: 907.e Rule Description: Oily Waste Alleged Violation Description: Pursuant to Rule 907.e., Magpie Operating, Inc. (“Operator”) shall treat or dispose of oily waste in accordance with options listed under 907.e.(1), such as disposal at a commercial solid waste disposal facility, or land treatment onsite, or at a permitted centralized E&P waste management facility. On January 28, 2014, COGCC Staff conducted an inspection of Operator’s Little Beaver Unit Injection Plant (ID 451505, “Location”) and observed an accumulation of oily waste at the tank battery. The associated Field Inspection Report (Document No. 673701019) included a photograph showing staining beneath a valve that was located inside of the building on the east side of the facility, and instructed Operator to remove and remediate stained soils at the battery with a corrective action due date of February 1, 2014. Over the next four years, COGCC Staff conducted at least five follow-up inspections, documenting continued and increasing instances of stained soils at the Location, including stained soil beneath unlabeled chemical storage containers and inside both treater sheds (Document No. 673706779, October 9, 2014); leaks from a valve at the south crude oil tank, stained soil inside of the produced water tank berms, flooding of the vertical heater treater sheds, and accumulations of produced fluids along the east side of the main injection building (Document No. 673713319, June 13, 2016); continued fluid presence on the east side of the main injection building and in the northeast corner of the produced water tank berm (Document No. 673713633, July 29, 2016); the recurrence of crude oil leaks from the valve at the south crude oil tank, oily waste underlying various flowline risers, crude oil and produced water tanks (and associated flowlines), at the crude oil loadout, on east and west sides of main injection building, and inside of both vertical heater treater sheds (Document No. 681700672, July 25, 2017); another fluid drip from the valve at the south crude oil tank, new staining at the crude oil loadout and diesel tank as well as preexisting staining persisting beneath the produced water tanks, inside vertical heater treater sheds, beneath the crude oil tanks and associated flowline risers, and at the southwest corner of the main building (Document No. 681700966, December 19, 2017). With each of these inspections, COGCC Staff required Operator to perform corrective action(s) to remove or remediate stained soils, carrying forward due dates when a previous corrective action had not been performed, and assigning new due dates for new or recurring stains and oily waste accumulations. Operator filed a Form 42 Notice of Corrective Actions Performed (Document No. 400792517) on February 13, 2015, certifying that the corrective actions required by the October 2014 Field Inspection Report (Document No. 673706779) had been completed as of December 16, 2014, and the July 2016 Field Inspection Report (Document No. 673713633) states that the corrective actions from the June 2016 inspection (Document No. 673713319) were completed. Starting with the photos from the July 2016 inspection (Document No. 673713633), which show water on the east side of the main building and inside the northeast corner of the produced water tank berm, COGCC Staff has documented multiple instances of stained soils and oily waste accumulations that were not corrected. Since the July 2016 inspection, COGCC Staff has also documented multiple instances of the continuation or recurrence of stained soils, and oily waste spills or accumulations, that had first Enforcement Action: Corrective Action Description: Operator shall immediately remove and properly dispose of accumulations of oily waste from equipment listed in Field Inspection Report No. 681700966 and shall submit a Form 27 for site investigation and remediation of impacts associated with the eastern building. Due to the documented presence of shallow groundwater and the failure to timely remediate oily waste, Magpie shall perform a site wide groundwater characterization of the entire Little Beaver Injection Facility including all ancillary buildings and equipment. The work plan for groundwater characterization can be submitted on the same Form 27. A proposed soil boring/monitor well location diagram shall be included. A sufficient number of borings and monitor wells will need to be installed and sampled to determine if groundwater in the areas of surface releases has been impacted. Groundwater gradient, flow direction and hydraulic conductivity shall be determined. An upgradient monitor well shall also be installed to determine background water quality conditions. Final Resolution Comment:

Document No.: 401541545 Rule: 319.b Rule Description: Temporary Abandonment Alleged Violation Description: Pursuant to Rule 319.b., Magpie Operating, Inc. (“Operator”) shall abandon any well which is incapable of production or injection within six months of ceasing production unless the well passes a successful Mechanical Integrity Test (“MIT”) and the time is extended by the Director upon application by the owner. The application shall indicate why the well is Temporarily Abandoned (“TA”) and future plans for utilization. COGCC Rule 100 defines a well as temporarily abandoned if the well becomes incapable of production. Any well incapable of production should have a well status of TA in filings with COGCC, including the Form 7, Monthly Reports of Operations. COGCC Rules do not permit placing a well back on production to fulfill, or in lieu of, the requirements to conduct an MIT. Subsequent MIT will be required at the frequency specified in Rule 326. COGCC Staff conducted an inspection of Operator’s Little Beaver Unit #25 location (ID 316994, “Location”) on January 28, 2014, and observed that the pump jack was not connected to the well (API 05-121-06259, “Well”). In the associated Field Inspection Report (Document No. 673701018), COGCC Staff instructed operator to comply with MIT/TA requirements no later than February 28, 2014. On April 9, 2014, COGCC Staff conducted an inspection to document a witnessed MIT (Field Inspection Report Document No. 673702215, MIT Form 21 Document No. 673702216). As of January 3, 2018, Operator has not submitted an application or sundry notice to request continued TA status for this well. COGCC Staff conducted a follow up inspection on October 9, 2014, and documented in the field photos that the well remained incapable of production. In the associated Field Inspection Report (Document No. 673706775), COGCC Staff instructed Operator to update the production record. Operator reported one (1) day of production in November 2015 (1 bbl oil, 500 bbls of produced water). On June 13, 2016, COGCC Staff conducted an inspection of the Location and observed that the pump jack remained disconnected from the wellhead. In the associated Field Inspection Report (Document No.673713317), COGCC Staff instructed Operator again to update the production record. On July 25, 2017, COGCC Staff conducted a follow-up inspection. In the associated Field Inspection Report (Document No. 681700658, “FIR 681700658”), COGCC Staff documented the Well’s production status as TA on the basis that the Well was incapable of production, matching the 100-series definition of a TA well. COGCC Staff also noted that the Well status was listed as PR in the COGCC database and the production record listed the Well as SI from December 2015 to March 2017. In FIR 681700658, COGCC Staff instructed Operator to contact the Engineering unit with a resolution to the Well’s status no later than August 7, 2017. On December 19, 2017, COGCC Staff conducted a follow-up inspection. In the associated Field Inspection Report (Document No. 681700965), COGCC Staff again documented the Well’s TA status and reiterated the instruction for Operator to contact Engineering unit to resolve the well’s status with the original corrective action date of August 7, 2017. Operator failed to MIT, plug and abandon, or request continued TA status for the Well, in violation of Rule 319.b. Enforcement Action: Corrective Action Description: Operator shall conduct a successful MIT on the Well and submit a Form 4 Sundry Notice to request continued TA status for the Well; or shall plug and abandon the Well, including submitting and receiving approval of a Form 6 Notice of Intent to Abandon. If well will not produce within 12 months of December 19, 2017, inspection date (Document No. 681700965), Operator shall remove pump jack to comply with Rule 603.f. Final Resolution Comment:

Document No.: 401541545 Rule: 905 Rule Description: Closure of Pits, and Buried or Partially Buried Produced Water Vessels Alleged Violation Description: Pursuant to Rule 905.b., Magpie Operating, Inc. (“Operator”) shall close pits not used exclusively for drilling operations in accordance with an approved Site Investigation and Remediation Workplan (“Form 27”). COGCC Rule 100 defines Pit as any natural or man-made depression in the ground used for oil or gas exploration or production purposes, excluding vessels which do not release their contents to surrounding soils. Operator shall submit the Form 27 for prior Director approval and such Form 27 shall include a description of the proposed investigation and remediation activities in accordance with Rule 909. On July 25, 2017, COGCC Staff conducted an inspection of Operator’s Little Beaver Unit #25 location (ID 316994, “Location”) and observed the presence of unknown fluids and flowlines inside of a vertical culvert structure (“Structure”) at the Location. In the associated Field Inspection Report (Document No. 681700658), COGCC Staff instructed the operator to submit a Form 27 Site Investigation and Remediation Workplan by August 28, 2017, in order to identify the fluid inside of the structure as stormwater, groundwater, or produced fluids, and to investigate potential environmental impacts prior to its abandonment. COGCC Staff conducted a follow up inspection of the Location on December 19, 2017, and observed that Operator had removed the Structure prior to the inspection date. In the associated Field Inspection Report (Document No. 681700965), COGCC Inspection Staff instructed Operator to immediately contact the COGCC Environmental Protection Specialist to discuss pit closure and site investigation requirements. As of January 3, 2018, Operator has not submitted Form 27 regarding disposal of the unidentified liquid or abandonment of the subject structure. Operator’s removal of the vertical culvert structure without an approved COGCC workplan constitutes a violation of Rule 905.b pit closure requirements. Enforcement Action: Corrective Action Description: Operator shall submit an eForm 27 Site Investigation and Remediation Workplan for closure of the subject structure, investigation of environmental impacts, and remediation of the impacted area. Final Resolution Comment:

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Document No.: 401665886 Rule: 907.e Rule Description: Oily Waste Alleged Violation Description: Pursuant to Rule 907.e.(1), HRM Resources II LLC (“Operator”) shall treat or dispose of oily waste from the oil and gas operations at the Marick #1-A facility (ID 317081, “Location”) that is not removed to a commercial solid waste disposal facility or a permitted centralized E&P waste management facility, by land treatment onsite. Pursuant to Rule 907.e.(2)G., when land treatment occurs in an area not being utilized for oil and gas operations, Operator shall obtain prior written surface owner approval. Pursuant to conditions of approval (“COA”) on the Site Investigation and Remediation Workplan (“Form 27”) for skim pit closure and land treatment of oily waste at the Location, “land treatment of oily waste shall be performed in strict accordance with the requirements of COGCC Rule 907.e.(2)” (Form 27 Document No. 2086926, COGCC approved with COA on April 26, 2015, for Remediation Project No. 9015). On March 30, 2018, the surface owner filed a complaint with COGCC (Document No. 200445680, “Complaint”) alleging property damage due, in part, to Operator’s land treatment of oily waste. According to the Complaint, the surface owner did not provide Operator with prior authorization to perform land treatment of oily waste on his crop land adjacent to the Location. The Complaint further states Operator’s land treatment caused approximately $3000 of crop damage as of early June 2015, and that the surface owner received a check from Operator for $3000 on June 12, 2015. According to the Complaint, the surface owner understood this check to be compensation for the crop damage that had occurred, and did not give Operator authorization to continue to use his crop land for the three year planned duration of the remediation project. COGCC Staff performed an inspection on April 23, 2018, to investigate the complaint and survey using GPS the areas where oily waste was being treated (Field Inspection Report No. 688000148 and aerial image showing land treatment areas in Document No. 2087412). During investigation of the complaint, COGCC Staff determined that Operator was treating oily waste by land treatment off the disturbed areas of the location on areas of crop land. As part of the investigation, COGCC requested Operator to provide a copy of prior written surface owner authorization. Operator provided a response to COGCC (Document No. 2496354) verifying that, while a one-time payment was made to the surface owner for crop loss, no written surface owner authorization was ever obtained for land treatment of oily waste. Operator failed to obtain written surface owner approval prior to using surface owner’s land for treatment of oily waste, violating Rule 907.e. and violating Operators Form 27 COA and § 34-60-121.(1)(a), C.R.S. Enforcement Action: Corrective Action Description: Operator shall remove all oily waste being land treated under COGCC Remediation Project No. 9015 from the site and properly disposed at a commercial solid waste disposal facility in accordance with Rule 907.e. no later than May 31, 2018. By July 31, 2018, Operator shall submit to COGCC all of the following: - All waste generator documentation required by Rule 907.b.(2) to document disposal of the oily waste; via supplemental Form 27. By July 31, 2018, - Sampling and analysis of native soil underlying the current land treatment areas to demonstrate that remaining soil complies with all contaminants of concern in Table 910-1. Samples shall be collected in a grid pattern following the same number and location of samples collected during land treatment. - A sample location diagram, summary table of results compared to Table 910-1 standards, and copy of all laboratory reports; via supplemental Form 27. If remaining soil complies with Table 910-1 standards, Operator shall perform reclamation of the offsite disturbed areas suitable to bring those areas back to productive crop land. If underlying soils do not comply with Table 910-1 standards, Operator will be required to perform additional remediation to remove any residual impacts. Operator shall consult with surface owner in writing on waste removal schedule, sampling and analysis results and reclamation plans. Final reclamation of disturbed areas shall be completed no later than August 31, 2018. Final Resolution Comment:

Document No.: 401781555 Rule: 326.b Rule Description: Shut-in Wells Alleged Violation Description: Pursuant to Rule 326.b., CORAL PRODUCTION CORP ("Operator") is required to perform a Mechanical Integrity Test ("MIT") on Shut-in ("SI") wells within two (2) years of the initial shut-in date and then at five (5) year intervals after an initial successful MIT. COGCC Rules do not permit placing a well back on production to fulfill, or in lieu of, the requirements to conduct an MIT. COGCC Staff had reason to believe Operator had committed one or more violations of COGCC Rules, and issued Warning Letter No. 401588905 to Operator on March 28, 2018 , requiring Operator to conduct MIT or plug and abandon delinquent wells by June 30, 2018 . On July 24, 2018 , COGCC Staff conducted an audit (“Audit”) of Operator's records for the well(s) in the attached table ("Well"). 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 SI, and the COGCC database to determine whether Operator reported MIT(s) for the Well. Through this Audit, COGCC Staff determined that at least one Well in the attached table was overdue for performance of an MIT on a SI well. Operator failed to conduct timely MIT(s) for at least one SI Well, violating Rule 326.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 July 24, 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. Final Resolution Comment:

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Document No.: 401541541 Rule: 210 Rule Description: Signs and Markers Alleged Violation Description: Pursuant to Rule 210., Magpie Operating, Inc. (“Operator”) shall mark each and every well in a conspicuous place, from the time of initial drilling until final abandonment, as follows: 210.b. Operator shall install a tank battery sign that provides Operator’s name, a phone number at which Operator can be reached at all times, and the names of the wells associated with the battery or the lease name for the associated wells; 210.d. Operator shall label storage containers with specified information, including NFPA label; and 210.e. Operator shall maintain all signs in a legible condition and shall replace damaged signs within 60 days. On July 25, 2017, COGCC Staff conducted an inspection of Operator’s Little Beaver Unit Injection Plant (ID 451505, “Location”) and took photographs showing that the operator information provided on a sign at the main injection building is illegible and that the NFPA placard attached to the horizontal crude oil tank (“AST”) located northwest of the vertical heater treater (“VHT”) sheds is in need of replacement. In the associated Field Inspection Report (Document No. 681700672), COGCC Staff instructed Operator to repair or replace the signs to comply with Rule 210. by October 1, 2017. COGCC Staff conducted a follow up inspection on December 19, 2017, and photographed the conditions of signs and labels at the main injection building and horizontal crude oil AST, showing that they had not been replaced or repaired. In the associated Field Inspection Report (Document No. 681700966) COGCC Staff again instructed Operator to immediately repair or replace the signs to comply with Rule 210., retaining the original corrective action deadline of October 1, 2017. Operator failed to maintain in legible condition and failed to repair or replace required signage at the main injection building and on the ASTs, in violation of Rule 210. Enforcement Action: Corrective Action Description: Operator shall repair or replace signs at the main injection building and the horizontal crude oil AST. Final Resolution Comment:

Document No.: 401149390 Rule: 309 Rule Description: Operator's Monthly Production Report Alleged Violation Description: Pursuant to Rule 309, High Plains Energy LLC (Operator) is required to submit Form 7, Monthly Reports of Operations, for all existing oil and gas wells that are not plugged and abandoned. Operator is required to report every month from the time the well is spud until one month after abandonment. Operator spud the State Hone #16-1 well, API 121-11019, (Well) on February 10, 2014. Operator failed to submit Form 7, Monthly Reports of Operations, for the DSND formation of the Well from February 2014 through September 2016, violating Rule 309. Enforcement Action: Corrective Action Description: Operator shall submit Form 7 reports for the DSND formation of the Well for February 2014 through September 2016. Final Resolution Comment:

Document No.: 401149390 Rule: 319.b.(1) Rule Description: Temporary Abandonment - Notice Required Alleged Violation Description: Pursuant to Rule 319.b.(1), for wells temporarily abandoned (TA), High Plains Energy LLC (Operator) is required to submit a Form 4, Sundry Notice, to the Director to request TA status and state plans for future operation. Additional Form 4, Sundry Notices, are required to be submitted annually stating the method by which the well is closed to atmosphere and plans for future operation. Operator submitted a Form 5A, Completed Interval Report, for the State Hone #16-1 well, API 121-11019, (Well) on August 13, 2015 (Document #400884334) indicating the D Sand Formation of the Well was recompleted in August 2015, but was found to be dry and incapable of production. Wells that are incapable of production without the addition of one or more pieces of wellhead or other equipment, including valves, tubing, rods, pumps, heater-treaters, separators, dehydrators, compressors, piping or tanks are by COGCC Rule classified as Temporarily Abandoned (TA). Operator has not submitted a Form 4, Sundry Notice, requesting continued TA status, violating Rule 319.b.(1). Enforcement Action: Corrective Action Description: Operator shall submit a Form 4, Sundry Notice, requesting extended TA status for the Well and stating the method by which the well is closed to atmosphere and plans for future operation. Final Resolution Comment:

Document No.: 401149390 Rule: 326 Rule Description: Mechanical Integrity Testing Alleged Violation Description: Pursuant to Rule 326, High Plains Energy LLC (Operator) is required to conduct a mechanical integrity test (MIT) on Temporarily Abandoned (TA) wells within 30 days of temporary abandonment. Operator submitted a Form 5A, Completed Interval Report, for the State Hone #16-1 well, API 121-11019, (Well) on August 13, 2015 (Document #400884334) indicating the D Sand Formation of the Well was recompleted in August 2015, but was found to be dry and incapable of production. Wells that are incapable of production without the addition of one or more pieces of wellhead or other equipment, including valves, tubing, rods, pumps, heater-treaters, separators, dehydrators, compressors, piping or tanks are by COGCC Rule classified as Temporarily Abandoned (TA).To date the COGCC has received no evidence that an MIT has been conducted on the Well, violating Rule 326. Enforcement Action: Corrective Action Description: Operator shall immediately schedule and complete either an MIT of the Well or plugging and abandonment of the Well. Rule 316B requires notice to the Director on a Form 42 at least ten (10) days prior to conducting an MIT and submission of MIT results on a Form 21, within thirty (30) days after the test. A pressure chart shall accompany this Form 21 report. Rule 311 requires Operator to submit a Form 6, Notice of Intent to Abandon and secure Director approval prior plugging and abandonment of a well and to submit a Form 6, Subsequent Report of Abandonment, within 30 days after plugging and abandonment of the well has been completed. Final Resolution Comment:

Document No.: 401541541 Rule: 603.f Rule Description: Statewide Equipment, Weeds, Waste, and Trash Requirements Alleged Violation Description: Pursuant to Rule 603.f., Magpie Operating, Inc. (“Operator”) shall keep all locations free of weeds, trash, debris and other rubbish. Rule 603.f. also applies to unused flowline risers (as unused equipment). On July 25, 2017, COGCC Staff conducted an inspection of Operator’s Little Beaver Unit Injection Plant (ID 451505, “Location”) and photographed wood debris, empty boxes, broken pipes, and other trash at the crude oil tank battery and the vertical heater treater (“VHT”) sheds. In the associated Field Inspection Report (Document No. 681700672), COGCC Staff instructed Operator to comply with Rule 603.f. by August 10, 2017. COGCC Staff also observed multiple unused flowlines throughout the Location, and in the Field Inspection Report instructed Operator to contact COGCC Engineering Integrity section by August 10, 2017, to discuss flowline abandonment requirements and a resolution plan. COGCC Staff conducted a follow up inspection on December 19, 2017, and photographed the continued presence of trash and debris at both the crude oil tank battery and VHT sheds, as well as unused flowline risers throughout the Location. In the associated Field Inspection Report (Document No. 681700966) COGCC Staff again instructed Operator to comply with Rule 603.f. and to contact the COGCC Engineering Integrity section by the original corrective action deadline of August 10, 2017. During the December 2017 inspection, COGCC Staff also observed the presence of a concrete slab with wood debris approximately 50’ east of the building located on the east side of the Location. In the associated Field Inspection Report, COGCC Staff instructed Operator to remove this slab to comply with Rule 603.f no later than March 26, 2018. Operator failed keep this location free of trash and debris, and failed to abandon unused flowlines, in violation of Rule 603.f. Enforcement Action: Corrective Action Description: Operator shall immediately remove wood debris and trash from locations listed in Field Inspection Report Nos. 681700672 and 681700966, and shall contact the COGCC Engineering Integrity section to plan abandonment of unused flowlines, by the Corrective Action Due Date indicated here. Operator shall also comply with the March 26, 2018, corrective action date for removal of the concrete slab. Final Resolution Comment:

Document No.: 401541541 Rule: 605.a.(4) Rule Description: Oil & Gas Facilities- Berms Alleged Violation Description: Pursuant to Rule 605.a.(4), Magpie Operating, Inc. (“Operator”) shall construct, inspect at regular intervals, and maintain berms or other secondary containment devices around crude oil, condensate, and produced water tanks (“ASTs”). On July 25, 2017, COGCC Staff conducted an inspection of Operator’s Little Beaver Unit Injection Plant (ID 451505, “Location”) and observed shallow and eroded earthen berms surrounding crude oil and produced water ASTs. In the associated Field Inspection Report (Document No. 681700672), COGCC Staff instructed Operator to repair or install berms or other secondary containment devices by September 1, 2017. COGCC Staff conducted a follow up inspection on December 19, 2017, and photographed the unrepaired earthen berms for crude oil and produced water ASTs and observed they that these berms were still shallow and eroded. COGCC Staff also observed that the berms shared by a horizontal AST and the vertical heater treater (“VHT”) sheds at the Location were shallow and eroded. In the associated Field Inspection Report (Document No. 681700966) COGCC Staff again instructed Operator to repair or install berms or other secondary containment devices for the crude oil and produced water ASTs by the original corrective action deadline of September 1, 2017; and to repair the earthen berms shared by a horizontal AST and VHT sheds by January 26, 2018. Operator failed to maintain adequate earthen berms or other secondary containment surrounding crude oil and produced water ASTs, in violation of Rule 605.a.(4). Enforcement Action: Corrective Action Description: Operator shall immediately repair earthen berms surrounding crude oil and produced water ASTs and around the VHT sheds, and provide photo documentation of the repaired berms to the COGCC Environmental Protection Specialist. Final Resolution Comment:

Document No.: 401541541 Rule: 605.d Rule Description: O&G Facilities - Mechanical Conditions Alleged Violation Description: Pursuant to Rule 605.d, Magpie Operating, Inc. (“Operator”) shall securely fasten and maintain in good mechanical condition all valves, pipes and fittings. On January 28, 2014, COGCC Staff conducted an inspection of Operator’s Little Beaver Unit Injection Plant (ID 451505, “Location”) and photographed localized oil-stained soil associated with flowline valves and manifolds inside of the building located on the east side of this Location. This inspection report included a corrective action instructing Operator to remove and remediate stained soils at the battery with a corrective action due date of February 1, 2014. Follow up inspections conducted by COGCC Staff observed additional accumulations of oily waste associated with production equipment at the tank battery, most notably underlying unlabeled storage containers and inside of treater sheds (Document No. 673706779, October 9, 2014); and fluid leaking from a valve attached to the southern crude oil tank, as well as numerous historical accumulations underlying production equipment (Document No. 673713319, June 13, 2016). With each of these inspections, COGCC Staff required Operator to perform corrective action(s) to remove or remediate stained soils, carrying forward due dates when a previous corrective action had not been performed, and assigning new due dates for new or recurring stains and oily waste accumulations. Operator filed a Form 42 Notice of Corrective Actions Performed (Document No. 400792517) on February 13, 2015, certifying that the corrective actions required by the October 2014 Field Inspection Report (Document No. 673706779) had been completed as of December 16, 2014, and the July 2016 Field Inspection Report (Document No. 673713633) states that the corrective actions from the June 2016 inspection (Document No. 673713319) were completed. Starting with a follow up inspection in July 2017, COGCC Staff again observed significant accumulations of oily waste inside of the building located on the east side of the facility, as well as a continued leak from the red valve attached to the southern crude oil tank (Document No. 681700672, July 25, 2017); and the enduring conditions of oily waste underlying production equipment, inside of vertical heater treater sheds, and underlying the leaking red valve attached to the southern crude oil tank (Document No. 681700966, December 19, 2017). In the July 2017 Field Inspection Report, COGCC Staff gave Operator corrective action due dates of 8/3/2017 to remediate stained soils and 9/1/2017 to ensure mechanical integrity of production equipment; those corrective action due dates were retained in the December 2017 Field Inspection Report. COGCC Field Inspection Reports dating back to January 2014, document repeated instances of localized environmental impacts associated with production equipment demonstrating Operator’s failure to maintain equipment and to ensure good mechanical conditions. Dating back to July 25, 2017, COGCC Field Inspection Reports document sustained failures to maintain equipment and ensure good mechanical conditions, in violation of Rule 605.d. Enforcement Action: Corrective Action Description: Operator shall immediately inspect and repair equipment listed in Field Inspection Report Nos. 681700672 and 681700966 to ensure mechanical integrity. Operator shall provide to COGCC documentation of repairs or replacements made in response to this Corrective Action. Final Resolution Comment:

Document No.: 401541541 Rule: 906.b Rule Description: Spill Reporting Alleged Violation Description: Pursuant to Rule 906.b., Magpie Operating, Inc. (“Operator”) shall make a supplemental spill report to the director not more than ten (10) calendar days after the spill/release is discovered. On October 28, 2014, Operator submitted an initial Form 19 Spill/Release Report (Document No. 400718966) to document a release of produced water and crude oil from a produced water tank into its containment berm that had occurred on October 26, 2014. The spill was assigned a Spill/Release point ID of #439500 (“Spill”). In comments on the approved form, Operator is instructed to provide waste disposal manifests and a topographic map along with the required supplemental spill report. Pursuant to Rule 906.b., Operator was required to submit a supplemental Form 19 Spill/Release Report no later than November 5, 2014, for this Spill. As of January 9, 2018, no supplemental Form 19 Spill/Release Report has been received by the COGCC for this Spill. Operator’s failure to file a supplemental spill report to the Director within 10 days of the discovery of the Spill is a violation of Rule 906.b reporting requirements. Enforcement Action: Corrective Action Description: Operator shall immediately file a Supplemental Form 19 Spill Report to request closure of the Spill record, if appropriate, or to document additional remediation of the impacted area. Operator’s supplemental report shall include documentation of disposition of impacted soil and/or groundwater. Final Resolution Comment:

Document No.: 401541541 Rule: 907.e Rule Description: Oily Waste Alleged Violation Description: Pursuant to Rule 907.e., Magpie Operating, Inc. (“Operator”) shall treat or dispose of oily waste in accordance with options listed under 907.e.(1), such as disposal at a commercial solid waste disposal facility, or land treatment onsite, or at a permitted centralized E&P waste management facility. On January 28, 2014, COGCC Staff conducted an inspection of Operator’s Little Beaver Unit Injection Plant (ID 451505, “Location”) and observed an accumulation of oily waste at the tank battery. The associated Field Inspection Report (Document No. 673701019) included a photograph showing staining beneath a valve that was located inside of the building on the east side of the facility, and instructed Operator to remove and remediate stained soils at the battery with a corrective action due date of February 1, 2014. Over the next four years, COGCC Staff conducted at least five follow-up inspections, documenting continued and increasing instances of stained soils at the Location, including stained soil beneath unlabeled chemical storage containers and inside both treater sheds (Document No. 673706779, October 9, 2014); leaks from a valve at the south crude oil tank, stained soil inside of the produced water tank berms, flooding of the vertical heater treater sheds, and accumulations of produced fluids along the east side of the main injection building (Document No. 673713319, June 13, 2016); continued fluid presence on the east side of the main injection building and in the northeast corner of the produced water tank berm (Document No. 673713633, July 29, 2016); the recurrence of crude oil leaks from the valve at the south crude oil tank, oily waste underlying various flowline risers, crude oil and produced water tanks (and associated flowlines), at the crude oil loadout, on east and west sides of main injection building, and inside of both vertical heater treater sheds (Document No. 681700672, July 25, 2017); another fluid drip from the valve at the south crude oil tank, new staining at the crude oil loadout and diesel tank as well as preexisting staining persisting beneath the produced water tanks, inside vertical heater treater sheds, beneath the crude oil tanks and associated flowline risers, and at the southwest corner of the main building (Document No. 681700966, December 19, 2017). With each of these inspections, COGCC Staff required Operator to perform corrective action(s) to remove or remediate stained soils, carrying forward due dates when a previous corrective action had not been performed, and assigning new due dates for new or recurring stains and oily waste accumulations. Operator filed a Form 42 Notice of Corrective Actions Performed (Document No. 400792517) on February 13, 2015, certifying that the corrective actions required by the October 2014 Field Inspection Report (Document No. 673706779) had been completed as of December 16, 2014, and the July 2016 Field Inspection Report (Document No. 673713633) states that the corrective actions from the June 2016 inspection (Document No. 673713319) were completed. Starting with the photos from the July 2016 inspection (Document No. 673713633), which show water on the east side of the main building and inside the northeast corner of the produced water tank berm, COGCC Staff has documented multiple instances of stained soils and oily waste accumulations that were not corrected. Since the July 2016 inspection, COGCC Staff has also documented multiple instances of the continuation or recurrence of stained soils, and oily waste spills or accumulations, that had first Enforcement Action: Corrective Action Description: Operator shall immediately remove and properly dispose of accumulations of oily waste from equipment listed in Field Inspection Report No. 681700966 and shall submit a Form 27 for site investigation and remediation of impacts associated with the eastern building. Due to the documented presence of shallow groundwater and the failure to timely remediate oily waste, Magpie shall perform a site wide groundwater characterization of the entire Little Beaver Injection Facility including all ancillary buildings and equipment. The work plan for groundwater characterization can be submitted on the same Form 27. A proposed soil boring/monitor well location diagram shall be included. A sufficient number of borings and monitor wells will need to be installed and sampled to determine if groundwater in the areas of surface releases has been impacted. Groundwater gradient, flow direction and hydraulic conductivity shall be determined. An upgradient monitor well shall also be installed to determine background water quality conditions. Final Resolution Comment:

Document No.: 401541545 Rule: 319.b Rule Description: Temporary Abandonment Alleged Violation Description: Pursuant to Rule 319.b., Magpie Operating, Inc. (“Operator”) shall abandon any well which is incapable of production or injection within six months of ceasing production unless the well passes a successful Mechanical Integrity Test (“MIT”) and the time is extended by the Director upon application by the owner. The application shall indicate why the well is Temporarily Abandoned (“TA”) and future plans for utilization. COGCC Rule 100 defines a well as temporarily abandoned if the well becomes incapable of production. Any well incapable of production should have a well status of TA in filings with COGCC, including the Form 7, Monthly Reports of Operations. COGCC Rules do not permit placing a well back on production to fulfill, or in lieu of, the requirements to conduct an MIT. Subsequent MIT will be required at the frequency specified in Rule 326. COGCC Staff conducted an inspection of Operator’s Little Beaver Unit #25 location (ID 316994, “Location”) on January 28, 2014, and observed that the pump jack was not connected to the well (API 05-121-06259, “Well”). In the associated Field Inspection Report (Document No. 673701018), COGCC Staff instructed operator to comply with MIT/TA requirements no later than February 28, 2014. On April 9, 2014, COGCC Staff conducted an inspection to document a witnessed MIT (Field Inspection Report Document No. 673702215, MIT Form 21 Document No. 673702216). As of January 3, 2018, Operator has not submitted an application or sundry notice to request continued TA status for this well. COGCC Staff conducted a follow up inspection on October 9, 2014, and documented in the field photos that the well remained incapable of production. In the associated Field Inspection Report (Document No. 673706775), COGCC Staff instructed Operator to update the production record. Operator reported one (1) day of production in November 2015 (1 bbl oil, 500 bbls of produced water). On June 13, 2016, COGCC Staff conducted an inspection of the Location and observed that the pump jack remained disconnected from the wellhead. In the associated Field Inspection Report (Document No.673713317), COGCC Staff instructed Operator again to update the production record. On July 25, 2017, COGCC Staff conducted a follow-up inspection. In the associated Field Inspection Report (Document No. 681700658, “FIR 681700658”), COGCC Staff documented the Well’s production status as TA on the basis that the Well was incapable of production, matching the 100-series definition of a TA well. COGCC Staff also noted that the Well status was listed as PR in the COGCC database and the production record listed the Well as SI from December 2015 to March 2017. In FIR 681700658, COGCC Staff instructed Operator to contact the Engineering unit with a resolution to the Well’s status no later than August 7, 2017. On December 19, 2017, COGCC Staff conducted a follow-up inspection. In the associated Field Inspection Report (Document No. 681700965), COGCC Staff again documented the Well’s TA status and reiterated the instruction for Operator to contact Engineering unit to resolve the well’s status with the original corrective action date of August 7, 2017. Operator failed to MIT, plug and abandon, or request continued TA status for the Well, in violation of Rule 319.b. Enforcement Action: Corrective Action Description: Operator shall conduct a successful MIT on the Well and submit a Form 4 Sundry Notice to request continued TA status for the Well; or shall plug and abandon the Well, including submitting and receiving approval of a Form 6 Notice of Intent to Abandon. If well will not produce within 12 months of December 19, 2017, inspection date (Document No. 681700965), Operator shall remove pump jack to comply with Rule 603.f. Final Resolution Comment:

Document No.: 401541545 Rule: 905 Rule Description: Closure of Pits, and Buried or Partially Buried Produced Water Vessels Alleged Violation Description: Pursuant to Rule 905.b., Magpie Operating, Inc. (“Operator”) shall close pits not used exclusively for drilling operations in accordance with an approved Site Investigation and Remediation Workplan (“Form 27”). COGCC Rule 100 defines Pit as any natural or man-made depression in the ground used for oil or gas exploration or production purposes, excluding vessels which do not release their contents to surrounding soils. Operator shall submit the Form 27 for prior Director approval and such Form 27 shall include a description of the proposed investigation and remediation activities in accordance with Rule 909. On July 25, 2017, COGCC Staff conducted an inspection of Operator’s Little Beaver Unit #25 location (ID 316994, “Location”) and observed the presence of unknown fluids and flowlines inside of a vertical culvert structure (“Structure”) at the Location. In the associated Field Inspection Report (Document No. 681700658), COGCC Staff instructed the operator to submit a Form 27 Site Investigation and Remediation Workplan by August 28, 2017, in order to identify the fluid inside of the structure as stormwater, groundwater, or produced fluids, and to investigate potential environmental impacts prior to its abandonment. COGCC Staff conducted a follow up inspection of the Location on December 19, 2017, and observed that Operator had removed the Structure prior to the inspection date. In the associated Field Inspection Report (Document No. 681700965), COGCC Inspection Staff instructed Operator to immediately contact the COGCC Environmental Protection Specialist to discuss pit closure and site investigation requirements. As of January 3, 2018, Operator has not submitted Form 27 regarding disposal of the unidentified liquid or abandonment of the subject structure. Operator’s removal of the vertical culvert structure without an approved COGCC workplan constitutes a violation of Rule 905.b pit closure requirements. Enforcement Action: Corrective Action Description: Operator shall submit an eForm 27 Site Investigation and Remediation Workplan for closure of the subject structure, investigation of environmental impacts, and remediation of the impacted area. Final Resolution Comment:

Document No.: 401957014 Rule: 1004.a Rule Description: Final Reclamation - Well Sites Reclamation Alleged Violation Description: Pursuant to Rule 1004.a., upon the plugging and abandonment of a well, Sand Hills Society (“Operator”) shall 1) backfill all pits, mouse and rat holes, and cellars; 2) remove all debris and surface equipment within three months; 3) reclaim well locations, access roads, culverts, and associated facilities; 4) as applicable, perform compaction alleviation, restoration, and revegetation work at well sites, associated production facilities, and access roads to the same standards established for interim reclamation under Rule 1003; and 5) remove all other equipment, supplies, weeds, rubbish, and other waste material. All such reclamation work shall be completed within three months on crop land and twelve months on non-crop land after plugging a well or final closure of associated production facilities, and Operator shall make every reasonable effort to complete reclamation before the next local growing season. On April 12, 2007, Operator plugged and abandoned the Strickler #1-31 (API No. 05-121-09713; at Location ID 403660, “Location”), (Form 6-Subsequent Document No. 2062139). The Location is on non-cropland, thus, pursuant to Rule 1004.a., Operator was required to complete final reclamation work no later than April 12, 2008. COGCC Staff observed the plugging operations, and required Operator to take the following steps with regards to the open pit(s) at the Location (Pit ID 117753, 104571; “Pit”): sample the Pit and file a Site Investigation and Remediation Workplan (“Form 27”) for COGCC’s approval before closing the Pit. (Field Inspection Report No. 200110143). On April 23, 2016, COGCC Staff conducted an inspection of the Location and observed that Operator failed to reclaim the Location and Pit in accordance with Rule 1004.a. final reclamation requirements: there were Pit, mouse/rat holes and/or cellars that had not been backfilled; the locations, facilities, and/or roads had not been recontoured; the Location had not been revegetated to 80% of reference area levels; and the Pit area where the well once resided remained unvegetated. COGCC Staff required Operator to perform the following corrective actions: sample the Pit, report results compared to the Table 910-1 standards, and submit a Form 27 by April 30, 2016; and establish appropriate vegetation and implement erosion controls to stabilize the seeded soil by May 31, 2016. (Field Inspection Report No. 682500676, “April 2016 FIR”). COGCC Staff conducted follow up inspections on December 15, 2016, and October 30, 2017, and observed that no reclamation work appeared to have been conducted and that the Pit was still open with no sample results or Form 27 submitted. COGCC Staff repeated the corrective action requirements, and retained the due dates from the April 2016 FIR. (Field Inspection Report Nos. 682501500 for December 15, 2016, and 682502768 for October 30, 2017). Operator failed to perform final reclamation at the Location, violating Rule 1004.a. Enforcement Action: Corrective Action Description: Operator shall perform reclamation in accordance with COGCC 1000-Series Rules at the Location. By the corrective action due date, Operator shall submit an eForm 4 Sundry Notice which: 1) Proposes a revegetation plan to accomplish the following before the next local growing season: a) Establish vegetation with total perennial, non-invasive uniform plant cover of at least eighty (80) percent of pre-disturbance or reference area levels, b) Use a seed mixture requested by the surface owner, or a mixture prescribed by the local county NRCS, and c) Implement erosion controls to stabilize the seeded soil, and continue to monitor and manage the Location until it has passed final reclamation; and 2) Details Operator’s plan (with specific tasks and schedules) to complete final reclamation at the Location, and proposes a reasonable timeline to complete such work. By the corrective action due date, Operator shall submit an eForm 27 with a plan to sample and properly close the Pit in accordance with Rules 905, 909 & 910. Operator shall include a proposed soil sample location diagram and plan to properly remediate any impacts. Final Resolution Comment:

Document No.: 401957014 Rule: 302.b Rule Description: Form 1A Designation of Agent Alleged Violation Description: Pursuant to Rule 302.b., Sand Hills Society (“Operator”) shall submit a Designation of Agent (“Form 1A”) listing employees approved to submit documents to COGCC on behalf of the Operator. Form 1A requires identification of a Principal Agent designated to accept and be served notices from COGCC. Operator shall immediately report all changes to reported agent information by submitting a new Form 1A. As of March 1, 2019, Operator has not identified a Principal Agent on a Form 1A. Operator’s has failed to maintain an up-to-date Form 1A on file with COGCC, with current designation of and contact information for Operator’s Principal Agent, violating Rule 302.b. Enforcement Action: Corrective Action Description: By the corrective action due date, Operator shall submit an accurate and up-to-date Form 1A Designation of Agent to COGCC. The Form 1A shall name a Principal Agent designated to accept and be served notices from COGCC, and list employees approved to submit documents to COGCC on behalf of the Operator. Operator shall include all pertinent information including name, valid email address, mailing address, and direct phone number. The Form 1A shall be signed, dated, and approved by an officer or principal of the company. COGCC Forms are available at http://cogcc.state.co.us/reg.html#/forms Final Resolution Comment:

Document No.: 401957019 Rule: 1004.a Rule Description: Final Reclamation - Well Sites Reclamation Alleged Violation Description: Pursuant to Rule 1004.a., upon the plugging and abandonment of a well, Sand Hills Society (“Operator”) shall 1) backfill all pits, mouse and rat holes, and cellars; 2) remove all debris and surface equipment within three months; 3) reclaim well locations, access roads, culverts, and associated facilities; 4) as applicable, perform compaction alleviation, restoration, and revegetation work at well sites, associated production facilities, and access roads to the same standards established for interim reclamation under Rule 1003; and 5) remove all other equipment, supplies, weeds, rubbish, and other waste material. All such reclamation work shall be completed within three months on crop land and twelve months on non-crop land after plugging a well or final closure of associated production facilities, and Operator shall make every reasonable effort to complete reclamation before the next local growing season. On April 18, 2009, Operator plugged and abandoned the Hickert #1-33 (API No. 05-121-09669; at Location ID 317201, “Location”), (Form 6-Subsequent Document No. 1769460). The Location is on non-cropland, thus, pursuant to Rule 1004.a., Operator was required to complete final reclamation work no later than April 18, 2010. On January 28, 2015, COGCC Staff conducted an inspection of the Location and observed that Operator failed to reclaim the Location and Pit in accordance with Rule 1004.a. final reclamation requirements: the locations, facilities, and/or roads had not been recontoured; the Location had not been revegetated to 80% of reference area levels; plastic, wood, and trash debris including several wooden posts had been left around the Location; and the Location was not stabilized and was susceptible to erosion. COGCC Staff required Operator to perform the following corrective actions: remove wooden posts and any debris that remains, decompact soils and recountour areas where needed, reseed and reclaim the Location, and stabilize the site to prevent erosion until vegetation establishes, by May 5, 2015. COGCC Staff also required Operator to establish vegetation with total perennial non-invasive plant cover of at least 80% of reference area levels. (Field Inspection Report No. 673502081, “January 2015 FIR”). COGCC Staff conducted follow up inspections on February 13, 2017, and February 8, 2018, and observed that no reclamation work appeared to have been conducted. COGCC Staff repeated the corrective action requirements from the January 2015 FIR, to be completed by May 31, 2017. (Field Inspection Report Nos. 682501656 for February 13, 2017, and 682503120 for February 8, 2018). Operator failed to perform final reclamation at the Location, violating Rule 1004.a. Enforcement Action: Corrective Action Description: Operator shall perform reclamation in accordance with COGCC 1000-Series Rules at the Location. By the corrective action due date, Operator shall submit an eForm 4 Sundry Notice which: 1) Proposes a revegetation plan to accomplish the following before the next local growing season: a) Establish vegetation with total perennial, non-invasive uniform plant cover of at least eighty (80) percent of pre-disturbance or reference area levels, b) Use a seed mixture requested by the surface owner, or a mixture prescribed by the local county NRCS, and c) Implement erosion controls to stabilize the seeded soil, and continue to monitor and manage the Location until it has passed final reclamation; and 2) Details Operator’s plan (with specific tasks and schedules) to complete final reclamation at the Location, and proposes a reasonable timeline to complete such work. Final Resolution Comment:

Document No.: 401665886 Rule: 907.e Rule Description: Oily Waste Alleged Violation Description: Pursuant to Rule 907.e.(1), HRM Resources II LLC (“Operator”) shall treat or dispose of oily waste from the oil and gas operations at the Marick #1-A facility (ID 317081, “Location”) that is not removed to a commercial solid waste disposal facility or a permitted centralized E&P waste management facility, by land treatment onsite. Pursuant to Rule 907.e.(2)G., when land treatment occurs in an area not being utilized for oil and gas operations, Operator shall obtain prior written surface owner approval. Pursuant to conditions of approval (“COA”) on the Site Investigation and Remediation Workplan (“Form 27”) for skim pit closure and land treatment of oily waste at the Location, “land treatment of oily waste shall be performed in strict accordance with the requirements of COGCC Rule 907.e.(2)” (Form 27 Document No. 2086926, COGCC approved with COA on April 26, 2015, for Remediation Project No. 9015). On March 30, 2018, the surface owner filed a complaint with COGCC (Document No. 200445680, “Complaint”) alleging property damage due, in part, to Operator’s land treatment of oily waste. According to the Complaint, the surface owner did not provide Operator with prior authorization to perform land treatment of oily waste on his crop land adjacent to the Location. The Complaint further states Operator’s land treatment caused approximately $3000 of crop damage as of early June 2015, and that the surface owner received a check from Operator for $3000 on June 12, 2015. According to the Complaint, the surface owner understood this check to be compensation for the crop damage that had occurred, and did not give Operator authorization to continue to use his crop land for the three year planned duration of the remediation project. COGCC Staff performed an inspection on April 23, 2018, to investigate the complaint and survey using GPS the areas where oily waste was being treated (Field Inspection Report No. 688000148 and aerial image showing land treatment areas in Document No. 2087412). During investigation of the complaint, COGCC Staff determined that Operator was treating oily waste by land treatment off the disturbed areas of the location on areas of crop land. As part of the investigation, COGCC requested Operator to provide a copy of prior written surface owner authorization. Operator provided a response to COGCC (Document No. 2496354) verifying that, while a one-time payment was made to the surface owner for crop loss, no written surface owner authorization was ever obtained for land treatment of oily waste. Operator failed to obtain written surface owner approval prior to using surface owner’s land for treatment of oily waste, violating Rule 907.e. and violating Operators Form 27 COA and § 34-60-121.(1)(a), C.R.S. Enforcement Action: Corrective Action Description: Operator shall remove all oily waste being land treated under COGCC Remediation Project No. 9015 from the site and properly disposed at a commercial solid waste disposal facility in accordance with Rule 907.e. no later than May 31, 2018. By July 31, 2018, Operator shall submit to COGCC all of the following: - All waste generator documentation required by Rule 907.b.(2) to document disposal of the oily waste; via supplemental Form 27. By July 31, 2018, - Sampling and analysis of native soil underlying the current land treatment areas to demonstrate that remaining soil complies with all contaminants of concern in Table 910-1. Samples shall be collected in a grid pattern following the same number and location of samples collected during land treatment. - A sample location diagram, summary table of results compared to Table 910-1 standards, and copy of all laboratory reports; via supplemental Form 27. If remaining soil complies with Table 910-1 standards, Operator shall perform reclamation of the offsite disturbed areas suitable to bring those areas back to productive crop land. If underlying soils do not comply with Table 910-1 standards, Operator will be required to perform additional remediation to remove any residual impacts. Operator shall consult with surface owner in writing on waste removal schedule, sampling and analysis results and reclamation plans. Final reclamation of disturbed areas shall be completed no later than August 31, 2018. Final Resolution Comment:

Document No.: 401781555 Rule: 326.b Rule Description: Shut-in Wells Alleged Violation Description: Pursuant to Rule 326.b., CORAL PRODUCTION CORP ("Operator") is required to perform a Mechanical Integrity Test ("MIT") on Shut-in ("SI") wells within two (2) years of the initial shut-in date and then at five (5) year intervals after an initial successful MIT. COGCC Rules do not permit placing a well back on production to fulfill, or in lieu of, the requirements to conduct an MIT. COGCC Staff had reason to believe Operator had committed one or more violations of COGCC Rules, and issued Warning Letter No. 401588905 to Operator on March 28, 2018 , requiring Operator to conduct MIT or plug and abandon delinquent wells by June 30, 2018 . On July 24, 2018 , COGCC Staff conducted an audit (“Audit”) of Operator's records for the well(s) in the attached table ("Well"). 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 SI, and the COGCC database to determine whether Operator reported MIT(s) for the Well. Through this Audit, COGCC Staff determined that at least one Well in the attached table was overdue for performance of an MIT on a SI well. Operator failed to conduct timely MIT(s) for at least one SI Well, violating Rule 326.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 July 24, 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. Final Resolution Comment:

Air Quality (PM2.5 ug/m3)

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