:r'1A V'l1 ' If.~yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings... · 3. Ms. Victoria Schmitt,...

59
UNITED STATES ENV IRONMENTAL PROTECTION AGENCY REGION 8 2012 JUL -3 PH 12: SO IN THE MA TIER OF: ) ) ) ) ) ;:: iL ':'lj :r'1A V' l1 Docket No. SDWA-08-20 ",4 Maralex Disposal, LLC Respondent. COMPLAINANT'S SUPPLEMENTAL PREHEARING EXCHANGE Complainant, the United States Environmental Protection Agency, Region 8 (EPA), files thi s COMPLAINANT'S SUPPLEMENTAL PREHEARING EXCHANGE pursuant to 40 C.F.R. § 22.19(a) and ORDER GRANTING EXTENSION OF TIME TO COMPLAINANT'S SUPPLEMENTAL PREHEARING EXCHANGE of the Presiding Officer issued June 28, 2012. ADDITIONAL POTENTIAL WITNESSES The following are potential witnesses whom the Complainant may call to testify in add iti on to those witnesses previously li sted in the Complainant 's Prehearing Exchange : 3. Ms. Victoria Schmitt, Planning Enginee r La Plata County 1060 E. 2" Avenue Durango, CO 81301 Ms. Schmitt is employed as the La Plata County Planning Engineer. As part of her duties, s he regularl y oversees oil and gas pennitting and act ivities on behalf of La Plata County. Ms. Schmitt is tasked in her professional position wit h balancing on behalf of La Plata County the pros and cons of local oil and gas development and can speak to the extent the County relie s on local oil and gas companies to avoid long-term damage to public health, the environment and property. Ms. Schmitt interacts regularl y with local oi l and gas owners and operators, including

Transcript of :r'1A V'l1 ' If.~yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings... · 3. Ms. Victoria Schmitt,...

Page 1: :r'1A V'l1 ' If.~yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings... · 3. Ms. Victoria Schmitt, Planning Engineer La Plata County 1060 E. 2" Avenue Durango, CO 81301 Ms. Schmitt is employed

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 8 2012 JUL -3 PH 12: SO

IN THE MA TIER OF: ) ) ) ) )

;:: iL ':'lj

:r'1A ;1 EGIOi~ V' l1 Docket No. SDWA-08-20 11-,9l!7.9,~.Hf~· ",4 ' If.~

Maralex Disposal, LLC

Respondent.

COMPLAINANT'S SUPPLEMENTAL PREHEARING EXCHANGE

Complainant, the United States Environmental Protection Agency, Region 8 (EPA), files this

COMPLAINANT'S SUPPLEMENTAL PREHEARING EXCHANGE pursuant to 40 C.F.R.

§ 22.19(a) and ORDER GRANTING EXTENSION OF TIME TO COMPLAINANT'S

SUPPLEMENTAL PREHEARING EXCHANGE of the Presiding Officer issued June 28, 2012.

ADDITIONAL POTENTIAL WITNESSES

The following are potential witnesses whom the Complainant may call to testify in

addition to those witnesses previously listed in the Complainant's Prehearing Exchange:

3. Ms. Victoria Schmitt, Planning Engineer La Plata County 1060 E. 2" Avenue Durango, CO 81301

Ms. Schmitt is employed as the La Plata County Planning Engineer. As part of her

duties, she regularly oversees oil and gas pennitting and activities on behalf of La Plata County.

Ms. Schmitt is tasked in her professional position with balancing on behalf of La Plata County

the pros and cons of local oil and gas development and can speak to the extent the County relies

on local oil and gas companies to avoid long-term damage to public health, the environment and

property. Ms. Schmitt interacts regularly with local oi l and gas owners and operators, including

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the Respondent, and has personal knowledge ofthe Ferguson #1 well. Ms. Schmitt will testify

as a fact witness if called regarding concerns La Plata County has regarding (I) impacts to the

subsurface caused by oil and gas activities; (2) the subsurface impact of not maintaining

mechanical integrity; (3) the type(s) of water being injected into a well; and (4) whether or not

the County is sufficiently protected from negative impacts caused by oil and gas activities.

4. Ms. Karen Spray. Acting Environmental Manager Colorado Oil and Gas Conservation Commission Durango, CO

Ms. Spray currently is the Acting Environmental Manager for the Colorado Oil and Gas

Conservation Commission (COGCC), Durango Office. Ms. Spray has knowledge concerning

the Rules and Regulations and Rules of Practice and Procedure delegated to the COGCC and

what they serve to protect/promote. Ms. Spray has knowledge of the Respondent's oil and gas

activities in the State of Colorado and compliance with COGee rules and regulations. Ms. Spray

may be called as a fact witness to testify regarding (I) the Respondent's oil and gas compliance

history with the COGCC, including but not limited to mechanical integrity, and (2) her dealings

with the Respondent and Respondent's representatives concerning COGCC compliance-related

matters. Ms. Spray may establish through testimony the basis for admitting into evidence

Complainant's Exhibit 20.

ADDITIONAL EXIDBITS

Complainant plans to offer into evidence as an additional exhibit an enumeration of the

COGCC's outstanding notices of alleged violations (NOAV), complaint reports, mechanical

integrity test reports and spill reports from the Colorado Oil and Gas Incident Search (COOlS)

database against the Respondent and related company Maralex Resources, Inc. that share the

In the Maner of Maralex Disposal, LLC Complainant's Supplemental Prehearing Exchange - Page 2

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same officers, operator contacts, physical and mailing address and/or employees. An official

record certified and authenticated by the COGCC Commission Secretary will be filed with the

court by motion and a copy provided to the Respondent upon receipt by the Complainant on or

about July 13,2012 as Complainant's Exhibit 19. A current unofficial copy of the COOlS

Database found at http::iicogcc.state.co.uslcogisprintedbetweenJune29and July 3, 2012,

listing incidents involving the Respondent and Maralex Resources, Inc ., is attached in the

interim. In addition, Complainant plans to offer into evidence the following exhibits:

I. Complainant's Exhibit 20. Colorado Oil and Gas Incident Search - Field Inspection

Report for the Dara Ferguson Injection # 1 Well, API Number 05-067-09194, dated

January 3, 2008.

2. Complainant's Exhibit 21. Colorado Secretary of State Corporations Section, Articles of

Organization for Maralex Disposal, LLC, Date Stamped June 26, 1995.

3. Complainant'S Exhibit 22. Colorado Secretary of State Corporations Office, Articles of

Incorporation, Maralex Enterprises, Inc. , Date Stamped December 1, 1989.

4. Complainant's Exhibit 23. Colorado Secretary of State Corporations Office, Articles of

Amendment to the Articles of Incorporation, Change of Name From Maralex Enterprises.

[nc., to Maralex Resources, [nc. , Date Stamped January 10, 1990.

RESERV A nONS

Complainant reserves the right to move for additional discovery pursuant to 40 C.F.R.

§ 22.l9(e) and supplement its prehearing exchange thereafter if warranted to include evidence

deemed relative and probative by the presiding officer. Complainant also reserves the right to

add witnesses to rebut Respondent's case, to call as a hostile witness any witness endorsed or

[n the Matter of Maralex Disposal, LLC Complainant's Supplemental Prehearing Exchange - Page 3

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noticed by Respondent, to subpoena any witnesses who is an employee, agent or contractor of

the Respondent or is endorsed or noticed by Respondent and to cross-examine any witnesses

examined by Respondent at any time.

Date: 7_3·,012-

In the Matter of Maralex Disposal, LLC

Respectfully submitted,

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8

By: wans ,Senior Enforcement Attorney

Legal Enforcement Program EPA Region 8 1595 Wynkoop Street (8ENF-L) Denver, Colorado, 80202-1129 Telephone No: (303) 312-6906

Complainant's Supplemental Prehearing Exchange - Page 4

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CERTIFICATE OF SERVICE

The undersigned hereby certifies that on July 3, 2012, the original and one true copy of the COMPLAINANT'S SUPPLEMENTAL PREHEARlNG EXCHANGE were hand-carried to the Regional Hearing Clerk. EPA Region 8. 1595 Wynkoop Street. Denver. Colorado. and that a true copy of the same was sent as follows:

Via hand-delivery to:

The Honorable Elyana R. Sutin Regional Judicial Officer U.S. EPA Region 8 (8RC) 1595 Wynkoop Street Denver. CO 80202-1129

Via electronic and certified mail to:

Mr. William E. Zimsky. Esq. Abadie Schill 1099 Main Street. Suite 315 Durango. CO 81301 [email protected]

Date: 1/"31 '-0 1 ___

In the Matter of Maralex Disposal. LLC Complainant's Supplemental Prehearing Exchange - Page 5

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COOlS - Incident Data Inquiry

COGIS - Inspection/Incident Inquiry

I i

hnp:J/cogcc.state.co.us/cogisllncidentSearch2.asp

Page I of I

Complainant's Exhibit 19

, I , I , I

, I

, I , I , I , I , I , I

7/312012

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COOlS· NOA V Reports Page I of I

COGlS • NOAV Report O'perator Information ~ Related ~ Docs by API _ ~ Single Doc ~ Docs under NO,AY

DocNum: 200344 176 Date Rec'd: 312312012 Operator: MARAlEX RESOURCES, INC Oper,INo. 53255 Address: POBOX 338 ATTN: JIM GRAVES IGNACIO, CO 81137 Company Rep. JIM GRAVES OPERATION MANAGER Well Name/No. SULFUR GULCH 9-98-2 1 location SWSW 2 T9S R98W 6 Fac.lD: 222 107

API number: 05-077 -08709 COGCC Rep: CHUCK BROWNING

Alleged Violation: Date of Alleged Violation: 3120/2012

I Fac.Type: , CounW

I Phone:

WEll

MESA (970 ) 4334139

Approx. time of violation: this wen has been shut-In since 2009 without having passed a mechanical Integrity test (MIT). An application for shut-in or temporary abandonment il months was not filed. Improper signs. Junk and unused equlpmerl\ scattered around location. Weeds. Insufflclant berms around tank. No Interim reClain No stOOTlwaler management BMP'sln place.

Act, Order, Regulation, Permit Conditions Cited: 319.b.(I), 319.b.(3), 326.b.(I), 210.b.(1), 210.b.(2), 603.j, 1003.1., 604.a.(-4), 1003.1,

Abatement or Corrective Action Required to be Performed by Operator The operator Is requirecl.o either. 1.) produce the well, 2.) perform a mechaniealln.egrtty les. on the well (the weD musl pass the lesQ, or 3.) property I abandon the well. Forms used to submil information and operational requests shall be the most recent versions available 00 the Colorado Oil and Gas Commission website: www.coIorado.gov/cogec. Install proper signs per rule 210. Clear Junk.debrls, weeds per rule S03.j. & loo3.f. JnstaD and maintain rule 6O-4.a.(-4). Intiate and Implement Interim reclamation pre rule loo3.lmpJiment and maintain stormwater manag~menl BMP's per rule 1002.1.

Abatement or Corrective Action Required to be Completed by: 6/30/2012

This section to be completed by Operator when alleged violation is corrected

Company Rep: Title:

Signature? Date: 3123120122:24:46 PM

Company Comments:

COGCC Signature?

Resolution approved by:

Final Resolution Date Case Closed?

No Final data found.

Friday, June 29, 2012

Title:

Letter Sent? COGCC person

hnp:llcogcc.state.co.us/cogisINOA VReport.asp?doc_oum=200344 176

Date: N/A

6129/2012

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COOlS - NOA V Reports Page 1 of 1

COG IS - NOAV Report

O.eerator Information ~ Related Cb. Docs by API _ ~ Single Doc LQ. Docs under NOAY I .

OocNum: 200344201 Date Rec'd: 3/2312012 Operator: MARALEX RESOURCES, INC oper."lNo. 53255 Address: POBOX 338 AnN: JIM GRAVES IG~ACIO , CO 81137 Company Rep. JIM GRAVES OPERATIONS MANAGER Well Name/No.

Location

Fac.lD:

SULFUR GULCH 9-98-10 #1 NENE 10 T9S R98W 6 222080

API number: 05-077 -08682

COGCC Rep: CHUCK BROWNING

Alleged Violation : Date of Alleged Violation: 312012012

Fac.Type: County Phone:

WELL MESA

(970) 433-4139

Approx. time of violation: ThIs 'Nell has been shut-in since 2009 without having passed a mechanical Integrity test (MIT). An application for shut-In or temporal)' abandonment h months was not filed . Improper slgnsWeeds. Insufficiant berms around tank, No Interim reclalmation started. No stormwater management BMP', In pIE

Act, Order, Regulation. Permit Conditions Cited: Jt9.b .(1), 3tS.b.(3), 32a.b.(t ), 210.b.(I), 210.b.(2). &03.j, 1003.1 .. 604 .• . (4),1003 .• .

Abatement or Corrective Action Required to be Performed by Operator The operator Is required to either: 1.) produce the well, 2.) perform 8 mechanICal Integrity test on the well (the well must pass the test). or 3.) property I abandon the well. Forms used to submit Information and operational requests shall be the most recent veBlons available on the Colorado 011 and Gas Commission website: www.COIorado.gov/oogcc. Install proper signs per rule 210. Clear junk,debris, weeds per rule 603.j. & 1003.f. Install and maintain rule 60<4.a.(4). Intiate and Implemenllnterlm reclamation pre rule 1003. Impliment end maintain slormwater management BMP's per rule loo2.f.

Abatement or Corrective Action Required to be Completed by: 6130/2012

This section to be completed by Operator when alleged violation is corrected

Company Rep: Title:

Signature? Date: 3123120123:06:24 PM

Company Comments:

COGCC Signature?

Resolution approved by:

Final Resolution Date Case Closed?

No Final data found.

Friday, June 29,2012

Title:

Letter Sent? COGCC person

hnp:/Icogcc.state.co. usicogisINOA VReport.asp?doc _ nurn~20034420 I

Date: N/A

612912012

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COGIS - NOA V Reports Page I of I

COG IS - NOAV Report

O~~:;:nl:!c:::tion ~ Related ~ Docs by API ~ Single Doc DocNum: 200344210 Date ~ec'd: 3123/2012 Operator: MARALEX RESOURCES, INC Oper'INo. 53255 Address: POBOX 338 ATTN: JIM GRAVES IGNACIO, CO 81137 Company Rep. JIM GRAVES OPERATIONS MANAGER Well NamelNo. WAGON TRAI L 1-3 Location SWSE 3 T9S R98W 6 Fac.lD: 222070 API number: 05-077 -08672 COGCC Rep: CHUCK BROWNING

Alleged Violation :

Date of Alleged Violation: 3/20/2012

I . Fac.Type:

,

~~~~r I

WELL MESA (970 ) 433-4139

Approx. time of violation: This Well has been shut-in since 2009 without having passed a mechanicallnlegrity test (MIT). An application for shut-in or temporary abandonment II

months was not filed. Improper signs. Unused equipment. weeds. No IflIe rim reclaimation started.

Act, Order, Regulation, Pe rmit Conditions Cited: 319.b.(I), 319.b.(3), 326.b.(I), 21 C.b.{I), 210.b.(2), 603.j. 1003.1.

Abatement or Corrective Action Required to be Performed by Operator The operator is required to either: 1.) produce the well . 2.) perform a mechanical lntegr\ty tesl on the well (the welt must pass the tesl). or 3.) property I abandon the well. Forms used to submit Information and operational requests shall be the most recent versions available on the Colorado 011 and Gas Commission website: www.colorado.gov/cogcc. lnstaliproperslgnsperNle210. Clear Junk.debris. weeds per Nle S03.j . & 1003.1.

Abatement or Corrective Action Required to be Completed IbY: 6/30/2012

This section to be completed by Operator when alleged violation is corrected

Company Rep: Title :

Signature? Date: 3123/20123 :31 :49 PM

Company Comments:

COGCC Signature?

Resolution approved by :

Final Resolution Date Case Closed?

No Final data found.

Friday, June 29,2012

Title:

Letter Sent? COGCC person

http://cogcc.state.co.uslcogis/NOA VRepon.asp?doc _ num=200344 210

Date: N/A

612912012

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COOlS - NOA V Reports Page 1 of 1

COGIS - NOAV Report

Operator Information ~ Related ~ Qocs by.be! _ ~ Single Doc ~ Docs under NOAY

DocNum: 20034421 1 Date Rec'd: 3123/2012 Operator: MARALEX RESOURCES, INC Oper. No. 53255 Address: POBOX 338 AnN: JIM GRAVES IGNACIO . CO 81 137 Company Rep. JIM GRAVES OPERATIONS MANAGER Well NamelNo.

location Fac.10:

SULFUR GULCH 9-98-10 2 NWNW 10 T9S R98W 6 222089

API number: 05-077 -08691 COGCC Rep: CHUCK BROWNING

Alleged Violation :

Fac.Type: County Phone:

WELL MESA (970 ) 433-4139

Date of Alleged Violation: 3/20/2012 Approx. time of violation: This well has been shut-In since 2003 without having passed a mechanlcallntegriJ test (MIT). An application for shut-in or temporary abandonment 11 months was not filed. Improper &!gns, Junk and unused equipment scattered around Iocatlon.Weeds. Insulfidanl berms around lank. No Interim reclaln

Act, Order, Regulation, Permit Conditions Cited: 319.b.{I). 319.b.(3), 326.b.(I), 2tO.b.(t), 2tO.b.(2), S03.i, 1003.(., 6~.a . (4), l003.a.

Abatement or Corrective Action Required to be Performed by Operator The operator Is required to either: 1.) produce the we", 2.) perform a mechanical Integrity lest on the well (the well must pass the test), or 3.) properly I abandon the well. Forms used to submit information ana operational requests shall be the mosl recent versions available on the Coloraao Oil ana Gas Commission website: www.coIorado.govlcogcc. Install proper signs per rule 210. Clear Junk,debris, weeds per rule 603.;. & 1003.1. Install and maintain rule 604.a.(-4). lntlate ana Implement Interim reclamation pre rule 1003.

Abatement or Corrective Action Required to be Completed by: 613012012

This section to be completed by Operator when al/eged violation is comlcted

Company Rep: Title :

Signature? Date: 3123/20124:04:33 PM

Company Commenis :

COGCC Signature?

Resolution approved by:

Final Resolution

Date Case Closed? No Final data found.

Friday, June 29, 2012

Title:

Letter Sent? COGCC person

http://cogcc.state.co. us/cogislNOA VReport.asp?doc _ num~20034421 1

Date: N/A

612912012

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COGlS - NOA V Reports Page 1 of 1

COGIS - NOAV Report Operator Information

= Gl-+<I.&~ ca Docs byAf.!. ~ .sing~ [} ~s under

DocNum: 20031 41 27 Operator: MARALEX RESOURCES, INC f'ddress: PO BOX 338IGNACIO , C0 811 37 Company Rep. DORI S NEY Well Name/No. BEAR GULCH 26-2

location SENE 26 TSS R1 01W 6

Fac.lD: 210530 API number: 05-045 -()6286 COGCe Rep: BOB KOEHLER

Alleged Violation: Date of Alleged Violation : 612912011

I Date Rec'd: 61291201 1

I oper'io.

Fae.Type: County

Phone:

53255

WELL GARFIELD (303) 894-2100 X5147

Approx. time of violation: . I M.rete~ Re$OUl'OI)$ Inc. 011 5121/2010 promiMd 10 bring Into compliance 20 wen. from allsl 0182 wells sent by cooce on 4/112010. The well$ were 01,1\ of compllanoe ~ .. 1118Y I\a(j no! prod\lQllcl 011 or g" 10 ... 1'1 In two or more Y"11I and had .~h&r n'VtI" ,*IMd • MIT or had not pal Md on. w~hifl 5 yean of an I'I ~~ MIT. The requlrem.nllor re.aUlion wa'lO . ther, prOlluce the Individual wenl , plug . nd abll'ldon them, Or get them 10 pall 11'1 MIT. A. of 8.1112011 only 4 well. of the orlg..,,11I1l of 82 (3 from the 611 d 20) have been brought Into eompllance. Maralex I. In violation 01 Rule 208 lor not following through on I pLan 'ppI'aved by COGCC to eliminate unuM'd wel ls or relurn well. 10 produd ion . M .... I •• I. lllto In violation 01 Rul • • 318.1I.(1}. 318 .b .(3), at"KI 326.b .( I) lor no! pel'lorml"9 a'! MIT, ~Ing lind ~nlng, or ~turrmg to pll)dudion well' that ha". not produc.d .., 2 or mort yterl. (Blar Gulch 2&-2 (045-08288) IfIItdtd at rar.ctom trom weill In violation d COGCC NItI.)

Act, Order, Regulation, Penn it Conditions Cited: RULES 208. 319. b.( I ). 319. b.(3). 32t1. b.( I )

Abatement or Corrective Action Required to be Perfonned by Operator By July IS, 2011 provide a'! txplenel lon ofwhy the 20 wells propoMCI by M .... 1elc .., MIY 2010 Wefe not br<lUghC Into eompl'-nol .. promlMd . AlIO by July 15. lO l l

PfOPOM' pi," for brtl~ the remai ning 11 prwni"d well' up 10 dIIll Ind Into eomplllnce wMl Ruiet 3 19 Ind 32t1. By July 15. 201 I propose I pia'! lor the comI"9 ye ... the! wli bmll30 wells dthe remaining 82 1rom lhe original ~lIlnto eompl __ w~h Ruiet 319 1Wld ~26. By August 15, 20 1 lli1e Sundry Notices reqUMtlng COIl~nued temporer~y IllIIndoned w.1I fUllUI Whl~ I pproprlate. An d,lIle. Sundry NOlie» ~pQfIing AI Built GPS coordln" .. IS needed (tee lI:$l provided by cooce). Abatement or Corrective Action Required to be Completed by: 7/15/2011

This section to be completed by Operator when alleged violation Is corrected

Company Rep:

Signature?

Company Comments:

COGCC Signature? Y

Resolution approved by:

Final Resolution Date Case Closed?

No Final dnta found.

Friday, June 29, 201 2

Letter Sent?

Title:

Date: 2111201 21 :36:36 PM

Date: 6/271201111 :00:00 AM

TItle:

COGCC person

http://cogcc.state.co.us/cogisINOAVReport.asp?doc _ num=20031 41 27 6129120 12

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COOlS - NOA V Reports

COG IS - NOAV Report

O.eerator Information ~ Docs under NOAY

DocNum: 200317017 Date Rec'd:

Operator: MARALEX RESOURCES, INC Oper. No. Address: P O BOX 338 IGNACIO , CO 81 137 Company Rep. JIM GRAVES Well Name/No. RIFLE-BOULTON 1

Location NWNW 23 T7S R91 W 6 Fac.ID: 210371 Fac.Type: API number: 05-045 -061 27 County

8/3/2011

53255

WELL GARFIELD

Page I of I

COGCC Rep: DAVID ANDREWS Phone: (970 ) 625-2497 EXT 1

Alleged Violation:

Date of Alleged Violation: 6/23/201 1 Approx. time of violation: Bradenhead gas has been vented with no written approval to venl in COGCC's well file. Hlllh pressure gradient at surface casing shoe (setting depth (

have broken down the cement at the shoe or the underlying formation, potentially resulting In a release of gas or other produced ftuids, which could m~ groundwater or nearby surface water. II appears that the open braden head access may discharge water with an oily emulsion Intermittently Into a meta nuid has overtopped the trough.

Act, Order, Regulation, Permit Conditions Cited: Rule 317.d., Rule 324A.a., Rule 906, and Rule 912.b.

Abatement or Corrective Action Required to be Performed by Operator Submil Form " (Sundry Notice, Notice of Inlenl, Requesllo Venl Of Flare) within 30 days. Identify the approximate now I<Ite of the gas and water, and

water discharge. Attach laboratcwy analyses 01 the vented gas (composition, Including H2S), and water (dissolved methane, major cations, major anion Submil Form 27 (Site Investigation and Remediation INcN1tplan) within 30 days, describing the opel<llor's proposed investigation workplan 10 evaluale ~ 10 soil , groundwater, aoo surface water from both the overtopped bradenhead waler collection \Tough and posSible breakdown 01 the surface caSirlg sh WOtXpIan Iha~ also address dispoliliOn of e&p waste from the water collection !1ough and all requirements contained In the attached environmental ab requirements ENV·I through ENV·7.

Abatement or Corrective Action Required to be Completed by: 9/3/2011

This section to be completed by Operator when alleged violation is corrected

Company Rep: Title:

Signature?

Company Comments:

COGCC Signature? Y

Resolution approved by:

Fina I Resolution

Date Case Closed? No Final dala found.

Friday, June 29, 2012

Letter Sent?

Date: 1211 2/201 11 :22:29 PM

Date: 8/1/20 11 4:00:00 PM

Title:

COGCC person

hI1p:l/cogcc,slale,co,us/cogisINOAVReport.asp?doc_num=200317017 612912012

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COGIS - NOA V Reports

COGIS - NOAV Report • I

o~e~:~:nl~!~;,::tion r Related

DocNum: 200317021 Date r,eC'd: Operator: MARALEX RESOURCES. INC Oper. No. Address: POBOX338 IGNACIO.C081137 I Company Rep. JIM GRAVES Wen Name/No. RIFLE WALTON 25-2 Location SENW 25 T7S R91W 6 Fac.lD: 210534 Fac.Type: API number: 05-045 -06290 County

8/3/2011

53255

WELL GARFIELD

Page 1 of 1

COGCC Rep: DAVID ANDREWS Phone: (970 ) 625-2497 EXT 1

Alleged Violation :

Date of Alleged Violation: 6/23/2011 Approx. time of violation: High bradenhead pressure gradient at surface casing shoe (setting depth of 309') may have broken down the cement at the shoe or the undertying for potentially resulting in a release of gas or other produced nuids, which could migrate to shallow groundwater or nearby surface water. Venting off press feasible considering thaI the braden head access will produce wa ter quickly after opening the valve.

Act, Order, Regulation, Permit Conditions Cited: Rule 317.d. and Rule 324A.B.

Abatement or Corrective Action Required to be Performed by Operator Submit Form 4 (Sundry Notice, Notice of Intent) with operator's proposed production casing cement remediation procedures. which shall be designed

gas flows at their source(s), 2) eliminate waler flows at their source(s), and 3) provide cement coverage across the surface casing shoe. Collect a gas: possible) and a water sample from the bradenhead discharge. Analyze samples of the vented gas (composition, including H2S), and water (disSOlved I cations, major anions, and BTEX). Submit Form 27 (Site Investigation and Remediation VVOrkplan) within 30 days. Attach the bradenhead sample anat describe the operator's proposed investigation workplan to evaluate potential impacts to groundwater and surface water from possible breakdown of th shoe. The wor1qllan shall address all Items Identified In the attached environmental abatement requirements ENV·j through ENV·7.

Abatement or Corrective Action Required to be Completed by: 9/3/2011

This section to be completed by Operator when al/eged violation is corrected

Company Rep:

Signature?

Company Comments:

COGCC Signature? Y Resolution approved by:

Final Resolution Date Case Closed?

No Final data found.

Friday, June 29, 2012

Letter Sent?

Title:

Date: 12/12/20111:22:51 PM

Date: 8/1/2011 4:00:00 PM Title :

COGCC person

http://cogcc.state.co.uslcogisINOA VReport.asp?doc_num=20031702 1 612912012

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COGIS - NOAV Reports Page I of I

COGIS - NOAV Report

0a::~:nl~:~::tion .<gtRelaled [b. Docs by API [9. Single Doc DocNum: 200317022 Date Rec'd: 81312011

Operator: MARALEX RESOURCES, INC Oper, No. 53255 Address: POBOX 338 IGNACIO. CO 81137 Company R~p. JIM GRAVES Well Name/No.

Location Fac.lD: API number:

FEDERAL 26-3 •

NWSW 26 TIS R91W 6 210457 05-045 -06213

Fac.Type: WELL GARFIELD

COGCC Rep: DAVID ANDREWS County Phone: (970 ) 625-2497 EXT 1

Alleged Violation:

. Date of Alleged Violation: 6/23/2011 Approx. time of violation: High braden head pressure gradients! surface casing shoe (setting depth of 450') may have broken down the cement at the shoe or the undertying for potentially resulting in 8 release of gas or other produced fluids, which could migrate 10 shallow groundwater or nearby surface water. Venting off preu feasible considering that the bradenhead access will produce water quIckly after opening the valve.

Act , Order, Regulation, Permit Conditions Cited: Rule 317.d. and Rule 324A.8.

Abatement or Corrective Action Required to be Performed by Operator Submit Form" (Sundry Notice, Notice of Inlent) with operator's proposed production casing cemenl remedlaUon procedures, which shall be designed

gas flows at their source(s), 2) eliminate water !lows at their source(s), and 3) provide cement coverage across the surface casing shoe. Collect a gas i

possible) and a water sample from the braden head discharge. Analyze samples of tpe vented gas (composition, Including H2S), and water (dissolved r callons, major anions. and BTEX). Submit Form 27 (Site Investigation and Remediation Workplan) within 30 days. Attach the bradenhead sample anat describe the operator's proposed InvesUgaUon wor1t.plan to evaluate potentJallmpacts 10 groundwater and surface water from possible breaKdown of th shoe. The wor1qllan ,haliaddr8'1 ell Items identified In the attached envlronmentalebatement requirements ENV-t through ENV-1.

Abatement or Corrective Action Required to be Completed by: 9/3/2011

This section to be completed by Operator when alleged violation is corrected

Company Rep: Title:

Signature?

Company Comments :

COGCC Signature? Y Resolution approved by:

Final Resolution Date Case Closed?

No Final data found.

Friday, June 29, 2012

Letter Sent?

Date: 1211212011 1 :23:09 PM

Oat.: 81112011 4:00:00 PM

Title:

COGCC person

hnp:/Icogcc.state.co.usicogisINOA VReport.asp?doc_num=2003 1 7022 612912012

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COGlS - NOA V Reports Page I of I

COGIS - NOAV Report I O.eerator Information ~ Related . llA ~ under NQA V I

I}. Docs by API _ ~ Single Doc

DocNum: 200293704 Date ~ec'd: Operator: MARALEX RESOURCES, INC Oper. No. Address: POBOX 338 IGNACIO , CO 81137 Company Rep. JIM GRAVES Well Name/No. RI FLE-BOULTON 1 Location NWNW 23 TIS R91W 6 Fac.lD: 210371 Fac.Type: API number: 05-045 -06127 County

1/14/2011 53255

WELL GARFIELD

COGCC Rep: DAVID ANDREWS Phone: (970 ) 625-2497 EXT 1

Alleged Violation :

Date of Alleged Violation: 1111/2010 Approx. time of violation: MARAlEX RESOURCES, INC rOPERATQR") DID NOT PERFORM THE FOLLOV¥lNG DURING THE PERIOD FROM 11/112009 THROUGH 10f3n

Vv'ELL FOR PRESSURE AND FLOW AND 2) SUBMIT ANNUAL BRADENHEAD PR1ESSURE AND FLOW MEASUREMENT RESULTS.

Act, Order, Regulation, Permit Conditions Cited: cOGce ORDER NO. '·107

Abatement or Corrective Action Required to be Performed by Operator PERFORM BRADENHEAD PRESSURE AND FLOW TEST AND REPORT RESULTS TO COGCC NO LATER THAN 613012010, TESTING AND REF REQUIREMENTS ARE SUMMARIZED IN THE JULY 8, 2010 BRADENHEAD TESlj AREA NOTICE TO OPERATORS (COpy ATTACHED). AN ADD BRAOENHEAD PRESSUREIFLOWTEST WILL BE REQUIRED FOR THIS WELL IN SUMMER 2011, TO BE REPORTED AS SPECIFIED IN THE N( OPERATORS BY 111112011.

Abatement or Corrective Action Required to be Completed by: 6/30/2011

This section to be completed by Operator when alleged violation is corrected

Company Rep: DORIS NEY Title : PRODUCTION TECH

Signature? Y Date: 6/30/2011

Company Comments :

COGCC Signature? Y Date: 1h6/2011 4:00:00 PM

Resolution approved by: DAVID ANDREWS Title:

Final Resolution Date Case Closed? Letter Sent? COGCC person

8/3/2011 Y DA VID ANDREWS COOCC RECEIVED PRESSURE DATA ON 6/301201 1. BRADENHEAD PRESSURE <150 PSI. NO FORM 17 REQUIRED.

Friday, June 29, 2012

http://cogcc.state.co.us/cogisINOAVReport.asp?doc_num=200293704 6129/2012

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COalS - NOA V Reports Page 1 of 1

COGIS - NOAV Report

O~~~:n~~:C;;;:~tjon ~ Related [}. Docs by API [}. Sin~

I DocNum: 200293705 Date ~ec'd:

Operator: MARALEX RESOURCES, INC oper'ro' Address: POBOX 338 IGNACIO. CO 81137 Company Rep. JIM GRAVES Wen Name/No. FEDERAL 26-3 Location NWSW 26 T7S R91 W 6 Fac.ID: 210457 Fac.Type: API number: 05-045 -06213 County

1/1412011 53255

WELL GARFIELD

COGCC Rep: DAVID ANDREWS Phone: (970 ) 625-2497 EXT 1

Alleged Violation: Date of Alleged Violation: 11/1/2010 Approx. time of violation: MARALEX RESOURCES, INC. rOPERATOR"j 010 NOT PERFORM THE FOLLOWING DURING THE PERIOD FROM 111112009 THROUGH 10131.

\NELL FOR PRESSURE AND FLOW AND 2) SUBMIT ANNUAL BRADENHEAO PRESSURE AND FLOW MEASUREMENT RESULTS.

Act, Order, Regulation, Permit Conditions Cited: cOGce ORDER NO. 1-107

Abatement or Corrective Action Required to be Performed by Operator PERFORM BRAOENHEAO PRESSURE AND FLOW TEST AND REPORT RESULTS TO COGCC NO LATER THAN 6/3012010. TESTING AND REF REQUIREMENTS ARE SUMMARIZED IN THE JULY 8, 2010 BRADENHEAD TESTiAREA NOTICE TO OPERATORS (COPY ATTACHED), AN ADD BRADENHEAD PRESSURElFLOWTEST'NlLL BE REQUIRED FOR THIS 'NELL IN SUMMER 2011 , TO BE REPORTED AS SPECIFIED IN THE N( OPERATORS BY 11/112011 .

Abatement or Corrective Action Required to be Completed by: 6130/2011

This section to be completed by Operator when alleged violation is corrected I

Company Rep: DORIS NEY Title : PRODUCTION TECH

Signature? Y Date: 6/30/2011

Company Comments:

COGCC Signature? Y Resolution approved by: DAVID ANDREWS

Final Resolution

Date Case Closed? Letter Sent? 8/312011 Y

Date: 112612011 4:00:00 PM

Title:

COGCC person DAVID ANDREWS

COGCC RECEIVED PRESSURE DATA AND FORM 17 ON 613012011.

Friday, June 29,2012

http: //cogcc.state.co.us/cogis/NOAVReport.asp?doc_num~200293705 6129/20 12

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COGIS - Incident Data Inquiry Page 1 of 1

COGIS . Inspection/Incident Inquiry

You requested : Complaint Information Operator name: mara[ex Maximum records are limited to: 10

Search Results - 10 record(s) returned.

Incident Date Document # Complainant Facility Type Facility IOIAPI Company Name Operator # MARALEX

51412011 2QO,097~5 Bob Kelley WELL 05-045-06127 RESOURCES, 53255 INC

Mr. MARALEX

71612010 20Q25§980 Tomlinson PIT 418038 RESOURCES, 53255 INC

Beth MARALEX 1012912009 2QQ2, 1 2~ Brennaman - WELL 05-045-06175 RESOURCES, 53255

BLM INC

Bradley N. MARALEX 612512009 200213457 Switzer, Esq WELL 05-045-06175 RESOURCES, 53255

INC

MARALEX 812612008 20Q1966~1 Jim Rudnick PIT RESOURCES, 53255

INC

Jack MARALEX 41412008 200 12~7:;9 Bourriague WELL 05-067-06537 RESOURCES, 53255

INC

Gary MARALEX

41412008 2Q012~ZoO WELL 05-067-06537 RESOURCES, 53255 Raymond INC

Tom Durland MARALEX

41412008 'OQ12~Zo, WELL 05-067-06537 RESOURCES, 53255 INC

Phil Johnson MARALEX 41412008 200 1297~ WELL 05-067-06537 RESOURCES, 53255

INC

ROY LYONS MARALEX

112912008 ,QQ1,5,ZZ WELL 05-067-09474 RESOURCES, 53255 INC

http: //cogcc.state.co . us! cogislI ne identS earch2. asp 7/3/2012

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COGIS - Complaint Reports Page I of I

COGIS - Complaint Reports

Form 18/18A i!tK9 Related [l). Doc

Date Rec'd:

DocNum:

5/4/2011

200309795

Complaint taken by: LINDA SPRY OROURKE

APt number: 05-045-06127 Complaint Type:

Complainant Information Name: Bob KelJey

Address:

Oate Received: 5/4/2011

Connection to Incident: land owner

Description of Complaint:

Operator: MARALEX RESOURCES, INC

Oper. No. 53255

Date of Incident:

Type of Facility:

Well NamelNo.

County Name:

Operator contact:

5/4/2011

WELL

GARFIELD

qtrqtr: NWNW section: 23 township: 78 range: 91W meridian: 1

Complaint Issue

Issue: FENCING Assigned To: LlNDA SPRY

OROURKE Status: Resolved 5/1212011

Description: Landowner reported that fencing around well/pad is in disrepair. He has tried contacting operator but does not get response.

Resolution: The fences of concern are not Maralex fences and Maralex does not have any concerns if Mr. Kelley erects a fence near their well pad. I researched parcel owner with downed fence from Garfield County GIS website and sent infonnation to Mr. Kelley via certified mail.

letter Sent?: Y Report Links:

Other Notifications Date: 5112120 II Agency: Maralex Resources

Response or Details Contact: Jim Graves

I met Mr. Kelley. Jim Graves. and Leland Clifton at the Rifle-Boulton #1 well site. We looked at downed section of fence by road. walked the well pad and where Mr. Kelley wants a fence. None of the fences In question are Maralex Resource fences. The area Mr. Kelley Ihought was Maralex pad area Is not. so Maralex does not have any concerns If Mr. Kelley wants to put up a fence there. The well and tank are fenced to protect from animals. and all equipment would be outside the fence Mr. Kelley wants to put up.

Date: 5/9120 11 Agency: Maralex Resources Contact: Doris Ney Response or Details

From: Spry ORourk. Linda Sent: Monday. May 09, 2011 4:14 PM To: 'Doris Ney' Subject Rifle-Boulton'l field visit Hi Doris. I received a complaint from a landowner who reported to me that he has been trying to reach someone at Maralex to get a fencing issue around a well pad resolved. I would like to schedule a Joint visit 10 this location with Maralex personnel. """"'0 at your company should I work with to schedule this field visit? Thanks for letting me know. Unda Spry O'Roui1(e Environmental Protection Specialist. Northwest Region Colorado Oil & Gas Conservation Commission 101 Wapiti Court Suite 204 Rifle. CO 81650 (910) 625-2497 Office (910) 625-5682 Fax (970) 309-3356 Cellular [email protected]

Monday. July 02. 2012

http://cogcc,state.co.us/cogis/ComplaintReport.asp?doc_num~200309795 7/2/2012

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COOlS - Complaint Reports Page I of I

caGis - Complaint Reports

Form 18/18A ~ Related [9. Do<

Date Rec'd: 7/6/2010

DocNum: 200258980

Complaint taken by: SQRAYA BAROUMAN D

Facility 10: 418038 Complaint Type:

Complainant Information Name:

Address :

Date Received:

Connection to Incident:

Mr. Tomlinson

Silt , Co 81652

7/6/2010

land owner

Description of Complaint:

Ope,ator: MARALEX RESOURCES, INC

Ope,. No. 53255

Date of Incident:

Type of Facility:

Fac. Name

County Name:

Operator contact:

7/6/2010

PIT

Maralex Unit II Evaporation Pit

qtrqtr: Null section: Nu township: Null range: Null meridian: 1

Complaint Issue Issue: PITS Assigned To: SORA VA BAROUMAND Status: In Process

Oescription: Mr. Tomlinson contacted me to report his concerns regarding the Garfield II-Unit Evaporation Pit operated by Maralex on East Divide Creek. He has heightened concernS regarding this pit due to the longevity of operations, and its close proximity to East Divide Creek. the adjacent drainage. and rural residents. In addition, he questions the legitimacy of pit operations due to his observations of late night and inconsistent pit disposal activities. (of which he reported was over a year ago). He also stated that he had contacted the BLM in the past regarding his observations and concems. He fees that regulatory management fo r this pit should be reinforced and has requested that the BLM and COQCC review this operation as soon as possible.

Other Notifications Date: 7/27120 10 Agency:

Response or Details Informed Mr. TomHnson that Maraiex removed the coodensate from the pit.

Date: 7/612010 Agency: BLM - Silt Office Response or Details

Contact: Mr. Tomlinson

Contact: Beth Brenneman

Infonned Beth Brenneman that I received a phone call regarding a complaint for this pit, (within houl'l alter cooees and BlMs joint Inspection of referenced pit on July 25,2010 at 10:00 AM. BlM and COGGC are both reviewing this operation at present time.

~ay,~y02,2012

hnp:llcogcc.state.co.uslcogisiCompiaintReport.asp?doc_num=200258980 71212012

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COOlS - Complaint Reports Page lof2

COGIS - Complaint Reports

Form 18/18A ~ Related [9. Doc

Date Rec'd:

DocNum:

10/29/2009

200221234 Complaint taken by: SORAYA BAROUMAND

APt number: 05-045-06175 Complaint Type:

Complainant Information Name:

Address:

Date Received:

Connection to Incident:

Beth Brennaman - Bl M

2300 River Frontage Road Silt I CO 81652

1012912009

BLM - Federal CA property

Description of Complaint:

Operator: MARALEX RESOURCES, INC

Oper, No. 53255

Date of Incident:

Type of Facility :

Well Name/No.

10129/2009

WELL

County Name: GARFIELD

Operator contact:

qtrqtr: SENW section: 17 township: 78 range: 90W meridian: 1

Complaint Issue Issue: ORPHANED EQUIPMENT Assigned To: SORA VA BAROUMAND Status: In Process

Description:BLM has requested that the decommissioned storage tank be removed, in addition to miscellaneous equipment no longer in use be removed.

------------------~--------------------Issue: RECLAMATION Assigned To: SORA VA BAROUMAND Status: In Process

Description: BlM has requested that the smal l enclosed pit be drained, fi lled, and seeded; followed by fence removal.

Issue: TANK BATTERY Assigned To: SORA YA BAROUMAND Status: In Proccss Description: BLM has requested that lIle replacement tank needs sencondary containment.

Issue: WEEDS Assigned To: SORAYA BAROUMAND Status: In Process Description:BLM has requested the removal orland control of noxious weeds (bull & canadian thistle and hounds tongue).

Other Notifications Date: 12122/2009 Agency: coacc Contact: Soraya Baroumand

Response or Details On December 10, 2009, COGCC Issued a Notice of Alleged Violations (NOAV) 10 Marale)( resources, Inc. Refer to Document number 200223622 fO( information regarding vioIatiOtll and required abatement and corrective actions.

Date: 1111912009 Agency:

ltwas addressed to BLM thai an NOAV is forthcoming.

BLM • Sill Office Response or Details

Contact:

hnp:/lcogcc.state.co. usicogisiComplaintReport.asp?doc _ num~20022 1 234

Beth Brenneman

71212012

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COOlS - Complaint Reports

COGIS - Complaint Reports

Form 18/18A

Date Rec'd :

~ Related [9.!22< 6/25/2009

DocNum: 200213457

Complaint Type:

Complainant Information Name: Bradley N. SWitzer, Esq

Complaint taken by: BOB CHESSON

API number: 05-045-06175

Address:

Date Received:

400 South 3rd Street; PO 816 Montrose, CO 81402

612512009

Connection to Incident: LANDOWNER CONTACT

Description of Complaint:

Operator: MARALEX RESOURCES, INC

Oper. No. 53255

Oate of Incident: 612512009

Type of Facility: WELL

Well Name/No.

County Name: GARFIELD

Operator contact:

qtrqtr: SENW section: 17 township: 75 range: 90W meridian: 1

Complaint Issue

Page I of I

Issue: SPILLS Assigned To: BOB CHESSON Status: Resolved 719(2009

Description : Landowner believes operator may be discharging water to surface drainage. Resolution: COGCC personnel inspected three locations of possible I water discharge. All three wells were shut-in during

time of inspection and no evidence of discharge was noted. Infonned complainant ofCOGCC findings. Letter Sent?: N Report Links:

Other Notifications Date: 7/912009 Agency: Contact: Bradley N. Switzer

Response or Details . COGCC per-monel inspected !tYee locations of possible J water discharge. AU !tYee wells were sl'w.rt-in during time of inspection ancJ no evlcJeoce of discharge was noted. InfOfTTled complainant of COGCC tincJings.

MoncJay. July 02. 2012

hnp: llcogcc.state.co. usicogisiComplaintReport.asp?doc _ num~200213457 71212012

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\,..UV1 " - \,..Um pUl1J1l 1\.t;:purl.S

COGIS - Complaint Reports

Form 18/18A ~ Rel'ted [9. QQ<

Date Rec'd: 8/26/2008 Compla Int taken by:

DocNum: 200196641 Complaint Type:

Complainant Information Name:

Address:

Date Received:

Connection to Incident:

Jim Rudnick

unknown on Rd 44 Oe8eque , CO

8/26/2008

CONCERNED CITIZEN

Description of Complaint: Operator:

Oper. No.

Date o f Incident :

Type of Facility:

Fac. Name

County Name:

Operator contact:

53255

812612008

PIT

qtrqtr: NES E section: 36 township : 8S range: 98W meridian: 1

Complaint Issue

Facility 10:

rage 1 or L

Issue: Assigned To : BOB CHESSON Status: Resolved 1011512008 Description: Concerned citizen contacted CDPHE Solid Waste (Grand Junction) regarding water hauling truck traffic and

waste water pit near DeBeque in Mesa County. Complaintant expressed concern that waste wate pit might be taking water as a commercial facility. Original e-mails: From: DONNA D. Stoner [mailto:[email protected]] Sent: Tuesday, September 23, 2008 12:28 PM To; CHARLES JOHNSON Cc: Bob Peterson; Canfield, Chris; Baldwin, Debbie Subject: Fwd: production water pit on BlM September 22,2008 Hello Donna, Listed below is an email we have received from a gentleman who appears to be concerned that Black Mountain customers are using the pond on V.2 Road. Have you heard anything back from the COGCC as to whether they have this pond on their roles'? Thanks, Donna Ross Jim Rudnick 0912012008 II :45 AM Hello Donna, I live on 44 road. On an average day there are about thirty production water trucks that pass my house. They go oul V 21 I 0 road and come back. The day after Black Mountain was suspended the were at least one hundred of these trucks. If you are unaware of the waste water pit the with google earth go to lat 39.313976 and Ion - 108.271232. You will see a lined pit approximately 200X400 feet. Who, if anyone, is responsible for monitoring this pit'? What goes into it'? What evaporates out of it'? What keeps birds and animals out of it'? Who operates it'? These large tanker trucks MUST travel through the town of DeBe que to get to this area. Just another example of the industry exploiting a community. I am not a happy landowner any more. Regards, Jim Rudnick

Resolution: Pit is operated by Maralex Resources to service Mralex well operations in the DeBuque area. Pit is used to evaporate produced water and is not being used by any other company or operator. Maralex maintains very good records on the pit operations. Pit operates on Federal surface lands administered by the BlM and Maralex operates this pit under agreement with the BLM. The BLM is the lead govennentaJ agency on this matter and is conducting additional nvestigations of this operation for any violations. The COOCC is supporting the BLM in their investigation.

Letter Sent?: N Report Links:

Othe r Notificat ions Date: 10/1512008 Ag e ncy: BLM Contact: Christina Stark

Respo nse or Details

http://cogcc.state.co.us/cogis/ComplaintReport.asp?doc _ nwn~200 1 96641 71212012

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coms -Complaint Reports Page 2 of2

Pit is on BLM SU'face location and open'l1es under BLM lease agreement. Pit Is only authorized to handle operator's waste water. BLM will be conducting further Invesllgation of pll op8n11Uonl and ponlble lolls Impacted from opeatlon releases noticed during joint site visit by CDPHE and cOGce (8126108).

Date: 10/1512008 Agency: COGCC Contact: Bob Chesson Response or Details

Pit Is located on Federal sLrface and Opeflltes ooder jurisdiction of the BlM. The pit Is used for the 8VaponlUon of produced water from Maralex operated wells In the DeBeque area. COGCC has a trackb"lg number for the pit #116525 which was assigned dlRlg the SlatEHVide pit Inventory In 1995-96. The BlM Is conducting all follow-on inspections and, If necessary, 8ny release remediation. The COGCC Is supporting !he BLM in their investigation, as necessary. The complaint observed Increased water truck traffic which has been klentified as Increased water hauling to new wen drilling locations on Federal lands west of DuBeque and were not related to any operaUons conducted by Maralex.

Monday, July 02, 2012

httn:/Icoflcc.5tate.co.uslco2islComulaintReoort.asp?doc num=200 196641 71212012

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\....U\JJ,:) - l..,..ompJruDt KepOnS

COGIS - Complaint Reports

Form 18/18A ~ Related [§, ll2<

Date Rec'd: 4/4/2008

DocNum: 200129759

Complaint Type:

Complainant Information Name: Jack Bouniague

Complaint taken by: KAREN SPRAY

API numbor: 05-067-06537

Address :

Date Received:

442 Mountain View Avenue Ignacio , CO 81137

4/4/2008

Connection to Incident: Adjacent land owner

Description of Complaint:

Operator: MARALEX RESOURCES, INC

Oper, No, 53255

Date of Incident:

Type of Facility:

Well Name/No.

County Name:

operator contact:

4/4/2008

WELL

LA PLATA

qtrqtr: NWSW section: 10 township; 33N range: 7W meridian: 1

Complaint Issue

page j 014

Issue: NOISE Assigned To: LESUE MELTON Status: Resolved 1111012008 Description: Compressor underwent modifications last year sometime and stack now sticks out above sound walls by

about 2 feet. Can hear compressor in house wI closed windows at 2 a.m .. Contacted operator but have haa no positive response. Did not have this issue last year at this time.

Resolution: Operator has installed sound wall on west side of compressor. Field inspection was made and additional sound measurements were taken on 11/06/08. Measurements can been viewed on COOCC internal document #01921029. Measurements taken on north, south, and east sides are all within COOCC prescribed limits under Rule 802.c (SO dbA). Measurements taken at deadmen on northwest and southwest comers are also within prescribed limits. NOA V #2OO19266S is being closed out. Complaint #'s 200129760, 200129763, and 200129764 are also be closed out.

Letter Sent?: N Report Links: I NOM I

Other Notifications Date: 11 /612008 Agency: Mamlex Resources Contact: Christi Reid

Response or Details Operator has recently piled dirt around the last sound wall (west side) Installed. FIeld Inspection was made and additional sound measurements were taken. Measurements can been viewed on COGCC Internal document 101921029. Measurements taken 00 north, south, and east sides are all within COGCC presctibed limits l.Jlder Rule 802.e (50 dbA). Measurements taken al dead men on northwest and southWest comers are also within prescirbed limits. NOAV #2001926651$ being dosed out. Complaint 1'5 200129760, 200129763, and 200129764 are also be Closed out.

Date: 812912008 Agency: Mamlex Resources Contact: Mickey O'Hare . Response or Details

FIeld Inspector contacted Operator andlelt a voice message requesting an update on sound mitigation efforts.

Date: 812912008 Agency: Mamlex Resources Contact: Christi Reid Response or Details

Operator contacted Field Inspector and Indicated that two additional sound walls (9' x 161 were being Installed on the today. InspectOf and Operator agreed to meet jointly the week of September 1 st. 2006 to take noise measurements and detennlne If Operator Is now In compliance with COGCC presctibod limits. Operator Indicated that If levels are still In excess, that they had other options In mind, Includnlg Installing additional angledlflllf8d

hnp://cogcc.state.co. us/cogis/ComplaintReport.asp?doc _num=200 129759 71212012

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COGIS - Complaint Reports Page 2 of4

WIllS on north andlor west side to re1Ie<:t sound upwards.

Date: 7/1612008 Agency: Maralex Resources Contact: Mickey O'Hare: Response or Details

Operator was contacted and asked what plans to mitigate were In mollon. Field InspectCH" asked Operator how long It would reasonably lake 10 Implement sound mitigation measures. Operator Indicated they needed approximately six weeks to Implement these measures. Inspector Informed Opera tor that an NOAV would be Issuecllmmedlately giving them this amount of time to reduce sound levels to within prescribed limits. NOAV '200192665 was issued on July 18th, 2008 giving Operator until August 29th, 2008 to come Into compliance with prescribed limits.

Date: 611512008 Agency: Nearby Landowner Contact: Jack Bowriague Response or Details

SW FJeld Inspector received In email requestirJ,;J an update on when noise measurements would be made with MaraJex personnel present. Field Inspector emailed back that she would attempt to coordinate with Samson and Maralex to take readings earty \o\Iednesday morning (June 18U1)

Date: 6/4fl008 Agency: Nearby Landowner Contact: Jack Bowriague Response or Details

The following emalls were eKc::hanged between SW Field Inspector and Complainant: leslie, Thanks you for the update, I do think If you keep the heat on Maralex you will get results. Sad to think this is what it takes to get compliance but I guess that's the way It Is, Jack On VoIed, Jun 4, 2008 at 5:25 PM, Melton, leslie wrote: Jack, I spoke with Christi yesterday and menlloned the Jelter that the County Is pl"epared to dran In support of COGCC efforts to gain Maralex's compliance, I also explained that I don't have to let them eccompany me when taldng measurements. I told her that I could push much harder than I am with data I aJrrenUy have and that she should seriously share this with MicM'y. AnyhoW, I wanted to take measurements in the morning but It Is SlJpposed to be windy and rainy so I didn't schedule a Samson shut-down. I may try for Friday depending on forecast tOlTlOf"R)W. I'm then out of town tiU late Sunday so It wlU be Tuesday at the ear1lesllll keep you posted.

Date: 5/1212008 Agency: Adjacent Landowner Contact: Jack Bourraigue Response or Details

SW Field Inspector received a message from Complainant indicating thaI Indeed the mufller had been modified to push noise southwards, but !hat It now seemed thaI noise was reflecting off south sound wall and going north again towards his reSidence. Parties tenlatlvely sel a meeting 10 take sound measurementss Tuesday earty AM. InspectOr musl first contact Samson Resources to have them shut down their pumpjack and will call Complainant back to con!lrm moetlng.

Date: 5/1212008 Agency: Maralcx Resources Contact: Christi Reid Response or Details

SW Field Inspector contacted Operator 10 discuss InCfeased noise levels after muffler modification. Operator Indicated that they had thought this would help to reduce noise levels. Field Inspector agreed to take additional measurements and call Operator back with results.

Date: 511212008 Agency: Land owner Contact: Jack Bourriaguc Response or Details

SW FJeld Inspector contacted Complainant agaIn and postponed meeting for one day (\'Vednesday 51104/08 6 AM) due to an Incoming late season storm.

Date: 5/1212008 Agency: Maralex Resourccs Contact: Mickcy O'Hare Response or Details

SW Field Inspector contacted Operator and arranged to meet Jointly on 5/104108 at 8 am to take sound measurements and .assessthe situation. Mr. Sourrlague wiU also be pre5ef1l Operator indicated that they were having a noise study conducted and were considering putUng up a set bact sound wall on north end which is partially open.

Date: 5/1012008 Agency: Maralcx Rcsources Contact: Christi Reid Response or Details

SW Field Inspector receiVed a voice message from MaraleK Indicating that they had Installed an elbow on mlJffler and had rotated it 90 degrees to push the sound southwards.

Date: 5ilfl008 Agency: Maralex Resourccs Contact: Mickey O'Hare Response or Details

SoN FJelcllnspector contacted Operator and discussed the results of previous days sound measurements. Operator was told that all five readings were ebove COGCC presaibed limits and that an NOAV would be issued based on complaints and non-<:omptlance. Both parties agreed to meet jointly and take measurements so Operator could witnell readings. Due 10 high wind conditions forecast for !he neld few days. both parties agreed 10 moet early next woek as conditions aPew. Field Inspector i1forrned Operalor thai Samson Resources would be contacted In order to have them $hut down their pl.mpjack to provide accurate readings of sound coming from Maralex compressor. FIeld Inspectorwll contact Operator late Monday and try and schedule a meeting for Tuesday early AM.

Date: 4/3012008 Agency: Adjacent Landowncr Contact: Jack Bourraigue Response or Details

SWFlelcllnspec!or made a !leid visit Inc! took sound measurements at ComplaJnants residence at 5:30 AM. Wnd was calm. dbC readings taken 25 feet from resIdence ~fe between 52-5<' dbC which falls within COGCC prescl1bed limits. Both parties then wenl to facility and took dbA readings at

httn :IICOf1cc.~tate.co,u5lcol2: islComDlaintReoort.asD?doc num=200 129759 71212012

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CO(jl~ - Complaint Keports rage.) 01 't

approldmate/y 5:56 AM. dbA readings were aU above COGCC prew1bed limits and can be ~ed on COGCC internal documenl"10192101 4, FIeld InspectOC' wln contact Operator to discuss results.

Date: 4/3012008 Agency: Maralex Resources Contact: Mickey O'Hare Response or Details

SW FIeld Inspedor place call to Operator and left a message for them to please caD back to discuss the results of sound measurements taken that morning.

Date: 412912008 Agency: Maralex Resources Contact: Mickey O'Hare Response or Details

SW Field Inspector contacted Operator to dlsClJSS adding a panel on the northwest comer. Operator that it wasn't possible as heat from the facility needed to place to escape. Discussed the posslbUty of added to wall several feel out which would block noise but allow heat to escape. OperalQ( indicated that he would check with their engineers. Operator indicated he didn't think they were out of compliance. Inspector noted to him thai measurements would be taken the next morning with the Samson pump;adl shut down and that th is would provlda accurate readings. Inspector would contact Operator after this to di$O.JSl results.

Date: 4/2812008 Agency: Adjacent Landowner Contact: Nita Bourriague Response or Details

Conlactecl Complalnanta wife to provide an update on the noise sltuatlon. Explained that Christi Reid with Maralex indicated that had put In a request with compressor malntanance Claw to put an elbow on the stack which sticks abo .... e sound waUa and rotate It 90 degrees to push noise south. Christl indicated that they had been trying to worJ( with Jack, but are unsure exactly what needs to be done.

Date: 4/2812008 Agency: Maralex Resources Contact: Christi Reid Response or Details

SW Field Inspector oontacted Operator to discuss sound mitigation. Inspector baslcally'uked what they thought they could do to lower sound levels. Operator indicated that they had requested that compressor maintena~ crew put an elbow on exhaust and fotate it 90 degrees to point the noise to th!' south. Operator Indicated they would conftrm thatlhis worJ( Is still sCheduled for the near future.

Date: 4128/2008 Agency: Samson Resources Contact: Billy Box Response or Details

SW FIeld Inspector contacted Samson and requested thatlhelr pumpJack on this location be shut down so that sound measurements coukl be taken of only the Mal1liex comprelSor. It was agreed that It woUld be &hut down at 11:00 AM and after measurements were \lken it would be started u~ again. Aftef thinking abolll. springtime wind conditions, FIeld Inspector called Operator back again to see If it could be &hut down at6 AM as this IS when measurements will be taken at the Boumague residence. Operator Indicated thaI this was not possible so it was agreed to shut it down Tuesday 4129 at midnight and Field Inspector would go out early wednesday end take measurements.

Date: 4128/2008 Agency: Adjacent Landwner Contact: Jack Bourriague Response or Details

sw Field Inspector oontacted Complainant and agreed to make sound measurements Tuesday -i129 at 6:00 AM. Inspector wi. then leave sound meter with Complainant In orner for him to lake additional dbC measurements durlng nlghtlme hou~.

Date: 412812008 Agency: Adjacent Landowner Contact: Jack Bourraigue Response or Details

SW Field Inspector contacted Complainant and scheduled a meeting at 6:00 AM 4f29J08. FIeld InspectOf" made a field visit but Complainant thought that there was already too much traffic noise for an accurate reading. Both partles visited location of facility and attempted to take readings but it was detennined thai noise from pumpjack (Samson) was still making readings Inaccurate. It was agreed thaI if the northwest corner of facility had a noise panel installed, that noise levels would be lCM'ered. InspectOf" explained that pumpjack would be shut down by Samson that night and that Inspector wotJld rerum the next momlng to take additional measurements.

Date: 412812008 Agency: Adjacent Landowner Contact: Jack Bourraigue Response or Details

SW Field Inspector contacted Complainant and Icheduled a meeting al 6:00 AM -i129108. FIeld ll15pector made a field visit but Complainant thought that there was already too much traffic noise for an accurate reading. Both parties visited location of facility and attempted to take readings but It was determined that noise from pumpjack (Samson) was stiU making readings Inaccurate. It was agreed thai if the northwest comer of facility had a noise panel installed, that noise lell'8ls woukl be lowered. Inspector explained that pumpjack would be lhut down by Samson that ~ht and that Inspector would return the next moming to take additional measurements.

Date: 412512008 Agency: Adjacent Landowner Contact: Jack Bourriague Response or Details

Complainant called FlOId Inspector and left a melsage saying he wanted 10 take noise mealurements Saturday evening. COmplalnant indicated that if he didn't near back from Inspector, he woucl meet her out there. Message was not picked up by Inspector untit Monday morning. ComplaJnant had already tailed two ott1er COGGC staff and indicated thaI he fe/t he had been stood up.

Date: 412312008 Agency: Adjacent Landowner Response or Details

Contact:

http://cogcc.state.co.usicogisiComplaintReport.asp?doc_num=200129759

Jack Bourriague

7f212012

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caGIS - Complaint Reports Page 4 of4

SW FJeld Inspector contacted Complainant and agreed to come oul and take sound measurements at 7:45 PM. Inspector later called back and cancelled meeting due to conftlcting appointments.

Date: 4/812008 Agency: Adj acent Landowner Contact: Jack Bourriague Response or Details

SW Flekllnspector made a field visit and talked to Complainant allength. Inspector offered to take sound me3SUfements but Complainant Indicated that noiS& level. al ItIaI lime were nol representative of what they here at right. Complainant requested that noise measurements be laken during the night hows. Inspector agreed 10 schedule a visit dur1ng sleeping hours In the near Mure.

Date: 41412008 Agency: Maralex Contact: Christi Reid Response or Oetails

Monday, July 02, 2012

httn · II(".no('.(': . ~t;:! f~ . C:O . ll~CogisJC;omn'aintReoort. a'in?doc num=200 129759 7121201 2

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CUUI~ - Complamt Keports Page I 01'2

COGIS - Complaint Reports

Form 18/18A ~ Related 0. QQ<

Date Rec'd: 4/4/2008

DocNum: 200129760

Complaint taken by: KAREN SPRAY

API number: 05-067-06537

Complaint Type:

Complainant Information Name: Gary Raymond

Address:

Date Received:

145 Mountain View Lane Ignacio , co 81137

4/4/2008

Connection to Incident: Adjacent land owner

Description of Complaint: Operator: MARALEX RESOURCES, INC

Oper. No. 53255

Date of Incident:

Type of Facility:

Well Name/No.

County Name:

Operator contact:

4/4/2008

WELL

LA PLATA

qtrqtr: NWSW section: 10 township: 33N range: 7W meridian: 1

Complaint Issue Issue: NOISE Assigned To: LESLrE MELTON

Description: Compressor is too noisy and bothers the neighborhood.

Status: Resolved 11 /1012008

Resolution: Operator has installed sound wall on west side of compressor. Field inspection was made and additional sound measurements were taken on 11/06/08. Measurements can been viewed on COGCC internal document #0192 1029. Measurements taken on north, south, and east sides are all within COGCC prescribed limits under Rule 802.c (50 dbA). Measurements taken at deadmen on northwest and southwest comers are also within prescribed limits. NOAV #200192665 is being closed out. Complaint #'s 200129759, 200129763, and 200129764 are also be closed out.

Letter Sent?: N Report Links: I HQAY I

Other Notifications Date: 1II612008 Agency: Maralex Resources Contact: Christi Reid

Response or Details Operator has rec::enUy piled dirt around the last sound wall (west skle) Installed. Fteld Inspection was made and additional sound measurements were taken. Measurements can been viewed on COOCC Intema! document 101921029. Measurements taken on north, south, and east sides are all within COOCC pl"esaibed limits under Rule S02.c (50 dbA). Measurements taken at dead men on northwest and southwest comers are also within prescirbed limits. NOAV 1200192665 Is being closed out. Complaint 1'5 200129759, 200129763, and 200129764 are also be closed out.

Date: 5/112008 Agency: Contact: Gary Raymond . Response or Details

Please see Complaint 1200129759 (Jack Bourraigue)for all additional Information regarding this complaint as Mr. Bourraigue has been Field Inspectors primary contact and as relaying progress to Mr. Raymond.

Date: 4/812008 Agency: Adjacent Landowner Contact: Gary Raymond Response or DetailS

SoN Field Inspector made a field visit and took sound measurements. Measurements were recorded three times at 25' from residence. Results were as follows: 1st reading-52.6-54.D dbC: 2nd reading · 53.2-54.3 dbC: 3rd readlng-52.4-55.9 dbC. These readings are all below COGCC presaibed limits.

http://cogcc.state.co.us/cogis/ComplaintReport.asp?doc _num~200 129760 71212012

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CO GIS - Complaint Reports Page 2 of2

Mooday, July 02, 2012

httn: llcOflCC.state.CO.llS/C02islComoiaintReoort.aso?doc num=200 129760 7/212012

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...... VUl" - ...... ompuum Kepons Page 1 on

COGIS - Complaint Reports

Form 18/18A ~ Related [9.!2Q£ Date Rec'd : 4/4/2008 Complaint taken by: KAREN SPRAY

DocNum: 200129763 API number: 05-067-06537 Complaint Type:

Complainant Information Name: Tom Durland

Address:

Date Received:

172 Zart Drive Ignacio, Co 81137

4/4/2008

Connection to Incident: Adjacent land owner

Description of Complaint:

Operator: MARALEX RESOURCES, INC

Oper. No.

Date of Incident:

Type of Facility :

Well Name/No,

County Name:

Operator contact:

53255

4/4/2008

WELL

LA PLATA

qtrqtr: NWSW section: 10 township: 33N range: 7W meridian: 1

Complaint Issue

Issue: NOrSE Assigned To: LESLIE MELTON Status: Description: Compressor is very loud and bothersome. Especially in the early morning.

Resolved 11 / 10f2008

Resolution : Operator has installed sound wall on west side of compressor. Field inspection was made and additional sound measurements were taken on 11106/08 . Measurements can been viewed on COGCC internal document #01921029. Measurements taken on north, south, and east sides are all within COOCC prescribed limits under Rule 802.c (50 dbA). Measurements taken at deadmen on northwest and southwest comers are also within prescribed limits. NQAV #200192665 is being closed out. Complaint #'s 200 129759, 200129760, and 200129764 are also be closed out.

Letter Sent?: N Report Links: I liQA.Y I

Other Notifications Date: 1111012008 Agency : Maralex Resources

Response or Details Contact: Christi Reid

Operator has recenUy plied dirt around the last sound wall (west side) installed. FIeld InspecUon was made and additional sound measurements were taken. MeaslJrements can tieen viewed on COGCC Interna! document 101921029. Measurements taken on north, south. and east sides are all withln COOCC prescribed limits under Rule S02.c (50 dbA). Measurements taken at dead men on northwest and southwest comers are also within prescirbed limits. NOAV '200192665 Is being closed out. Complainttt's 200129759. 200129760, and 200129764 are also be closed out.

Date: 51112008 Agency: Contact: Tom Durland Response or Details

Please see Complaint #200129759 (Jacll Bourriague) for all additional infonnatlon regarding this complaint as Mr. Bourriague has been Field Inspectors primary contact end is relaying progress to Mr. Durland

Date: 4/812008 Agency: Adjacent Landowner Contact: Tom Durlan Response or Details

sw Field Inspector made a field visitand took sound measurements. Measurements were recorded three times at 25' from residence. Results were as follows: 1st readlng-54.4-57.6 dbC; 2nd reading· 52.9-55.2 dbC; 3rd readlng-53.6-56.1 dbC. These readings are all below COOCC prescribed limits.

http://cogcc.state.co.us/cogisiComplaintReport.asp?doc _ num~200 129763 712/2012

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COGIS - Complaint Reports Page 2 of2

Monday, July 02, 2012

httn:IICOQcc.state.co. us/collisiComolaintReoort.asp?doc nwn=200 129763 71212012

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COGIS • Complaint Reports

~ R,iot,d !],. l2o< Form l8/l8A

Date Rec'd: 4/4/2008

DocNum: 200129764

Complaint taken by: KAREN SPRAY

API number: 05-067-06537 Complaint Type:

Complainant Information Name:

Address:

Date Received:

Phil Johnson

327 Mountain View Lane Ignacio I CO 81137

4/4/2008

Connection to Incident: Adjacent land owner

Description of Complaint: Operator: MARALEX RESOURCES, INC

Oper. No.

Date of Incident:

Type of Facility:

Well Name/No.

County Name:

Operator contact:

53255

4/4/2008

WELL

LA PLATA

qtrqtr: NWSW section: 10 township: 33N range: 7W meridian: 1

Complaint Issue Issue: NOISE Assigned To: LESLIE MELTON Status: Resolved 11/1012008

Oescription: The compressor is very noisy at his house. Resolution: Operator has installed sound wall on west side of compressor. Field inspection was made and additional

sound measurements were taken on 11/06/08. Measurements can been viewed on COGCC internal document #01921029. Measurements taken on north, south, and east sides are all within COGCC prescribed limits under Rule 802.c (50 dbA). Measurements taken at deaclmen on northwest and southwest comers are also within prescribed limits. NOAV #200 192665 is being closed out. Complaint #'s 200129759, 200129760, and 200129763 are also be closed out.

Lette r Sent?: N Report Links: I N.QAY I

Other Notifications Oat.: 1 1/1012008 Agency: Maralex Resources

Response or Details Contact: Christi Reid

Operator has recenUy piled dirt around the last sound wall (west side) installed. Field Inspection was made and additional sound measurements were taken. Measurements can been viewed on eooee Intemal document #01921029. Measurements taken on nOrth. south, and east sides are all within COGCC prescribed limits under Rule 602.c (50 dbA). Measurements taken at dead men on northwest and southwest comers are atso within presclrbed timits. NOAV #200192665 is being closed out. Complalnt"lfs 200129759. 200129760, and 200129763 are also be closed out.

Date: 5/112008 Agency: Contact: Phil Johnson Response or Details

Please see Complaint #200129759 (Jack Bourriague) for aU additional Information regarding this complaint as Mr. 60uniague has been Field InspectOtS primary contact and Is relaying progress to Mr. Johnson.

Date: 4/812008 Agency: Adjacent Landowner Contact: Phil Johnson Response or DetaJls

SW Field Inspector made a field visit and took sound measurements. Measurements were recorde<;l three times at 25' from residence. Results were as follows: 1st reading-54.Hi9.6 dbC; 2nd reading· 52.7-55.0 dbC: 3rd reading·52.5-54.3 dbC. These readings arll all below cooce prescribed limits.

http://cogcc,state,co,us/cogis/ComplaintReport,asp?doc _ num=200 129764 71212012

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COOlS - Complaint Reports Page 2 of2

Monday. July 02. 2012

htto:llco2cc.state.co.uslcolrisiComolaintReoort.aso?doc num=200129764. 71212012

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COUI ~ - Complaint Keports

COG IS • Complaint Reports

Form 18f18A ~ Related [§'ll9£ Date Rec'd:

DocNum:

Complaint Type:

112912008 200125377

Complainant Information Name: ROY LYONS

Complaint taken by : MARK WEEMS

API number: 05-067·09474

Address:

Date Received:

1911 CR 336 IGNACIO, CO 81 137

1/29/2008

Connection to Incident: LANDOWNER

Description of Complaint: Operator:

Oper. No.

Date of Incident:

Type of Fac!!!ty :

Well Name/No.

County Name:

Operator contact:

MARALEX RESOURCES, INC.

53255

1/29/2008

WELL

MOLLIE CORYNNE 33-7-2 #36

LA PLATA

qtrqtr: SWNW section: 2 township: 33N range: 7W meridian: N

Complaint Issue

Page! or 1.

Issue: NOISE Assigned To: LESLIE MELTON Status: Resolved 21512008 Description: The noise from the drilling rig has been waking him up at 3 am and be wants the noise stopped or something

to be done to lower the levels. The applicable COGCC rules were explained to him as well as the reasons for drilling 24 hours per day. He does have the operator's phone number and does have a working relation with them. He was told that sound levels would be measured and that the operator would be contacted to infonn them of the complaint and also to detennine an estimate of how much more time it would take to complete the drilling operations. He was assured that the applicable rules would be enforced if out of compliance. The COGCC would report back 10 him regarding this infonnation.

Resolution: Rig was indeed moved off location on Friday Feb. 1st SW Field Inspector has never heard back from Complainant after asking him 10 call back. It is assumed that the complaint can now be closed.

Letter Sent?: Report Links:

Other Notifications Date: 21512008 Agency: Land owner Contact: Roy Lyons

Response or Details Rig was Indeed moved off location on Friday Feb. 1 &1. SW Field Inspector has never heard back from ComplaInant after asking him to carr back. II is assumed that the complaint can now be dosed.

Date: 2/412008 Agency: Landowner Contact: Roy Lyons Response or Details

SW Field left a voice message with Complainant Indicating that Samsoo left two messages saying that the rig was being moved Friday. Inspector requested an update 00 noise levels and askeel that the Complainant call her back to discuss.

Date: 2/112008 Agency: Samson Resources Contact: Christi Reid Response or Details

Two voice messages wore left by Operator In respon.e to SW Field Inspectors messages requesting update on rig move. Both messages Indicated thatlhe rig would Indeed be moved oft' location that day (Friday).

http://cogcc.state.co.us!cogisiComplaintReport.asp?doc_ num=200 125377 71212012

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COGIS - Complaint Reports Page 2 of2

Date: 113112008 Agency: landowner Contact: Roy Lyons Response or Details

Complain ant was contacted by SW Field Inspector to discuss the situation. Complalnanllndicated that noise levels at night were bad and that it SOUnded like a snowplow was coming Uvough the waU. Complainant had spoken with Operator Monday and was told that the right would be moved late Tuesday. this had not yel occurred. SW Field InspectOllnfOfTTled Complainant that cooce would come oulimmediatety to take sound measurements. Operator was rontacted and advised InspectOf thai the rig was being moved off location the next day (Friday January 1st). IMpedor called Complainant back and left a voice message relaying this Information and postponed noise measurements. VoIeather conditions were Inclemem al this time.

Monday, July 02, 2(}12

httn :/1 CO I2CC .state. CO . us/CO Ili S/Como laintReoort.aso ?doc num=200 12 5377 7(2(2012

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COGIS - Incident Data Inquiry Page 1 of 1

COGIS - Inspection/Incident Inquiry

You requested: Mechanical Integ ri ty Test Information Operator name: maralex Maximum records are limited to: 10

Search Results ~ 2 record(s) returned.

Document # Facility 10 # API Number Well Name & Number Test Date Test Type Company Nal

05-045- ALBERTSONS SlrrA MARALEX

llIQ820 210547 06303 RANCHES -13-4

6/1212006 MAINTENANCE RESOURCE: STATUS INC

05-077- SlrrA MARALEX 12416~a 221856 SWETLAND -1-5 5/12/2004 MAINTENANCE RESOURCE:

08458 STATUS INC

http://cogcc.state.co.uslcogis/IncidentSearch2.asp 71212012

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COGIS - MlT Reports Page I of!

COGIS - Mechanical Integrity Test Report

Form 21 Date Submitted:

Date Rec'd:

DocNum:

6/1 412006 6/2612006

1170825

~ Related 19. QQl1

MIT Assigned by: KRABACHER, JAY

API number: 05-045-06303

Facility Status: PA

Operator Information:

Oper. No.

Operator:

Address:

Type of Facility:

Well Name/No.

53255

MARALEX RESOURCES, INC

PO BOX 338 IGNACIO , CO 81137

WELL Well Status: SI

ALBERTSONS RANCHES 13-4

Operator contact: JIM GRAVES

Location : qtrqtr: NWSE section: 13 township: 75 range: 99W meridian: 6

MIT Details: Test Type: Test Date: Field Rep: Approved Date: Approved by: Last Approved MIT: Injection/Producing Formation Zones: Perioration Interval: Open Hole Interval: Bridge/Cement Plug Depth: Tubing Size: Tubing Depth: Top Packer Depth: Multiple Packers:

Condition of approval:

Test Data-Reading Type

10 MI N CASE

MI N CASE

ASE BEFORE

FINAL CASE

FINAL TUBE

INITIAL TUBE

LOSS OR GAIN

START CASE

SIITA MAINTENANCE STATUS 6112/2006

6/2612006 KRABACHER, JAY Not Available

DKTA 8792 - 8890 NA

4620 N

Pressure

458

460 0

455 0 0

-10 465

Well bore Channel Test: No channel test.

http://cogcc.state.co.usIcogis/MJTReport.asp?doc_num~1170825 71212012

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caGIS • MIT Reports Page 1 of 1

COGIS • Mechanical Integrity Test Report

Form 21

Date Submitted:

Date Rec'd:

DocNum:

5/1212004

5/1712004

1241698

~.Relaled ~ Doc

MIT Assigned by: KRABACHER, JAY

API number: 05-077·08458

Facility Status: 81

Operator Information:

Oper. No.

Operator:

Address:

Type of Facility :

53255

MARALEX RESOURCES, INC

POBOX 338 IGNACIO, CO 81137

WELL Well Status: 51

Well Name/No. SWETLAND 1-5

Operator contact: DENNIS REIMERS

Location: qtrqtr: SWNE section: 5 township: 115 range: 95W meridian: 6

MIT Details: Test Type: Test Date: Field Rep: Approved Date: Approved by: Last Approved MIT: Injection/Producing Formation Zones: Perforation Interval: Open Hole Interva l: Bridge/Cement Plug Depth: Tubing Size: Tubing Depth: Top Packer Depth: Multiple Packers:

Condition of approval:

Test Data ' Reading Type

10 MIN CASE

h5 MIN CASE

CASE BEFORE FINAL CASE

FINAL TUBE

INITIAL TUBE

LOSS OR GAIN

START CASE

SIITA MAINTENANCE STATUS 5/1212004 KRABACHER, JAY 5/1712004 KRABACHER. JAY Not Available

DKTA

4900 NA

3331

Wellbore Channel Test: Pressure No channel test.

289

296

0 282

·26

308

http://cogcc.state.co.uslcogis/MITReport.asp?doc _ num~ I 241698 71212012

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COGIS - Incident Data Inquiry Page 1 of 1

COGIS - Inspection/Incident Inquiry

You requested : SpilVRelease Information Operator name: maralex Maximum records are limited to: 10

Search Results - 8 record(s) returned.

Submit Date Doc # Complainant Operator # Facility 10 Company Name Ground Water Surface Wi MARALEX

10/1 812011 2216:;§0 53255 RESOURCES. N N INC

MARALEX 2/4/2010 .oQ~617 53255 RESOURCES. N N

INC

MARALEX 11212008 mo122 10119 DISPOSAL LLC N N

MARALEX 12/3112007 :113312:1 53255 RESOURCES. N N

INC

MARALEX 4/1412006 12~3000 53255 RESOURCES. Y N

INC

MARALEX 8/412003 12~1726 53255 RESOURCES. N N

INC

MARALEX 5/10/1996 1994R 53255 215787 RESOURCES. N

INC

MARALEX 4/30/1996 Z99993 53255 216390 RESOURCES. N

INC

http://cogcc.state.co.us/cogis/lncidentSearch2.asp 71212012

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coms -Spill Reports

COGIS - Spill Reports

Form 19/19A

Date Rec'd : 11212008

t'age ! 01 1.

Repor1taken by: KAREN SPRAY

DocNum: 1733122 API number: 05-067 ·09194 Facility 10: 285319

Operator Information Operator: MARALEX DISPDSAL LLC Oper. No. 10119

Address: POBOX 338 ATTN: A. M. O'HARE IGNACIO , CO 81137

Phone: (970 )563-4000 Fax: (970 )563-4116

Op~rator Contact: DENNIS REIMERS

Description of Spill: Date of Incident: 1/112008 Type of Facility: WELL

Well Name/No. DARA FERGUSON Fac. NamelNo. INJECTION 1

County Name: LA PLATA qtrqtr: SWNW section: 32 township: 33N range: 9W meridian: N

Volumes spilled and recovered (bbls)

on spilled: 0

Water s pilled: 170

Other splllod: 0

GWlmpact? N SUrfaC41 wliter impact? N

Area and vertical .xtent of split: 20-FT X 20·FT

Current land use: NON-CRQP RANGELAND

Weathlr condlUons: 'MNTER COLO 5-20 DEGREES F

Soil/Geology description ZYME CLAY LOAM

Distance in feet ~o noarost surflce water:

Depth to ,hallowe.t GW:

Wetlands:

Recvrd: 0

Recvrd: 160

Reeved: 0 Contained with in berm? N

Buildings:

LIVestock: Wator Well.:

Cause of spill : EQUIPMENT FAILURE

Immediate Response: STOPPED TAKING WATER, SUCKED UP SPILL 'NHICH WAS 95% CONTAINED IMTHIN BERM

Emergency Pits : NlA

How extent determined: VISUAL

Further Remediation PROPOSEO NEW eQUIPMENT IMLL INCLUDE A TANK LOCKOUT WHEN TANKS ARE ENAR FUll

Prevent Problem :' SEE ABOVE

Detailed Description: INJECTION PUMP FAILED AND WATER TRUCK HAULERS CONTINUED TO OFFLOAD WATER UNTIL TANK OVERFLOWED.

Other Notifications 0 ...

1I2l2008 Agency COGCC

Contact KAREN SPRAY

Re.ponse VIA 'AX

http://cogcc.state.co.uslcogisiSpiIlReport.asp?doc _ num= 173 3122 71212012

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COGlS • Spill Reports

Field Visit/Follow Up Name No FIeld Visit data found.

Final Resolution

Phone o.te

Date Case Closed? L.ettor Sent? COGCC person 613012010 Y N KAREN SPRAY SITE REGRADED. ACCESS ROAD PAVED AND SECURITY GATES INSTAL.LED, NFA AT THIS TIME.

Monday, July 02, 2012

hnu:/lc02cc.state.co.us/cogis/SpillReport.asp?doc num~ 1733122

Page 2 of2

7(2(2012

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COGIS - Spill Reports r age 1 01 ~

COGIS - Spill Reports

Form 19/19A

Date Rec'd: 10/1 8/2011

DocNum: 2216560 Report takon by: STEVE LINDBLOM

API number: 05-- Facility 10: 426065

Operator Information Operator:

Address :

Phone:

MARALEX RESOURCES. INC Ope,. No. 53255

PO BOX 338 AnN: JIM GRAVES IGNACIO. CO 81137

(970 )563-4000 Fax: (970 )563-411 6

Operator Contact: JIM GRAVES

Description of Spill : Date of Incident: Type of Facility:

712712011

GAS COMPRESSOR

Well Name/No. CORCORAN POINT Fac. NamelNo. COMPRESSOR 426065

County Name: GARFIELD qtrqtr: NWNE section: 6 township: 8S range: 102W meridian: 6 Volumes spilled and recovered (bbls)

Oil spil led: Rocvrd:

Water spilled: Rocvrd:

Other spilled: Rocved :

GWlmpact? N Surface water impact? N Contained with in borm? Y

Area e nd vertical extent of s pill: 100-sa FT X •

Current land usa: OPEN RANGELAND

Weather condlUons: CLEAR, HOT, CALM WINOS

SoilfGeology description MESA·AVALON COMPlEX

Distance In feet to nearOlt surface water: 1230

Depth 10 shallowest GW: !50

Wotland.:

Livestock:

Cause of spill: HISTORICAL RELEASE

Immediate Response:

Buildings: 915

Water Wells: 1100

THE ENTIRE AREA OF IMPACTED SOIL IS ALL CONTAINED WITHIN THE PIT BOUNDARY. DUE TO THE AGE OF THE PIT NO FLUIDS HAVE BEEN RECOVERED FROM THE PIT.

Emergency Pits: NONE 'M?:RE CONSTRUCTED.

How extent determined: BY FIELD MEASUREMENTS AND MAPPING WITH A TRIMBLE GPS UNIT.

Further Remediation THE IMPACTED SOIL FROM ""'THIN THE PIT 'MLL BE REMEDIATED TO LEVELS BELOW TABLE 91()'1 STANDARDS. A CONFIRMATION SAMPLE WILL BE COLLECTED FROM THE PIT BOTTOM AND WALLS TO CONFIRM NO RESIDUAL CONTAMINATION IS LEFT IN PLACE. THE IMPACTEO SOIL FROM THE PIT 'MLL BE PROFILED FOR DISPOSAL AT AN APPROVED PERMITTED FACILITY. THE PIT 'MLL BE BACKFILLED WITH CLEAN NATIVE MATERIAL AND THE SITE WILL BE RECLAI MED AND RESEEDED AS DIRECTEO'BY THE BLM.

Prevent Problem: NlA AS THIS IS A HISTORICAL RELEASE.

Detailed Description :

THE SITE OF THE RELEASE IS AN OLD BLOW OO'vVN PIT LOCATED AT THE FORMER CORCORAN POINT

http://cogcc.state.co.usIcogisiSpi llReport.asp?doc _ num=221 6560 712120 12

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COGIS - Spill Reports

COMPRESSOR STATION. THERE HAS BEEN NO EQUIPMENT ON sITe FOR ~13 YEARS ACCORDING TO THE CURRENT O'loJNER OF THE FACILITY. MARALEX RESOURCES IS IN THE PROCESS OF RECLAIMING THE FORMER FACILITY. THE FACILITY IS LCOATED ON BLM LAND AND THEY HAVE ASKED THAT THE OLD PIT BE REMEDIATED TO cOGce GUIDELINES AS PART OF THE RECLAMATION PROCESS.

Other Notifications Oat.

1()(11/2011

Agency

COGce

Contact

STEVEN LINDBLOM

Re.pon .. SUBMIT

FORM1g AND

fORM 12

Field Visit/Follow Up Name Phone Date No FIeld VIsit data found.

Final Resolution Oat. Case Closed? Letter sent? coace person

1011812011 Y N STEVE LINDBLOM PLEASE REFER TO REMEDIATION 16S201D0CUMENT '2216561 FOR MORE INFORMATION.

Monday, July 02. 2012

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Page 2 of2

71212012

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COGIS - Spill Reports

COGIS • Spill Reports

Form 19/19A

Date Rec'd: 2/4/2010

1}.R2£

LINDA SPRY Report taken by: OROURKE

yage 1. or ~

DocNum: 2605817

Operator Information API number: 05·1 03 -07632 Facility 10: 229973

Operator:

Address:

Phone:

MARALEX RESOURCES, INC Ope,. No. 53255

POBOX 338 ATTN: JIM GRAVES IGNACIO, CO 81137

(970 )563-4000 Fax: (970 )563-4116

Operator Contact: JIM GRAVES

Description of Spill: Date of InCident: 1212412009 Type of Facility : WELL Well NamelNo. SOLDIER CANYON 25-2 Fac. Name/No. County Name: RIO BLANCO qtrqtr: NENE section : 25 township: 4$

Volumes spilled and recovered (bbls)

OliapUled:

Water 5pllled: 7

Other spilled:

range: 101W

Recvr(l:

Recvrd: 0

Reeved:

meridian : 6

GWImpact1 N Surface water Impact? N Contained within beon? N

Anta and vertl~lltxt.nt of Iplll: 587·Sa FT X 1 -IN

Current land use: OPEN RANGE

Weather conditions: VERY COLO WITH BLIZZARD CONDITIONS

SOIL'Geology description BLAKABIN-RHQNE·WAYBE COMPLEX, CLAY·SIL TY CLAY LOAM

DlstanCli In feet to nearest surface water: 200

Depth to shaUowost GW: 20

Wetlands:

Livestock:

Cause of spill: EQUIPMENT FAILURE

Immediate Response:

6ullclln9S:

Water Wells:

DUMP LINE WAS REPAIRED. THE ENTIRE RELEASE IS CONTAINED TO A SMALL AREA ON THE 'NELL PAD. NONE OF THE PRODUCED WATER HAS BEEN REMOVED SINCE IT IS FROZEN.

Emergency Pits: NONE WERE CONSTRUCTED.

How extent determined: FielD MEASUREMENTS 'NITH A GPS UNIT.

Further Remediation REMEDIAL ACTIONS IMll BE DEPENDENT ON THE ANAL ¥TICAL RESULTS AND RESPONSES 6Y THE BlM ANDCOGCC.

Prevent Problem: 'NELlS IMlL BE CHECKED ON A MORE FREQUENT BASIS DURING PERIODS OF EXTREMELY COLO INEATHER.

Detailed Description: DUMP LINE RUNNING FROM SEPAAATOR FROZE AND CRACKED VoIHICH ALLO'NED PRODUCED WATER TO RUN OUT ONTO THE 'NELL PAD. DUE TO EXTREMELY COLO CONDITIONS THE PRODUCED WATER IS FROZEN IN THE SNOW IN A LAYER 1·1 .5 INCHES THICK.

http://cogcc.state.co.uslcogisiSpillReport.asp?doc _ num~260S 817 7(212012

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caGIS - Spill Reports

Other Notifications 0."

lf29l2Dl0

Field Visit/Follow Up Name No Field Visit <:lata found .

Monday, July 02, 2012

Agency

COGCC

ContaCI

LINDA SPRYOROURKE

Phone

Response NOTIFIED OGCOF RELEASE AND BlM

INC DETAILS

Date

htto://co.cc.state.co.us/co.islSoillReoort.aso?doc ourn=2605817

Page 20f2

71212012

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COGIS - Spill Reports

COG IS - Spill Reports

Form 19/19A

Date Rec'd: 1213112007 Report taken by: KAREN SPRAY

DocNum: 1733121 API number: 05--

Operator Information Operator: MARALEX RESOURCES, INC Oper. No. 53255

Address: POBOX 338 ATTN : JIM GRAVES IGNACIO, CO 81137

Phone: (970 )563-4000

Operator Contact: CHRISTI REID

Description of Spill: Date of Incident: 1212812007 Type of Facility: TANK BATTERY

Fax: (970 )563-4116

Facility ID:

Well Name/No, Fac. Name/No. KATIE EILEEN TANK BATTERY

County Name: LA PLATA qtrqtr: NWNE section: 10 township: 33N Volumes spilled and recovered (bbls)

ou spillod: 0

Water spilled: 50

Other spilled:

GWlmpact? N Surface water Impact? N

Area end vortlcaloxtent of spill: 700FT X 1!i·FT

Current land use: NON-CROP RANGElAND

Woather conditions: ININTER COLO 5-20 DEGREES F

SollfGeology description WILT LOAM

Dlslance in foet to noarest surface waler:

Depth to shallowolt GW: 360

Wotland,:

Llvellock:

Cause of spill: ECUIPMENT FAILURE

Immediate Response:

range: 7W

Rocvrd: 0

Rocvrd: 17

Rocvod:

meridian: N

Contained within berm? N

Buildings: 1089

Water Weill:

DECOMMISSION TANK, SUCKED UP SPill WITH VACUUM TRUCK, REPAIRED BERM AND CONTAINED SPILL

Emergency Pits: NONE How extent determined: VISUAL

Further Remediation REPAIR TANK AND IMPROVE BERM

Prevent Problem: IMPROVE BERN

Oetailed Description: STORAGE TANK LEAKED DUE TO CORROSION.

Other Notifications Dale

1213112007 Agency COGCC

Contact Response V1A FAX

hnp://cogcc.state.co.usicogisiSpiliReport.asp?doc _num= 1733121

l"age 1 or L

71212012

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COGIS - Spill Reports

Operator/COGCC Response Name Phon, Date CHRIST REID SPRA Y 970 ~3,""OOO 11812008 MARALE>: HAS PLANS TO REPAIR THE SECONDARY CONTAINMENT. TRUCK DRIVERS WERE FLUSHING WATER ONTO THE BERM WIOUT MARA-LEX KNOWL.EDGE, CAUSING rr TO BREAK DOWN. WILL SUBMIT A PLAN AND TIME SCHEDULE FOR REPAIRS. MAYBE SOMEWHAT DELA YEO DUE TO MAJOR SNOWSTORM. COGCC WILL WORK Wm-I mEM ON TIMING. .

Field Visit/Follow Up NalT14l Phone Oato SPRA Y 1I3l2008

SECONDARY CONTAINMENT APPEARS INADEQUATE IN VOLUME FOR4 PW TANKS - BERMS ARE BROKEN DOWN AND INSIDE IS SILTED IN sa TIIAT THE BOTTOMS OF ALL CFniE TANKS ARE COVEREDWffi{ SILT. BREAK IN BERM TO SW APPEARS TO BETEMI'QRARlLY REPAIRED WI FROZEN BLOCKS OF DIRT. EVIDENCE OF FREE WATER PONDfNO ON THE GROUND SURFACE. NEEDS FURTHER ASSESSMENT, REMEDIATION AND R£fAIR. SPRAY 612312008

CHRISTI REID HAD INFORMED SW EPS THAT THE BERM HAD BEEN RECONSlRUC'TE.D TO THE APPROPRlA TE SIZE FOR CONTAINMENT. SITE VISIT CONFIRMED CONSTRUCTION· CREWS WORKING TO ARMOR THE BERM WI ORA VEL WHILE ONSITE.

Final Resolution Date NlA

Case Closed? N

Letter Sent? N

COGCC pel'$on KAREN SPRAY

6I29l2OO8 Y N KAREN SPRAY SECONDARY CONTAINMENT BERM VERIFIED AS RECONSTRUC'TEO. NFA AT THIS TIME.

Monday, July 02. 2012

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caUls - Spill Reports

COGIS - Spill Reports

Form 19/19A

Oate Rec'd: 411412006

DocNum: 1953000

Operator Information

Report taken by: STEVE LI NDBLOM

API number: 05-067 -09016 Facility 10:

Operator: MARALEX RESOURCES, INC Oper. No. 53255

Address:

Phone:

P.O. BOX 338 IGNACIO, CO 81137

(970 )563-4000 Fax: (970 )563-4116

Operator Contact: MICKEY O'HARE

Description of Spill : Date of Incident: 1013112005 Type of Facility:

We ll NamelNo.

WELL KEEGAN PATRICK 33-7-11 #2A

County Name: LA PLATA

Fac. Name/No.

qtrqtr: NWSW section: 11 township: 33N ra nge: 7W

Volumes spilled and recovered (bbls)

Oil spilled:

Waler spilled:

Other s pilled:

Rocvrd:

Recvrd: 0

Roeved:

meridian: N

GWlmpact? Y Surface wator Impact? N Contained within berm? N

Area and vertJcalextent of spill: • X •

CUmlnt !.and use: COAlBEO METHANE PRODUCTIONNACANT

Weather conditions:

SolllGoology descrlpUon CLAY LOAM

Dh.tance In foet to nearnt surface water.

Depth to shallowest GW: 15

Wetlands:

Llvostock: 350

Cause of spill: RELEASE OF FLUIDS FROM RESERVE PIT

Immediate Response:

Buildings: 400

Wator wons: 350

DRAINED RESERVE PIT IMTH VACUUM TRUCKS AND RECLAIMED PIT

Emergency Pits:

How extent determined: PERIODIC TESTING OF LANDOWNER'S WATER 'WEll AND TESING OF OTHER DOMESTIC VoIELLS IN THE AREA

Further Remediation CONTINUE TESTING OF LANDOWNER'S AND OFFSET DOMESTIC 'lY'ELLS UNTIL 2 SUCCESSIVE TESTS INDICATE WATER HAS RETURNED TO NORMAL. PROVIDE TREATMENT SYSTEM IN THE MEANTIME.

Prevent Problem: CLOSED RESERVE PIT

Detailed Description: IT APPEARED THAT FLUIDS FROM THE KEEGAN PATRICK 2A UNLINED RESERVE PIT INF ILTRATED INTO SHALLOW GROUNDWATER, FLO\oVED DOIN'NHILl AND IMPACTED THE DAVE THOMSON WATER VoIELt.

Field Visit/Follow Up N.~

No Field Visit data found. Phone Data

hrtp:llcogcc.state.co.uslcogisiSpillReport.asp?doc _ num~ 1953000

t'age J or 1.

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coors -Spill Reports Page 2 of2

Final Resolution Dlte Case Closed? l ottor Sent? COGCC pertlon ~~10 Y N

SEE REMEOIA TION '3680 fOR MORE INFORMATION.

Monday, July 02, 2012

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CUUI S - SpIll Keports t'age 1 01 £

COGIS- Spill Reports

Form 19/19A

Date Rec'd: 8/4/2003 Report taken by: BOB CHESSON

DocNum: 1247726 API number: 05·045 -06127 Facility 10: 210371

Operator Information Operator: MARALEX RESOURCES. INC Oper. No. 53255

Address: POBOX 338 AnN: JIM GRAVES IGNACIO. CO 81137

Phon. : (970 )563-4000 Fax: (970 )563-4116

Operator Contact: JIM GRAVES

Description of Spill: Date of Incident: 8/4/2003 Type of Facility: VVELL Wen NamelNo. RIFLE-BOULTON Fac. NamelNo. County Name: GARFIELD qtrqtr: NWNW section: 23 township: 7$ range: 91W Volumes spilled and recovered (bbls)

Oil spllled:

Water . pll1.c1: 10

Other s pilled:

Rocvrd:

Recvro: 0

Reeved:

meridian: 6

GWlmplct? N Surface water Impact? N Contained wIthin berm? N

Area and vertical extent of spill: 35-FT X 40·FT

Current land use:

Weather conditions:

Soil/Geology d'olcrlptlon

Distance In feet to nearest surface water.

Depth t o Shallowest GW:

Wetlands:

livestock:

C~use of spill: EQUIPMENT FAILURE

Immediate Response: AREA EXCAVED 'MTH BACKHOE.

Emergency Pits: NONE.

How extent determined: VlSUALANO EXCAVATION.

Further Remediation NONE AT THIS TIME.

Prevent Problem: TANK 'MTH LEAK REPLACED AND BERM WAS REBUILT.

Detailed Description:

Building.:

Water We lls:

A LEAK DEVELOPED IN THE BOTTOM OF A 0400 BBL PRODUCED WATER STORAGE TANK. THE BERM AROUND THE TANK DID NOT CONTAlNTHE RELEASE. APPROX. 10 BBL OF WATER LEAKED OUT OF THE BERM AREA AND RAN DO'M'I THE LEASE ROAD. THE WATER EVAPORATED BEFORE DISCOVERY LEAVING A "SALT STAIN".

Field Visit/Follow Up Name Phone Dale No Field Visit data found.

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COG! S - Spill Reports

Final Resolution Date

811 01200' CaseCloud7

y

Monday, July 02, 2012

Letter Sent? N

COGCC person BOB CHESSON

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COUIS - Spill Reports page 1 or L

COGIS - Spill Reports

Form 19/19A

Date Rec'd: 5/10/1996 Roporttaken by: LOREN AVIS

DocNum: 799474 API number: 05·067 ·07392 Facility 10: 215787

Operator Information Operator: MARALEX RESOURCES, INC Oper. No. 53255

Address: 210 GODDARD AVE POBOX 338 IGNACIO. CO 81 137-

Phone: ( ) Fax: ()

Operator Contact: TOMMIE YOUNG

Description of Spill : Date of Incident: 511011996 Type of Facility : Well Name/No. JAQUES 33-8-26 1 Fac. Name/No. County Name: LA PLATA qtrqtr: NENW section: 26 township: 33N range: 8W meridian: N Volumes spilled and recovered (bbls)

0 11 spilled:

Water $pllled: 50

Other spilled:

GWlmpact? Surface water impact? N

Area and vertical extent of spill: • X

Current land use:

Weather conditions:

SoU/Geology description

Olstance In foet to nearest surface water:

Depth to shallowest GW:

Wetlands:

Livestock:

Cause of spill : Tank Battery

Immediate Response:

Emergency Pits:

How extent determined:

Further Remediation

Prevent Problem:

Detailed Description :

Recvrd:

Recvrd: 40

Reeved: Contained within berm? Y

Buildings:

Water Wells;

GROSS 50 BW, NET 10 BW. THE ALTERNATOR WENT OUT AND ALLOVv'EO PRODUCED WATER TO BE SPILLED 'MTHIN THE BERM SURROUNDING THE TANK. AlL FLUID WAS CONTAINED IN THE BERM, 40 eBLS VACUUMED UP. (Uploaded from tSplll)

Field Visit/Fo llow Up Name No Field Visit data found.

Final Resolution Oate

1213111996 Caso Closed?

y

Marked closed 111912000

Phone

Letter Sent?

Dato

COGCC person LOREN AVIS

http://cogec.state. eo. us! eo gis!Spi JlReport. asp ?doe _ num~7994 7 4 71212012

Page 53: :r'1A V'l1 ' If.~yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings... · 3. Ms. Victoria Schmitt, Planning Engineer La Plata County 1060 E. 2" Avenue Durango, CO 81301 Ms. Schmitt is employed

COGIS - Spill Reports Page 2 of2

Monday. July 02, 2012

httn:llcmlcc.state.co.us/coeisiSoiIIReoort.aso?doc nwn=799474 71212012

Page 54: :r'1A V'l1 ' If.~yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings... · 3. Ms. Victoria Schmitt, Planning Engineer La Plata County 1060 E. 2" Avenue Durango, CO 81301 Ms. Schmitt is employed

COUI~ - ~pill Reports page J or L.

COGIS - Spill Reports

Form 19/19A

Date Rec'd: 4/30/1996 Report taken by: LOREN AVIS

OocNum: 799493 API number: 05-067 -07996 Facility 10: 216390

Operator Information Operator: MARALEX RESOURCES, INC Oper. No. 53255

Address: 210 GODDARD AVE POBOX 338 IGNACIO, CO 81137-

Phone: (303 )290-8700 Fax: ( )

Operator Contact: JIM GRAVES

Description of Spill : Date of Incident: 4/3011996 Type of Facility: Well Wen Name/No. RICHMOND-FOXY 1 Fac. Name/No. County Name: LA PLATA qtrqtr: SWSE section: 15 township: 33N range: 8W meridian: N

Volumes spilled and recovered (bbls)

011 spilled:

Water spilled: 30

Other spilled:

GWlmpact? Surface water Impact? N

Area and vertlcal extent of spill: • X

Current lind use:

Weather condltlons:

SolL'Geology descriptlon

Distanetl In feet to nearest surhlu water:

Depth to shallowest GW:

Wetlands:

livestock:

Cause of spill:

Immediate Response:

Emergency Pits:

How extent detennlned:

Further Remediation

Prevent Problem:

Detailed Description:

Recvrd:

Recvrd: 0

Recvod: .

Contained within bonn? Y

Buildings:

Water Wells:

GROSS 30 aw, NET 30 aw. WATER TRUCK FILLING RECIEVING TANK. THE FILTER WAS CLOGGED AND THE WATER OVERFLOV'I'ED THE TANK. THE TRUCK WAS SHUT DOINN AND THE WATER CONTAINED IN THE BERM WAS AlLOWED TO EVAPORATE. DRIVER TO MONITOR UNLOADING MORE CLOSELY. (Uploaded from ISplll)

Field Visit/Follow Up Nam. No Field VISit data found .

Final Resolution Oat. Case Closed?

1213111996 Y Marked closed 111912000

Phon.

Lottar Sont?

Date

COGCC per'1'on LOREN AVIS

http://cogcc.state.co.uslcogisiSpillReport.asp?doc_Olun=799493 71212012

Page 55: :r'1A V'l1 ' If.~yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings... · 3. Ms. Victoria Schmitt, Planning Engineer La Plata County 1060 E. 2" Avenue Durango, CO 81301 Ms. Schmitt is employed

COGIS • Spill Reports Page 20f2

Monday. July 02, 2012

httn:lleooee. state. co. us! eOQis!Soi llReoort.aso ?doc n urn~7994 93 7(2(2012

Page 56: :r'1A V'l1 ' If.~yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings... · 3. Ms. Victoria Schmitt, Planning Engineer La Plata County 1060 E. 2" Avenue Durango, CO 81301 Ms. Schmitt is employed

COGIMS - Field Inspection Report Page I of I Complainant's Exhibit 20

COG IS - Field Inspection Report

Illil-+<t Relatgg • ills. ~Doc API Number: 05-067-091 94 Name:DARA FERGUSON INJECTION #1

Location: SWNW 32 33N 9W Lat: 37.03423 Long: -107.51228

Operator #: 10119 Operator Name: MARALEX DISPOSAL LlC

Inspection Date: 1/3/2008 Inspector: KAREN $PRA Y Inspection was. Unsatisfactory

Insp_ Type: ES Brhd. Pressure: Violation: Y

Insp. Stat AC Inj. Pressure: NOAV Sent: N

Reclamation (Pass, Interim or Fail): P&A (Pass/Fail): T~C Ann. Pressure: UIC Violation Type: Date Corrective Action Due: Date Remedied:

Field InSDection CQmmen~s and Observations Insp. Comment InspectionNiolation Comments

ACTION REMOVE UNUSED EQUIPMENT (603.J), PROPERLY DISPOSE OF WASTES IN SILVER TANK (907A,D & E).

FENCECOMMENT AROUND MAIN PAD AREA.

NEW BERMS AROUND 2 STL TANKS IN RESPONSE TO RECENT FIREWALL SPILL; LOOKS GOOD, BUT MAY BE POROUS. NEED TO FOLLOWUP

AND DETERMINE IF THEY HOLD FLUIDS.

GENHOUSE OK. UNUSED SILVER STEEL TANK AND GREEN BUILDING NEED TO BE REMOVED FROM SITE.

STORMWATER PIPE NOTED ROUTING FLOW FROM PAD TO A POINT

MISC WHERE IT DROPS INTO A NEARBY CANYON. NEWlY INSTALLED. ALREADY SHOWING SIGNS OF EROSION. NEED TO RECHECK AND SEE IF CREWS INSTALLED RIPRAP OR EROSION CONTROLS.

INSPECTION IS IN RESPONSE TO SPILL # 1733122. STILL EVIDENCE

SPILCOM OF OFFSITE FLOWOF pw. REPAIRS APPEAR ADEQUATE, BUT NEED CONFIRMATION OF BERM IMPERMEABILITY. FOLLOW-UP INSEPCTION NEEDED.

SURFRH CREWS WORKING WHILE ON SITE.

TANKBAT 2 STLIN USE FOR PW; 1 SILVER UNUSED (ALLEGEDLY HAS FRAC FLUIDS STORED IN IT)

http://cogcc.state.co.us!cogislFieldlnspectionDetaiI.a: .p?doc _num=200 125666 7/2/201 2

Page 57: :r'1A V'l1 ' If.~yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings... · 3. Ms. Victoria Schmitt, Planning Engineer La Plata County 1060 E. 2" Avenue Durango, CO 81301 Ms. Schmitt is employed

Mail to: Secretary of State Corporations Section

1660 Broadway, Suite 200 Denver. CO 80202

(303) 894.2251,

Complainant' s Exhibit 21

For offico use only

MUST BE TYPED FILING FEE: $50.00

Fax (303) 89 .... 2242 951082154 H '50.00 SECRETARY OF STATE 06-26-95 11:11

MUST SUBMIT JYiQ. COPIES

Plea •• Include a typed •• If_addres.ed envelope

ARTICLES OF ORGANIZA liON

IM'e the uoder~ned Miura' perwn(.j of the -sI' of elghleen year. or more, acting •• organlz8f(') of. limited liability QOITlfMI"'Y I8Mr the- Color~ Um/ted U,bIIlty Company Ad, tdopt the IoIIoWIng Mid •• of Organb:,tlon tor .uc;:h limlled liability --FIRST: ,

seCOND:

THIRD:

FOURTH:

FIFTH:

The neme 01 the \imlted labiLity ~y II: -,M~'~"~I~e~'~O~I~s~po~"~l~.c.hl~lC,-__ ..,... _____ _

PrindPlt ~ of bullnen (If knoYm): __ -<'~l0!2G~o~dd~,~,~d~A~v~e~n~u~e __________ _

Ignac1Q CO 81137

The ,Ir.-" .dcIr"~ of the initial rl\ll,llIed ol'k' 01 the Hmlt.d Illbllity COInpil"Y I, : ~S~'~m~e ____ _

The miMing address ~f clifl'erent from aboVe) of the initial regi.tered orfice 01 the 6mited labmly COrTIpIUl)' I,: Some

The name of Its ptOpOSecI registered IIgenlln Colorado lit th;It IIddreu is: A M 0' Hare

.L Th. management II vested In managers (check If Ippropri.le)

The names and business addresses of !he lnitial manager or managers or If the management Is vested In the membefl, flIther lllan m.nI1lIB, the name. and addresses of the member or "members ire:

NAME ADDRESS (Include :tip codes)

A. H Q'Hare 15682 Highway 172. IgnaCiO, CO 8 1137

SIXTH: The name and eddress of each organizer I. :

NAME

A M O' Hore

.. ~-... - --

ADDRESS (Includ. zip code)

Same

s~r=~~--------------__ Organtzllr

Page 58: :r'1A V'l1 ' If.~yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings... · 3. Ms. Victoria Schmitt, Planning Engineer La Plata County 1060 E. 2" Avenue Durango, CO 81301 Ms. Schmitt is employed

Complainant's Exhibit 22

fOIl OYl'ICI un OHLY

SSF ..... OI (Rev.7/l/89)

TOTAL o,'cu s 50 . 00 MUST II TTPI ... ~N (1UC1t)

SUIWIT OAlOIN4L Al'fD ONt: COPY

MAIL TO: Colorado Scerctary of Sta~

CQrporatioal omce 1560 Broldway. Siliu: 200

0."'«", CO 80102-(303) 894·1151

ARTICLES OF INCORPORATION JlWe the undenianed utUfll penon(l) of the l&e of eiahu:en yean Of

men. actina u inoorpontor(s) ofl corporatiOll under the Colorado Corporation Code, adopt the followinl Artkln of Incorpondoa fot such cOtpOl'ltion:

12-01-89 89110'1455

FIRST: The name 01 the OOI'pOrlition II Maralex . Enterprises , Inc

12:28 $50.00

SECOND: The period of duratioa if other than perpetual: _,"""'""""""""'?U' _____ ____ _

nn:RD: The Corporation Ia orpnized for Any Lela! aDd Lawful Purpose ~Ultlt to the Colorado CorpOl"l1io!l Code. A mote specifIC purpose ml)' be ItltM .

FOURTH: The aurtpte !lwuber of .hare. which the oorporation sh&ll hive the IUthority to iuue is 100,000 and the p&r vlhle of eacb 'hart 'hall be .... 0<....\00":'""_,..;;,,,,,... __ rot __ .. ....... _ 'i

FIFTH: Cumulative votina shires of stock II_~_:;;'- IUlhoriud.

SIXTH: Provilionllimitinl ordenylnl to shareholders the preemptive niht to lequire additional or treullf)' $hares of the corporation, it any, are: NOOe

SEVENTl;I: The addrUI 01 the initial ~plterod officc of tho cotpOrlltK:o is 7222 S . Alli9a'l \-lay T.1 ttletm. <nlO!J"\? 80123 _____ ._ l .. ___ ~ i_ .. o; ... &;;_tiPf;OOI.l

and the name of its initial re&lltered agent It such addreu il Alexis M Q'Hara EIOHTH:AddrcuoftheplaceofbllSineu: P 0 I'!rnr 620616 T.ittletpn. O? 801 6 2 ,._ .... _ ..... , NINTH: The number of dircetors cormitutina the initial board of director1 0( the corporation is ® (2) and the n~ and Mkiresles oftbe persons who are to lene u direccOl'l until the tirst

lnDuaJ meetiul of share holden or until their IUCCC. SOrs ate ejected and shan qualify are:

The number or dlrecton or .. corporlilion shill be not less lhl n three; except tblt the re need be only u manydlreclOl'I u there .te, or InItially will be, Iharcholden: In tbc n-ent Ih.t the ouUtlndln& Ihares are, ot Initially will be, beld of record by fewer thin tbn:e sbarebolders.

NAMe ADDRESS (intlude lip code)

Mary catherine O'Hare 7222 S. Allison l'fay, Littleton, CO 80123

'Pw" Michael Q'!i!lre ""'"

TENTH: The name and a~ of each incorporator Is:

NAME '

Alexis Michael 0' Rare

ADDRE 55 (Include lip code)

7222 S. Al.l.iston Way, Littleton, CO 80123

Signcd _____________ _

s~~ ____________ ~---------

COMPUTER UPDAll eoMamt • . :---- RA ."

Page 59: :r'1A V'l1 ' If.~yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings... · 3. Ms. Victoria Schmitt, Planning Engineer La Plata County 1060 E. 2" Avenue Durango, CO 81301 Ms. Schmitt is employed

Complainant 's Exhibit 23

A:"" Dol (_. IIUI ............. I'iiot IW:~ .10. 00 TlIio ___ __

t.~,f,~t

MAlL TO: C*",do Secreca'1 or State

eorpor.tlons Otfb 1560 Bro.cIw.y. Suitt 200 D.GYa', Coknc:Io 10201

(303).156 13(11

ny~/ ARTICLES OF AMENDMENT

10 the ~ ".-TtCLES OF INCORPORATION

PunuuIt 10 11M PfO'+'b;IoaI of the CoIondo Coq:ooratioII Cod.,1IM undenlpled c:orpor1Itlon acIopu tbc f'oIIowIaJ ArtKkJ of ... t 10 ila Artkkl 0( lPooo ..... '\c",'

PDI.S'n Tbt IWIMI 0( the c:orponQ II (DOlt I ) Maral.x Enterprhe. , Inc. n <!.£>

SECOND: The ~ amendment 10 the Artida ofiJleotpotatioQ .... ., adopu4 (III J anuary 7 , I' ~ .. prpaI"t.d by tile Colorado Cotpotatioll Code, ill the m&IIIICf nwtod with &II X below:

_x_ Sueh • ' nt ...... adopted by tile board of dirKlOrl where AO ,/ .... .,. line beet! iuucd.

__ ~ amcodInenl wu adopted by • YOie 01 the .lIareholdc .... TIM JI\III'Ibcr o(.h.aru ¥Oled !'or the amclldmeot ""u ...mau.lror~

Henceforth I the name of the ColDpal1y ahall be MaraIe" Resource. I Inc .

'llHt COI!IpIUlY 'U lifO'll h\',"'. ",\(l~'1 addroaa ia: 518 17th Street , Suite 1030 , Denver, CO 60202.

THlRD: n. _rr I( DOt Nt Corth Ia wc:h UMnr.ImeDI, III wbldI &/I)' ~ ,..;laaaiIlcatiooI. Of ~11ttioa 01 ~ sh&ra pfOridcd for In 11M amaxlmcallII.D be dl"cc:uld, ill .. rollows: Unaf't'acted.

POURTH: n.. IlWlIIU In wbleb ~h anMndment elf"" I ch'III' In the amounl oratated npital, .nd Ihc amount of ~ ~ .. ~ by II\dI M\CJIdIIIent,.,.. .. tollow1:; Unatre<:teoj.

... , . •

. "",

.,.-_,,= (NOIe 1)

(Nou J)

Nons: I. £act ~IC ..... 0( ~11001 fodo$>d", III, AnkLn or A .... nd_.u. (If 11111 I, • chua. 01 ...... ___ .c 11M _ kIon IIoIt .-..... , It Nod)

L S~ """ tkko vI..tnc... dpl .. r .. tM c.orponclo& 3. WIoocn 110 Para Iu ... Moe. INMI1. ~l'R vi. 61Rew. rnuPIlTER UPOAlE COMPl!T!