The URL can be used to link to this page

Browse Search

Home My WebLink About20160955.tiff Sterling Energy Investments , LLC Hemberger Compressor Station County Road 105 Weld County , Colorado Contact Name : Sean Miller Telephone : ( 970 ) 522-5101 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN PREPARED : April 27 , 2015 Prepared by: Kleinfelder, Inc. 1801 California Street, Suite 1100 Denver, CO 80202 Original Date of Plan : April 27, 2015 Date of Plan Review or Plan Amendment: Date of Last P.E. Certification : Copyright 2015 Kleinfelder Ali Rights Reserved UNAUTHORIZED USE OR COPYING OF THIS DOCUMENT IS STRICTLY PROHIBITED BY ANYONE OTHER THAN THE CLIENT FOR THE SPECIFIC PROJECT. Hemberger Compressor Station Page i of xiii SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLE/NFELOER &fight ftopte Right SoJurors. WHAT IS COVERED IN THIS SPCC PLAN ? • This plan only covers oil storage and handling equipment at the Hemberger Compressor Station , which is owned and operated by Sterling Energy Investments LLC (Sterling), including: o One 153-bbl slug catch, o One 22-bbl inlet separator, o Three 15-bbl compressor inlet/outlet separators, o Three 275-gallon lube oil tanks, o One 500-gallon compressor fluid tank, o One 500-gallon red diesel tank, o Two 55-gallon lube oil drums, and o One 200-gallon waste oil tank. WHAT IS NOT COVERED IN THIS SPCC PLAN ? • Oil storage and handling equipment that is not owned/operated or owned/leased by Sterling but may be located at the facility (e.g . , mobile refuelers), is not covered in this plan . • Completely buried underground storage tanks that are subject to 40 CFR §280 or §281 ; however, aboveground transfers to/from these tanks are covered in this plan and the tank locations are shown on the site plan . • The facility operates motor vehicles that provide their own means of propulsion (e.g . trucks, automobiles, etc.). The definition of these motive power containers was clarified in Federal Register ( FR) 77266 (December 26, 2006) , and motive power containers are specifically exempted. The capacity of the motive power fuel sources is not included in calculation of the oil storage capacity of the facility. Hemberger Compressor Station Page ii of xiii SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder (K-LEINFELDER Sire rwd. •r!Inn PROFESSIONAL ENGINEER'S CERTIFICATION STATEMENT FACILITY NAME: Hemberger Compressor Station FACILITY ADDRESS: 40.63353 N1104.06778 W, Weld County, CO l hereby attest in accordance with 40 CFR § 112.3(d) that: (1) I am familiar with the requirements of the SPCC Rule at 40 CFR § 112; (2) 1 or my agent have visited and examined the facility; (3) The SPCC Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of 40 CFR § 112; (4) Procedures for required inspections and testing have been established; and (5) The SPCC Plan is adequate for this facility. Signature: -_----- Printed Name: 4t3 Hecr } Title: crcpFF Et r,-, .= • DO l.! `'l Date: C:�S1lAnis f c,0,•,�N .loytis ea ",, : 1 . 1 Z:• F Registration No: 185'7 , : : : 57• • a State: LaoRAoo I' �,:•• 1 ,%9\11P s.;CS. 'I It SS/ONAI. t The Engineering Certification does not relieve the owner/operator of the facility herein described of the duty to prepare and fully implement the SPCC Plan in accordance with all applicable requirements. Hemberger Compressor Station Page iii of xiii SPCC Plan 20155174/DEN15O18231 April 2015 2015 Kieinfelder KLE/NEELDER 8gnt F I I* fitr Sotvtrorn PROCEDURES FOR A SPILL RESPONSE 1 . STOP THE RELEASE If such action can be performed without risk of injury, stop the release at the source (e.g., close valve on tank truck; push emergency stop for fuel system, upright the container, etc.). Note: Direct contact with oil products should be avoided. 2. CALL AND EVACUATE NON-RESPONSE PERSONNEL Determine the severity of the spill or leak and CALL 911 if there are injuries or a spill/leak is of a significant quantity to warrant Fire Department Hazardous Materials Team (e.g., approximately 42 gallons or more of oil/fuel have been released). 3. CONTAIN THE SPILL If the spill is threatening structures, storm or sanitary drains or bare soil AND if such action can be performed without risk of injury, the reporting party will attempt to contain the spill: a. Inspect secondary containment, if present, to verify that liquid is not visibly seeping through walls b. For spills outside passive secondary containment, such as fuel transfers, contain the spill using absorbent socks or by building a temporary dike with granular absorbent. 4. REPORT TO RESPONDING PARTIES Remain in a safe location near the spill site and report to Sean Miller and/or Rodney Barnes upon their arrival. 5. CONTROL ACCESS AND FIRE HAZARDS Control access to the affected onsite areas (e.g. barricades and traffic controls). If it is safe to do so, shut off electricity, gas service, and other sources of ignition. Prohibit smoking. If a fire ensues and the conditions are safe, use the fire extinguisher. Otherwise , call the Fire Department. 6. CLEAN UP THE SPILL After fire and safety hazards are under control, spill clean-up crews will be allowed into the area. The crew shall have the necessary materials and/or equipment to restore the area to a state reasonably equivalent to its condition prior to the spill. 7. PREPARE SPILL/INCIDENT REPORT FORM The Facility Response Coordinator (FRC) will be responsible for the completion of the Spill/Incident Report Form in Appendix D. 8. REPORT TO APPROPRIATE REGULATORY AGENCIES If the spill or leak of the fuel/oil or contaminated water is of a reportable quantity, the FRC will be responsible for reporting the incident to the appropriate regulatory agencies within the specific timeframes required by the regulation. (See Discharge Reporting, Section §112.7 (a)(4)). Hemberger Compressor Station Page iv of xiii SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kieinfelder KL E/NFEL DER EMERGENCY RESPONSE CONTACT INFORMATION Facility Responders Rodney Barnes Facility Response Coordinator (FRC) (720) 881 -7775 office (303) 589-6214 mobile Sean Miller Alternate FRC (970) 522-5101 office (970) 520-5717 mobile Sean Miller Facility Manager (970) 522-5101 office (970) 520-5717 mobile Shawna Moser-Mese Safety Officer (970) 768-1113 mobile Regulatory Agency Telephone Number Local Fire, Police, and/or Paramedics 911 National Response Center 1 -800-424-8802 or (202) 267-2675 U.S. Environmental Protection Agency (415) 744-2000 U.S. Coast Guard (510) 437-2940 or (800) 424-8802 Colorado Department of Public Health and 1 .877.518-5608 Environment Response Contractor 1 Telephone Number Belfor Environmental (24-hour responder 1 -800-930-0011 and cleanup activities) Kleinfelder (Site characterization and (303) 237-6601 cleanup coordination) Hemberger Compressor Station Page v of xiii SPCC Plan 20155174/DEN15018231 April 2015 © 2015 Kleinfelder KLEINFEL DER Bright l*oP it AISS"Sohitfornz DISCHARGE REPORTING The following information must be provided in the discharge report (Appendix D): • The exact address or location and phone number of the facility; • The date and time of the discharge; • The type of material discharged ; • Estimates of the total quantity discharged ; • Estimates of the quantity discharged as described in 40 CFR § 112. 1 (b); • The source of the discharge; • A description of all affected media; • The cause of the discharge; • Any damages or injuries caused by the discharge; • Actions being used to stop, remove, and mitigate the effects of the discharge; • Whether an evacuation may be needed ; and • The names of individuals and/or organizations who have also been contacted . Hemberger Compressor Station Page vi of xiii SPCC Plan 20155174/D EN 15O18231 April 2015 © 2015 Kleinfelder KL EINFEL DER -qht ftopk Righl Sotut'Crrs Reporting Agency Reportable Quantity Deadline Type of Report National Response Any release of oil to a navigable Immediately Telephone Center water unless exempted (800) 424-8802 EPA Region Viii A discharge of 1 ,000 gallons of 60 days Written oil into or upon navigable waters in a single spill event or US EPA — Region 8 1595 Wynkoop St. A discharge of oil more than 42 Denver, CO 80202 U.S. gallons into or upon navigable waters in each of two spill events occurring within any 12-month period Colorado Oil and Spills/releases of any size that Verbal Telephone Gas Conservation impacts or threatens to impact notification (303) 894-2100 Commission any Water of the State, a within 24- (COGCC) residence or occupied structure, hours; livestock, or a public byway. written report Written: within 10- Colorado Oil and Gas days. Conservation Commission 1120 Lincoln Street, Suite 801 Spills/releases >5 bbl, including Verbal Denver, CO 80203 those contained within lined or notification unlined berms. within 24- hours; written report within 10- days. Spills/releases >1 bbl but <5bbi Verbal NOT contained within a berm or notification secondary containment. within 24- hours; written report within 10- days. Spills/releases >1 bbl but <5 bbl No verbal or and contained within a berm or written secondary containment. notification necessary. Spills/releases <1 bbl. No verbal or written notification necessary. Hemberger Compressor Station Page vii of xiii SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KL EINFELDER Reporting Agency Reportable Quantity Deadline Type of Report Colorado Any spill that enters waters of the Immediately Telephone Department of State. (877) 518-5608 Public Health and Environment CDPHE recommends releases Written: (CDPHE) be reported immediately even if Colorado Department of the quantity of the release has Public Health and not yet been determined. Environment 4300 Cherry Creek Drive South Denver, CO 80246 Hemberger Compressor Station Page viii of xiii SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KL EINFEL DER &*gh croak.MO'Soatt n DOCUMENTATION OF PLAN REVIEW BY OWNER OR OPERATOR The Spill Prevention Control and Countermeasure (SPCC) plan is a carefully thought- out plan , prepared in accordance with good engineering practices, and has the full approval of management at a level with authority to commit the necessary resources. The SPCC plan follows the sequence outlined in the Code of Federal Regulations (CFR) Title 40 Parts (§) 112.7 and 112.8 (40 CFR § 112 .7 and 112 .8), and includes a discussion of the facility's conformance with the appropriate guidelines listed. A copy of the SPCC plan is available for on-site review by the EPA Regional Administrator (RA) during normal business hours at the following location : Owner/Operator: Sterling Energy Investments, LLC -- Yenter Office Address: 17598 County Road 21 City/State/Zip: Sterling, CO 80751 Telephone: 970-522-5101 This facility is attended two hours per day by Sterling personnel . The facility location is depicted on Figure 1 . The SPCC plan has been prepared to meet applicable state and federal requirements by addressing potential discharges resulting from operations performed . Title 40 CFR §112. 5(b) requires the owner or operator to complete a review and evaluation of this SPCC plan at least once every five years. Owner/operator information is as follows: Owner/Operator: Sterling Energy Investments, LLC — Main Office Address: 1200 17th Street, Suite 2850 City/State/Zip: Denver, CO 80202 Telephone: 720-881 -7100 As a result of this review and evaluation , the owner or operator "must amend this SPCC Plan within six months of the review to include more effective prevention and control technology if the technology has been field-proven at the time of the review and will significantly reduce the likelihood of a discharge ." Any amendment must be implemented as soon as possible but not later than six months after preparing the amendment. The owner or operator must document completion of the review and Hemberger Compressor Station Page ix of xiii SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLE/NFELOER t .Right��s. evaluation , and must sign a statement as to whether the SPCC plan will be amended . Administrative changes (such as names and telephone numbers) do not require Professional Engineer (RE. ) recertification . Technical amendments require a P. E. recertification . The Plan Review and Amendment Log are included in Appendix A. The Engineering Certification for this SPCC plan is included inside the cover page. Management Certification for this SPCC plan is included in Section 1 .3 of the SPCC plan . The next required management and engineering certification will occur within five years in 2020. Hemberger Compressor Station Page x of xiii SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLE/NFELOER bight fropte. Right Sofulioos. LIST OF ACRONYMS Part AST Aboveground Storage Tank CFR Code of Federal Regulations CP Cathodic Protection EPA United States Environmental Protection Agency FRC Facility Response Coordinator GPM Gallons Per Minute MSDS Material Safety Data Sheets NRC National Response Center OSCP Oil Spill Contingency Plan OPA Oil Pollution Act P. E . Professional Engineer PPE Personal Protective Equipment POTW Publicly-Owned Treatment Works RA EPA Regional Administrator RCRA Resource Conservation and Recovery Act SPCC Spill Prevention Control and Countermeasure SWPPP Stormwater Pollution Prevention Plan U .S. United States of America USACE Army Corps of Engineers Hemberger Compressor Station Page xi of xiii SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder I KLE/NFELOER 8nght People Right Soprtiont SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN HEMBERGER COMPRESSOR STATION WELD COUNTY, COLORADO TABLE OF CONTENTS Chapter Page What Is Covered In This SPCC Plan? ii What Is NOT Covered In This SPCC Plan? Il Professional Engineer's Certification statement iii Procedures For A Spill Response iv Emergency Response Contact Information v Discharge Reporting vi Documentation Of Plan Review By Owner Or Operator ix List of Acronyms xi 1 EXECUTIVE SUMMARY 1 1 . 1 Background 1 1 .2 Applicability 2 1 .3 Management Approval 4 2 SPCC PLAN REQUIREMENTS 5 2 . 1 GENERAL Requirements (§ 112.7) 5 §112.7(a)(3)(i) Oil Product Storage 7 §112.7(a)(3) (iii) Discharge or Drainage Controls 8 §112.7(a)(3)(iv) Countermeasures 9 §112.7 a)(3)(v) Disposal Methods 10 §112.7 (a)(3)(vi) Contact List 11 §112.7 (a)(4) Discharge Reporting 12 §112.7 (a)(5) Emergency Response Procedures 15 §112.7 (b) Potential Release from Equipment 17 §112.7 (c) Appropriate Containment and/or Diversionary Structures/Equipment 17 §112.7 (d) Impracticability of Secondary Containment 17 §112.7 (e) Inspections, Tests, and Records 18 §112.7 (f)(1 ) Personnel, Training, and Discharge Prevention Procedures 19 §112.7 (f)(2) Discharge Prevention Contact Name(s) 21 §112.7 (f)(3) Discharge Prevention Briefings 21 §112.7 (g) Security 21 (1 ) Fencing 21 (2) Master flow and drain valves 22 (3) Starter control on oil pump 22 (4) Loading/unloading connection of oil pipelines/piping 22 §112.7 (h) Facility Tank Car and Tank Truck Loading/Unloading Rack 22 §112.7 (i) Field-constructed ASTs 22 §112.7 (j) State and Local Conformance with Requirements and Procedures 22 12.7 (k) Qualified Oil-filled Operational Equipment 22 Hemberger Compressor Station Page xii of xiii SPCC Plan 20155174/DEN 15O18231 April 2015 © 2015 Kleinfelder rKLE/NFELDER e y..t nvcwar Rynr Scam• 2 .2 REQUIREMENTS for Onshore Facilities (§ 112 .8) 23 §112.8 (a) General Compliance 23 §112.8 (b) Facility Drainage 23 (1 ) Drainage from diked areas 23 (2) Diked area valves 23 (4) Alternative drainage 24 (5) Multiple drainage water treatment units 24 §112.8 (c) Bulk Storage Containers 24 (1 ) Construction and material compatibility 24 (2) Secondary containment 24 (3) Secondary containment drainage 25 (4) Completely Buried Tanks 25 (5) Partially Buried Tanks 25 (7) Internal heating coils control 26 (8) Liquid level sensing devices to avoid discharges 26 (9) Treatment facility effluent 27 (10) Corrective action for visible discharges 27 ( 11 ) Mobile or portable oil storage containers 27 §112.8 (d) Facility Transfer Operations, Pumping and Facility Process 28 (1 ) Buried piping 28 (2) Terminal connection 29 (3) Pipe supports 29 (4) Inspections and Testing 29 (5) Warnings and traffic control 29 FIGURES 1 Site Topographic Map 2 Site Plan — Facility Diagram APPENDICES A Plan Review and Amendment Log B Certification of the Applicability of the Substantial Harm Criteria Checklist C Bulk Storage Container, Piping, and Transfer Areas D Spill/Incident Report Form and Spill Reporting Requirements E Training Attendance Forms and Records F Inspection Checklists, Forms, and Records G Oil Spill Contingency Plan (OSCP) - Site Specific Information is in OSCP Figures (Appendix C) Hemberger Compressor Station Page xiii of xiii SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfeider c.., KLEINFELDER fright Rwpte Righl Sr tons. 1 EXECUTIVE SUMMARY 1 . 1 BACKGROUND A Spill Prevention Control and Countermeasure (SPCC) Plan is required at any facility subject to the requirements of the Code of Federal Regulations (CFR) Title 40 Part (§) 112 (40 CFR § 112). SPCC plans are developed using existing laws, regulations, rules, standards, policies and procedures relating to relevant safety, fire prevention , and pollution prevention standards. The purpose of the SPCC plan is to outline the requirements and procedures to be followed for both the prevention of and the response to oil product and oil waste discharges. This SPCC plan was prepared to reduce the potential for oil spills into waterways of the United States, to prevent accidental releases of oil to the environment, and to provide emergency response information in the event of a release of oil. The Certification of the Applicability of Substantial Harm Criteria was evaluated for this facility and a Facility Response Plan was not required, based on site conditions (see completed Certificate of The Applicability of Substantial Harm Checklist in Appendix B). The CFR Title 40 §112 . 1 (b) describes that a SPCC plan is required for "any owner or operator of a non-transportation-related onshore or offshore facility engaged in drilling , producing , gathering , storing , processing , refining , transferring , distributing, using , or consuming oil and oil products, which due to its location , could reasonably be expected to discharge oil in quantities that may be `harmful' . . . into or upon the navigable waters of the United States or adjoining shorelines, . . . or that may affect natural resources belonging to, appertaining to , or under the exclusive management authority of the United States. . . that has oil in : (1 ) any aboveground container; (2) any completely buried tank as defined in § 112.2 ; (3) any container that is used for standby storage, for seasonal storage, or for temporary storage , or not otherwise "permanently closed" as defined in §112.2 ; or (4) any "bunkered tank" or "partially buried tank" as defined in §112.2 , or any container in a vault, each of which is considered an aboveground storage container for purposes of this part." Hemberger Compressor Station Page 1 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KL E/NFEL DER &qN Rroph•.Right Solution; United States (U .S . ) Coast Guard reporting requirements are outlined in 33 CFR §153 including procedures for notification , removal actions, and costs associated with removal . Definitions and the content of applicable sections of 40 CFR § 110, 40 CFR § 112 and 33 CFR §153 are included in Appendix C . Discharges of oil in such quantities that the Administrator has determined may be "harmful" to the public health or welfare or the environment of the United States as defined in 40 CFR §110.3 include discharges of oil that either violate applicable water quality standards, or cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines, or that causes a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines. It is our understanding that the definition of "navigable waters of the U .S." has undergone regulatory scrutiny, and the U .S . Environmental Protection Agency ( EPA) and the Army Corps of Engineers (ACME) have developed a guidance document for Clean Water Act jurisdiction (5). The guidance document allows the agencies to decide jurisdiction over "non-navigable tributaries that are not relatively permanent" based on a "significant nexus" analysis . 1 .2 APPLICABILITY Kleinfelder professionals and Sterling management have prepared this SPCC plan in accordance with the requirements of Title 40 CFR § 112 as amended July 17, 2002 , December 26, 2006 , December 5, 2008, and November 5, 2009. The State of Colorado does implement the federal SPCC regulations. The Hemberger Compressor Station is a natural gas compressor station . The site is located off of County Road 105 in Weld County, Colorado. The general topography of the site and site vicinity is depicted on Figure 1 . A site visit was conducted on July 14, 2014, by Derek Veazey, (Kleinfelder) to evaluate oil storage at the facility. Five process flow through vessels, six aboveground storage tanks (ASTs), and two 55-gallon drum storage containers are on location , which meet the applicability requirements for inclusion in this SPCC plan . The oil storage locations are depicted on the site diagram (Figure 2). Hemberger Compressor Station Page 2 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KL EINFEL DER `r..� Bnght People Right Solution; Oil is broadly defined in 40 CFR §112 to include petroleum , fuel oil , sludge, synthetic oils, mineral oils and other oil products and waste. Sterling stores oil products and/or oil waste in aboveground storage containers with capacities greater than 55 gallons. The facility stores a maximum of approximately 11 ,375 gallons of oil product on-site. Therefore, the volume of aboveground storage of oil products stored onsite exceeds the 1 , 320-gallon threshold requirement established in 40 CFR § 112. In general, runoff at the site flows to the southeast corner from the center point of the site. Stormwater discharged from the site may eventually reach an unnamed pond , which is located approximately 0 . 11 miles southwest of the facility. Rodney Barnes at (303) 589-6214, will serve as the Facility Response Coordinator ( FRC) and Sean Miller at (970) 520-5717, will serve as the Alternate FRC. The general responsibilities of a FRC under this SPCC plan are to: • Be familiar with emergency procedures for the facility and community; • Assign response team personnel ; and • Initiate annual emergency procedure review. The FRC will be the primary point of contact for questions concerning this SPCC plan . Specific information on available equipment and manpower at this facility is discussed in Section 2 . 1 , Contact List ( 112 .7(a)(3)(vi)). Hemberger Compressor Station Page 3 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kieinfelder KL E/NFEL DER 67,961 Pea"Ptah!Sotut?ors 1 .3 MANAGEMENT APPROVAL Full approval is extended by management at a level with authority to commit the necessary resources toward spill prevention. MANAGEMENT APPROVAL Hemberger Compressor Station is committed to the prevention of discharges of oil to navigable waters and the environment, and maintains the highest standards for spill prevention control and countermeasures through regular review, updates, and implementation of this Spill Prevention Control and Countermeasure Plan for the Facility. Authorized Facility Representative (Printed Name): Signature: Title: Date: Personnel directly responsible for the management of the facility have reviewed this SPCC plan and are committed to implementing the SPCC plan as described herein , including : Signature Printed Name Title Date Nemberger Compressor Station Page 4 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder r^� KLEINFELDER &igy t Pt opk.right sohfioro. 2 SPCC PLAN REQUIREMENTS This SPCC plan follows the format specifications of 40 CFR § 112.7 (a)-(j). The facility will comply with the requirements of 40 CFR §112 .7 unless a deviation is described . 2. 1 GENERAL REQUIREMENTS (§ 112.7) §112.7 (a) ( 1 ) Conformance with the Requirements of 40 CFR § 112 This SPCC plan was prepared to demonstrate conformance with the requirements listed in 40 CFR § 112 , the 2002 Final Revised SPCC Rule and the December 26, 2006, December 5, 2008, and November 5, 2009, Final Amendments to the SPCC Rule. This facility is in conformance with the requirements of 40 CFR §112. §112.7 (a)(2) Deviations from 40 CFR § 112 Deviations) include equivalent measures for providing environmental protection and procedures that were found to be impracticable to implement at the facility. For the purposes of this Plan, deviations also include portions of the facility that may or do not meet the requirements 40 CFR §112 . The facility will address these non-compliant or potentially non-compliant deviations before the time frame specified . Deviations noted following a facility site visit, key individual interviews, and document review includes the following : The SPCC Plan may deviate from the requirements in paragraphs (g), (h)(2) and (3), and (I) of this section and the requirements in subparts B and C of this part, except the secondary containment requirements in paragraphs (c) and (h)(1) of this section, and §§112. 8(c)(2), 112. 8(c)(11), 112, 9(c)(2), 112. 9(d)(3), 112. 10(c), 112. 12(c)(2), 112. 12(c)(11), where applicable to a specific facility, if you provide equivalent environmental protection by some other means of spill prevention, control, or countermeasure. Where the Plan does not conform to the applicable requirements in paragraphs (g), (h)(2) and (3), and (i) of this section, or the requirements of subparts B and C of this part, except the secondary containment requirements in paragraphs (c) and (h)(1) of this section, and §§112, 8(c)(2), 112. 8(c)(11), 112.9(c)(2), 112. 10(c), 112. 12(c)(2), and 112. 12(c)(11), you must state the reasons for nonconformance in your Plan and describe in detail alternate methods and how you will achieve equivalent environmental protection. Hemberger Compressor Station Page 5 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLEINFELDER a,9nt Rope-Right So&iwa. 1 . Liquid Level Sensing Devices — The 500-gallon compressor fluid tank, 500- gallon red diesel tank, 200-gallon waste oil tank and 55-gallon drums are not equipped with a liquid level sensing device. Equivalent environmental protection for the containers is provided by manually gauging each container prior to filling them manually to determine if enough capacity exists in the container. In addition , small containers (e.g. , 5-gallon buckets) may be used to manually transfer oil into the containers and the level inside the containers is continually monitored while the transfer is taking place. §112.7 (a)(3) Physical Layout The facility is located off of County Road 105, in Weld County. For the purposes of this plan , oil storage containers include the following : o One 153-bbl slug catch, o One 22-bbl inlet separator, o Three 15-bbl compressor inlet/outlet separators, o Three 275-gallon lube oil tanks, o One 500-gallon compressor fluid tank, o One 500-gallon red diesel tank, o Two 55-gallon lube oil drums, and o One 200-gallon waste oil tank. The facility also includes three GE Waukesha compressor engines. The associated process equipment for the compressors includes three scrubbers, three inlet separators, and three discharge separators. The site diagram depicting the equipment and physical layout of the facility is included as Figure 2 . The facility site diagram shows the aboveground oil storage areas, underground piping (where present), and the general drainage patterns for the oil storage and handling areas. Hemberger Compressor Station Page 6 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLEINFELDER DER Soght Ptopk.RightSotuVont The site receives approximately less than 10 inches of precipitation annually2, and the predicted 24-hour rainfall for a 25-year storm event for the site vicinity is approximately 3 . 1 inches3. Precipitation generally pools on the ground, infiltrates, or evaporates; however, surface water run-off is generated during larger storm events. In general, runoff at the site flows to the southeast corner from the center point of the site. §112.7(a)(3)(i) Oil Product Storage The facility contains the following aboveground tank(s) and bulk storage containers: o One 153-bbl slug catch , o One 22-bbl inlet separator, o Three 15-bbl compressor inlet/outlet separators, o Three 275-gallon lube oil tanks, o One 500-gallon compressor fluid tank, o One 500-gallon red diesel tank, o Two 55-gallon tube oil drums, and o One 200-gallon waste oil tank. Details on the above-referenced bulk storage containers are provided in Appendix C. §112.7(a)(3)(ii) Discharge Prevention Measures Discharge prevention measures used onsite include: 2 National Oceanic and Atmospheric Administration, Average Annual Precipitation map for Colorado from 1961 to 1990 (http://www.wrcc.dri.edu/pcpn/co.gif). 3 National Oceanic and Atmospheric Administration — National Weather Service, Hydrometeorological Design Studies Center, Precipitation Frequency Data Server, Technical Paper 40 (http://www.nws.noaa.gov/oh/hdsc/PF_documents/TechnicalPaper No40.pdf). Hemberger Compressor Station Page 7 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLE/NEELDER &.jhf Prop/c Right Solut,ons Oil Handling Procedures — Transfers of oil are only preformed in designated areas shown on Figure 2 . Only personnel trained in the safe operation and use of the oil and used oil transfer equipment (e.g . , gauges, nozzles), emergency controls, and procedures to be followed in an emergency are authorized to conduct oil transfers to/from the engine oil , compressor oil, used oil and produced water ASTs. In addition , personnel are required to follow the regulations of the US Department of Transportation under 49 CFR §177 that are applicable to Hemberger Compressor Station operations. Oil Handling Equipment — Most oil handling equipment is visually observed each shift by personnel working in the area and monitored continuously during use. In addition, oil handling equipment also undergoes weekly, monthly, and annual inspections. Loading/Unloading Materials — The delivery driver or fueling personnel are to standby the emergency shut-off system or deadman controls during oil product transfers. If installed , the tanks' liquid level measurement devices are continually monitored by the delivery driver or fueling personnel during loading/unloading . The nozzles used to fill the stand-alone tanks and refuel site equipment are not equipped with automatic shut- offs. Drains are covered during loading/unloading operations. The hand brake will be set on vehicles prior to loading/unloading fuel . No tobacco smoking is allowed while loading/unloading fuel. Tobacco smoking is only permitted in designated areas at the facility. Oil transfer procedures are discussed in greater detail in §112.8(d) of this Plan . §112.7(a)(3) (iii) Discharge or Drainage Controls Discharge or drainage controls (e.g . secondary containment around containers and other structures, equipment, and procedures for control of a discharge) include the following : Secondary Containment — The bulk storage containers at the facility have appropriate secondary containment measures in-place. Hemberger Compressor Station Page 8 of 30 SPCC Plan 20155174/DEN15O18231 551 74/DEN15O18231 April 2015 © 2015 Kleinfelder KLEINFELOER Aright''opk.Right Solution. Pump Cut-Off/Emergency Shut-off Switch —The bulk storage containers and mobile refueling trucks are equipped with an emergency shut-off switch and/or pump cut-off switch that, when manually activated , will terminate the dispensing of oil products to/from the ASTs. Absorbent — If necessary, temporary berms are constructed with the nearby absorbent materials to contain spills or control drainage. §112.7(a)(3)(iv) Countermeasures Countermeasures for discharge discovery, response and cleanup include the following : DISCOVERY Monitoring — Most of the tanks, aboveground piping, and oil storage areas are visually observed at least once per shift by personnel working in the area. If a leak or release is observed , the FRC will be notified , and the FRC will direct the repair or replacement of equipment responsible for releases of oil . There is also a trained person present at all times during oil product handling and transfers. Inspections — Visual inspections of the tanks, aboveground piping , drums and related equipment (e.g. hoses, stands, etc.) are performed at least monthly and annually and a log is maintained . During the monthly and annual visual inspections, the tanks, aboveground piping, drums, and related equipment are inspected for signs of leakage or potential failure, such as drip marks, stains, pools of oil, corrosion , cracks, bulging , gasket deterioration , dead vegetation, foundation settlement, cracks in secondary containment, or other damage. Evidence of leaks or potential leaks will be reported to the FRC. In addition, if facility personnel notice a significant leak during their daily activities, they will notify the FRC. The FRC will direct the repair or replacement of equipment responsible for releases of oil. Hemberger Compressor Station Page 9 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder st' KL EINEEL DER 8 .ght Ropie Riyht Solutions RESPONSE Absorbent — Absorbent materials are readily available at the oil storage and usage areas in the event of a minor release. Assistance — In addition to the fire department, an emergency response contractor has been retained to assist with response efforts, if needed. The contact information for the emergency response contractors is provided on Table 2-1 , Emergency Response Contact Information. Spill Kit — A spill kit is located at this compressor station and contains equipment which may aid in spill response. In addition to the supplies in this spill kit, Sterling personnel have shovels in their vehicles with may be used to construct temporary structures to contain released oil. CLEANUP Assistance — An emergency response contractor has been retained to assist with cleanup efforts, if needed . The contact information for these emergency response contractors is provided on Table 2-1 , Emergency Response Contact Information. §112.7 a)(3)(v) Disposal Methods The FRC or Alternate FRC will be responsible for arranging the disposal of spilled oil and oil-contaminated cleanup materials in accordance with all local, state, and federal regulations. Spilled fuel and oil residue such as contaminated absorbent material and wash-down water could be a regulated hazardous waste and governed by the Resource Conservation and Recovery Act (RCRA). This type of waste, once containerized , should be sampled and analyzed for RCRA constituents and characteristics. The FRC or Alternate FRC should be contacted for assistance in maintaining compliance with environmental regulations during clean up and disposal of the spill debris. If required , the FRC or Alternate FRC will contract with the facility's hazardous disposal contractor for testing and/or proper disposal of the spilled material to ensure compliance with environmental regulations. Hemberger Compressor Station Page 10 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kieinfelder KL EINFEL DER &yht ftroPhc R;gig SoA tnen Stormwater accumulating in the oil storage secondary containment areas (e.g. curbed areas, containment pallets) is normally allowed to evaporate. If a secondary containment area needs to be emptied , the liquid is pumped out and sent to an approved disposal/recycle contractor. §112.7 (a)(3)(vi) Contact List A contact list, which includes the telephone numbers for the FRC, National Response Center and cleanup contractors with whom Sterling has an agreement to provide emergency response actions, and appropriate federal and state agencies are provided on Table 2-1 . TABLE 2-1 CONTACT LIST Facility Responders Rodney Barnes Facility Response Coordinator (FRC) (720) 881 -7775 office (303) 589-6214 mobile Sean Miller Alternate FRC (970) 522-5101 office (970) 520-5717 mobile Sean Miller Facility Manager (970) 522-5101 office (970) 520-5717 mobile Safety Officer Shawna Moser-Mese (970) 768-1113 mobile Regulatory Agency Telephone Number Local Fire, Police, and/or Paramedics 911 National Response Center 1 -800-424-8802 or (202) 267-2675 U.S. Environmental Protection Agency (415) 744-2000 U.S. Coast Guard (510) 437-2940 or (800) 424-8802 Colorado Department of Public Health (877) 518-5608 and Environment Hemberger Compressor Station Page 11 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KL E/NFEL DER drrgMt ilopre.Rtor sohltCom Response Contractor Telephone Number Belfor Environmental (24-hour responder 1 -800-930-0011 and cleanup activities) Kleinfelder (Site characterization and (303) 237-6601 cleanup coordination) The FRC is responsible for making appropriate contacts or delegating this task to a responsible party if an unauthorized release of oil occurs as described in §112 .1 (b). The FRC is to obtain a record of the individual report numbers you are given by the persons taking reports at each of the agencies contacted , and record the person's name taking the report. §112.7 (a)(4) Discharge Reporting The following information must be provided in the Discharge Report (Appendix D): • The exact address or location and phone number of the facility; • The date and time of the discharge; • The type of material discharged; • Estimates of the total quantity discharged ; • Estimates of the quantity discharged as described in § 112. 1 (b); • The source of the discharge; • A description of all affected media; • The cause of the discharge; • Any damages or injuries caused by the discharge; • Actions being used to stop, remove, and mitigate the effects of the discharge; • Whether an evacuation may be needed ; and • The names of individuals and/or organizations who have also been contacted. Hemberger Compressor Station Page 12 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLE/NFELQER &tight People flight Solutions. In addition, if available, the following information can be provided : • Fire and/or explosion potential . • Probability of offsite migration and/or environmental damages. The SPCC regulations state that inspection records shall be kept according to usual and customary business practices. Inspection records and written reports documenting reportable releases of petroleum hydrocarbons will be maintained at the facility for a period of at least three years. Reports associated with cleanup activities are completed by the FRC. These reports include, but are not limited to, notification of appropriate governmental agencies, contractor work authorizations, and shipment records associated with offsite transportation and disposal . Releases reported by telephone to the environmental agencies must be followed up by a written report. In all instances, the FRC or Alternate FRC must review the reporting regulations to evaluate contents of the required reports, the deadline for submitting them , and other information required. The facility follows the following reporting requirements: 1 . A verbal report giving the specific details of the release will be given to the FRC by the facility employee at the scene. The FRC will be responsible for preparation of the Spill/Incident Report Form . A copy of the Spill/Incident Report Form will be maintained at the facility. 2 . If a petroleum hydrocarbon release meets the definition of a "discharge" as defined in 40 CFR § 110.3, the FRC shall notify the National Response Center (NRC). A "discharge" is a release of oil into or upon the navigable waters of the United States or adjoining shorelines that may be harmful to the public health or welfare or the environment of the United States . Harmful quantities are quantities that violate applicable water quality standards, or cause a film or sheen upon , or discoloration of the surface of, the water or adjoining shorelines, or cause sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines. Hemberger Compressor Station Page 13 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLE/NFEL DER aright itvpfc. p%yht Soiuvonz 3. If two releases of 42 gallons or more occur at the facility in any 12-month period , or one discharge event of 1 ,000 gallons or more occurs, the owner or operator must submit a written report to the Regional Administrator of the EPA within 60 days of the event. The report must contain all of the following information (40 CFR 112.4a). • Name of the facility; • Name of person writing the report; • Location of the facility; • Maximum storage or handling capacity of the facility and normal daily throughput; • Correction actions and countermeasures taken , including a description of equipment repairs and replacements; • An adequate description of the facility, including maps, flow diagrams, and topographical maps, as necessary; • The cause of the discharge, including a failure analysis of the system or subsystem in which the failure occurred; • Additional preventative measures taken or completed to minimize the possibility or recurrence; and • Such other information as the Regional Administrator may reasonably require pertinent to the Plan or discharge. 4. All discharges reported to the NRC will also be reported to the Colorado Department of Public Health and Environment (CDPHE) by telephone. All written spill reports submitted to the EPA RA will also be submitted to the CDPHE . The FRC will be responsible for these notifications unless unavailable, in which case, the Alternate FRC is responsible. The CDPHE telephone number is provided in Table 2-1 . Copies of all reports will be maintained by the FRC at the facility. 5. The CDPHE will be notified by telephone of all spills reported to other agencies. Hemberger Compressor Station Page 14 of 30 SPCC Plan 20155174/DEN 15O18231 April 2015 © 2015 Kleinfelder KLEINFELDER awn'people.Rif%Gluttons. §112.7 (a)(5) Emergency Response Procedures The general emergency response procedures for the facility are summarized below. 1 . STOP THE RELEASE If such action can be performed without risk of injury, stop the release at the source (e.g. , close valve on tank truck; push emergency stop for fuel system , upright the container, etc.). Note: Direct contact with oil products should be avoided . 2. CALL Determine the severity of the spill or leak and CALL 911 if there are injuries or a spill/leak is of a significant quantity to warrant Fire Department Hazardous Materials Team . 3. CONTAIN THE SPILL If the spill is threatening structures, storm or sanitary drains, or bare soil ; AND, if such action can be performed without risk of injury, the reporting party will attempt to contain the spill: a. Inspect secondary containment, if present, to verify that liquid is not visibly seeping through walls. b. For spills outside passive secondary containment, such as fuel transfers, contain the spill using absorbent socks or by building a temporary dike with granular absorbent. 4. REPORT TO RESPONDING PARTIES Remain in a safe location near the spill site and report to the FRC upon their arrival. Hemberger Compressor Station Page 15 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLE/NFELDER &ght RoP1e.R.ght Solution 5. CONTROL ACCESS AND FIRE HAZARDS Control access to the affected onsite areas (e.g . barricades and traffic controls). If it is safe to do so, shut off electricity, gas service, and other sources of ignition. Prohibit smoking . If a fire ensues and the conditions are safe, use the fire extinguisher. Otherwise call the Fire Department. 6. CLEAN UP THE SPILL After fire and safety hazards are under control , spill clean-up crews will be allowed into the area. The crew shall have the necessary materials and/or equipment to restore the area to a state reasonably equivalent to its condition prior to the spill . Spill kits are positioned near the oil storage area onsite, which includes at a minimum , the following materials: o Chemically resistant container, o Absorption materials (e.g . spill pads), o Safety Data Sheets (SDS), and o Personal protective equipment (PPE) (e.g. goggles, gloves, etc.). 7. PREPARE SPILL/INCIDENT REPORT FORM The FRC will be responsible for the completion of the Spill/Incident Report Form in Appendix D. 8. REPORT TO APPROPRIATE REGULATORY AGENCIES If the spill or leak of the fuel/oil or contaminated water is of a reportable quantity, the FRC will be responsible for reporting the incident to the appropriate regulatory agencies within the specific timeframes required by the regulation. (see Discharge Reporting, previous section). Hemberger Compressor Station Page 16 of 30 SPCC Plan 20155174/DEN 15O18231 April 2015 © 2015 Kleinfelder KL E/NFEL DER \\ N,...et.4•oy.c Rcj? t Sufu tbri §112.7 (b) Potential Release from Equipment Where experience indicates a reasonable potential for equipment failure (such as loading or unloading equipment, tank overflow, rupture, or leakage, or any other equipment known to be a source of a discharge), the facility Plan must include a prediction of the direction , rate of flow, and total quantity of oil that could be discharged from the facility as a result of each type of major equipment failure. A summary of the potential release prediction for the facility is provided in Table C-2 (Appendix C). §112.7 (c) Appropriate Containment and/or Diversionary Structures/Equipment The entire containment system , including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system , such as a tank or pipe, will not escape the containment system before cleanup occurs. At a minimum , one of the following prevention systems or its equivalent are required for onshore facilities: dikes, berms, or retaining walls sufficiently impervious to contain oil ; curbing ; culverts, gutters, or other drainage systems; weirs, booms, or other barriers; spill diversion ponds; retention ponds; or sorbent materials. The containment systems in place at the facility are described in Table C-1 (Appendix C). To meet the requirements for secondary containment for the separators, scrubbers and filters, the facility maintains a spill materials onsite and this SPCC plan contains an Oil Spill Contingency Plan (OSCP) following the provisions of 40 CFR Part 109 and a written commitment of manpower, equipment and materials required to expeditiously control and remove any quantity of oil discharged that might be harmful that will be implemented . §112.7 (d) Impracticability of Secondary Containment The facility has not determined that any of the requirements of the SPCC rule are impracticable. To meet the requirements of 40 CFR § 112 .7(c), for separators, scrubbers and filters, the facility maintains a spill cart onsite and this SPCC plan Hemberger Compressor Station Page 17 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KL E/NFEL DER \ _ Bright People.Right Soluf:oos contains an OSCP following the provisions of 40 CFR Part 109 and a written commitment of manpower, equipment and materials required to expeditiously control and remove any quantity of oil discharged that might be harmful that will be implemented . §112.7 (e) Inspections, Tests , and Records Facilities subject to the requirements of 40 CFR § 112 must conduct inspections and tests in accordance with written procedures that have been developed for the facility. These written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, are to be maintained with the SPCC plan for a period of at least three years. Records of inspections and tests kept under usual and customary business practices by Sterling will suffice. Inspection and test records are maintained by the FRC. Oil storage and handling areas are inspected regularly by Sterling personnel . Evidence of leaks or potential leaks will be immediately reported to the FRC. The FRC will direct the repair or replacement of equipment responsible for releases of oil . The following inspections are conducted under this SPCC plan to identify and correct problems before spills occur: • Daily and Weekly Visual Observations -- During normal daily or weekly facility operations, facility personnel visually observe the condition of tanks, containers, secondary containment areas, pumps, piping , valves, and connections. Drips, corrosion , or fatigue which could indicate the potential for leaks are reported to the FRC . Observed signs of leakage will be evaluated and the equipment repaired . Visual observations will be logged only when a problem is detected . If a problem is detected , a record of the type of problem and actions taken to fix the damaged or leaking equipment will be made on the Inspection Log (Appendix F). • Regular Inventories — The product levels in the oil/lubricant tanks and inventories of drums containing waste oils are inventoried twice weekly by facility personnel . Records of delivery volumes and truck slips are maintained at Sterling's Yenter Field Office. Hemberger Compressor Station Page 18 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KL EINFEL DER \ fi:yhl Prop1P Rght Solution%. • Monthly and Annual Inspections — All of the bulk storage containers are visually inspected monthly and annually in accordance with the scope and schedule specified in the Steel Tank Institute's Standards for the Inspection of Aboveground Storage Tanks (STI SP001 ). During the inspections, the tanks, aboveground piping , and related equipment are inspected for signs of leakage or potential failure, such as drip marks, stains, pools of oil , corrosion , cracks, bulging , gasket deterioration , dead vegetation , foundation settlement, cracks in secondary containment, or other damage. The results of visual inspections are recorded on the inspection forms in Appendix F. After completing an inspection , the inspector signs and dates the form . A record of these inspections is also kept on the Inspection Log . §112.7 (f)(1 ) Personnel , Training , and Discharge Prevention Procedures Sterling will provide training to facility personnel involved with oil handling , in the proper operation and maintenance of spill prevention and control materials and equipment to prevent releases of petroleum products, general facility operations and the contents of the facility SPCC plan . Personnel training will address the spill prevention and response protocols and requirements of personnel working with the transfer of petroleum products. Responsible employees will be informed of the existence of and general content of applicable local , state, and federal regulations. Sterling's training program is designed to educate employees in the proper handling of materials and in procedures to use to mitigate the effects of a spill. All non-office personnel are trained to be alert for and recognize releases and to report incidents to the FRC . Release recognition and notification training is conducted as part of non-office employee orientation training for all personnel when hired . The FRC is responsible for verifying that personnel receive the appropriate training . Training is provided within one month of employment and refresher training is conducted annually. Hemberger Compressor Station Page 19 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder , KL EINFEL DER Wiyh[A+Opk.Right Solutions All personnel that handle oil at the Hemberger Compressor Station receive SPCC training , which may be conducted in conjunction with other training . The annual SPCC training will include the following information : • Overview of the SPCC plan ; • Requirements of the SPCC regulations and other applicable pollution control laws, rules, and regulations. These include Comprehensive Environmental Response, Compensation , and Liability Act (CERCLA) regulations, and state and local spill response laws; • Personnel responsible for management of the petroleum product systems ; • Health and safety protocols; • Standard operating procedures used to prevent discharges of oil ; • Location of oil storage systems; • Location of drainage systems; • Maintenance and inspection procedures; • Potential failure mechanisms; • Spill notification procedures; • Spill response procedures and discharge protocols; • Handling and disposal of spill materials; • Discussion of known releases, failures, malfunctioning components, and recent precautionary developments; • Location and contents of spill response kits ; and • Record keeping and reporting. Complete copies of the above-referenced training documents can be obtained onsite with the Plan and electronically. Training attendance forms and records are included in Appendix E. Training records are maintained for a minimum of three years. Hemberger Compressor Station Page 20 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLE/M-ELDER B;Kitt People.Right Soivrian This training section does not address other required employee training such as: • Stormwater best management practices; • Safety training; and • Hazardous waste management training . §112.7 (f)(2) Discharge Prevention Contact Name(s) The FRC (Rodney Barnes) and Alternate FRC (Sean Miller) are accountable for discharge prevention and report directly to facility management. Contact information is provided on Table 2-1 . §112.7 (f)(3) Discharge Prevention Briefings Discharge prevention briefings for oil-handling personnel are scheduled and conducted at least once a year to assure adequate understanding of the SPCC plan. Such briefings highlight and describe known discharges as described in §112. 1 (b) or failures, malfunctioning components, and any recently developed precautionary measures. §112.7 (g) Security Security measures at the Hemberger Compressor Station include a T-post fence which surrounds the facility. The main gate to the site is pad locked when operators are not on site. Operators at the facility limit site access to designated personnel and Sterling employees notify the Operation Manager prior to any site inspections/visits. ( 1 ) Fencing The oil storage and handling equipment is secured by a perimeter fence (T-post). Hemberger Compressor Station Page 21 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLEINEELOER fright People Regh r SoMiom. (2) Master flow and drain valves The oil storage tanks are not equipped with master flow or drain valves that permit direct outward flow of the container's contents to the surface. (3) Starter control on oil pump There are no oil transfer pumps on-site; therefore, this section is not applicable. (4) Loading/unloading connection of oil pipelines/piping There are no oil pipelines on-site; therefore, this section is not applicable. § 112.7 ( h) Facility Tank Car and Tank Truck Loading/Unloading Rack The facility does not have a tank car or tank truck loading/unloading rack. §112.7 (i) Field-constructed ASTs There are no field-constructed ASTs at the facility. §112.7 (j) State and Local Conformance with Requirements and Procedures The State of Colorado and local requirements are no more stringent than those required by 40 CFR § 112. 12.7 (k) Qualified Oil-filled Operational Equipment The Waukesha compressor engines at the facility have an oil capacity of 44 gallons each and each compressor skid has a nine inch wail around the perimeter to catch oil spills/leaks. If the skids need to be emptied the liquid is pumped out and sent to an approved disposal/recycle contractor. Because the skids provide sized secondary Hemberger Compressor Station Page 22 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLEINFELDER &ighl i,pop4e.Right Solutions containment, the facility will not utilize alternative requirements as described in 40 CFR 112 .7(k)(2). Site specific information for the Hemberger Compressor Station is located in the Figures of the OSCP (Appendix C). 2.2 REQUIREMENTS FOR ONSHORE FACILITIES (§ 112.8) §112.8 (a) General Compliance With the exceptions noted at the beginning of Section 2.0, the facility meets the general requirements for the SPCC plan listed under § 112.7, and the specific discharge prevention and containment procedures as described in this section . §112.8 (b) Facility Drainage The facility drainage has been designed to meet the requirements of (b)(1 ) through (b)(5) as described below: ( 1 ) Drainage from diked areas Stormwater accumulating in secondary containment areas is normally allowed to evaporate or is collected by a vacuum contractor truck if it is a significant amount and transported offsite for disposal at a Sterling contracted disposal facility. Truck/load-out volumes from service slips are collected and kept at Sterling's Yenter Office. (2) Diked area valves if valves are present, only manual open-and-close type valves are used for diked area drainage at the facility. The facility does not have drain valves. (3) Drainage from undiked areas Oil transfer operations to/from the ASTs and drums occur in undiked areas , at locations as shown in Figure 2 . A temporary dike is constructed with absorbent materials if Hemberger Compressor Station Page 23 of 30 SPCC Ran 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLEINFEL DER Bright People R*ghr Solutiwu needed to contain spills originating from the hoses used to transfer oil between the delivery/recycling truck and the tank or drum . Oil collected within these areas is either completely absorbed by the dike materials, sorbent materials, and/or is pumped out and sent to an approved disposal/recycle contractor. (4) Alternative drainage The facility drainage is engineered to meet the requirements of § 112 .8(b)(4); and is, therefore, not required to have an alternative diversion system . (5) Multiple drainage water treatment units There are no multiple drainage water treatment units therefore this section is not applicable. §112.8 (c) Bulk Storage Containers Bulk storage containers meet the requirements for construction , storage, secondary containment, drainage, testing as described in (c)(1 ) through (c)( 11 ) below: ( 1 ) Construction and material compatibility The aboveground storage tanks were manufactured to meet applicable aboveground storage tank industry and regulatory requirements for materials of construction (e.g . UL, STI, API , etc.). All of the tanks at the facility were shop-constructed of steel or steel and concrete. There is no unusual pressure demand or temperature demand in the areas the tanks are located in . The on-site 500-gallon tanks and 275-gallon tanks for engine/compressor oil are constructed of steel , which is compatible with the types of oil stored in the tanks. (2) Secondary containment The details of the secondary containment for each bulk storage container are shown in Table C-1 (Appendix C). Hemberger Compressor Station Page 24 of 30 SPCC Ran 20155174/DEN 15O18231 April 2015 © 2015 Kleinfelder KLE/NFELDER Bight lkople.Right Sotutwit Tanks are stored in appropriately sized secondary containment and drums are stored on containment pallets which have a capacity greater than 55-gallons (single largest container). (3) Secondary containment drainage Plugs and drain valves for secondary containment areas are always maintained in the secured and closed position . Stormwater accumulating in the oil storage secondary containment areas (e.g . curbed areas, containment pallets) is normally allowed to evaporate or is pumped out by a vacuum contractor truck for transport and disposal at a Sterling contracted disposal facility. (4) Completely Buried Tanks There are no completely buried metallic tanks on-site; therefore, this section is not applicable. (5) Partially Buried Tanks There are no partially buried tanks on-site; therefore, this section is not applicable. (6) Integrity testing At a minimum , the bulk storage containers will be inspected and tested in accordance with the scope and schedule specified in the Steel Tank Institute's Standards for the Inspection of Aboveground Storage Tanks (STI SP001 )4. Based on SP001 , the ASTs and drums at the facility would qualify as Category 1 tanks, which require only periodic inspections. Tests and inspections will be performed according to the schedule in STI SP001 and whenever material repairs are made. Only personnel with the appropriate qualifications, in accordance with STI SP001 or other applicable industry standards will perform tests and inspections. The tests and inspections will take into account container size, configuration and design . A summary of the periodic inspections is provided below. • Review prior inspection , repair and alteration data before each inspection . Note special conditions for a particular AST. 4 Standards for the Inspection of Aboveground Storage Tanks (STI SP001 ), Steel Tank Institute, 3rd Edition, July 2005. Hemberger Compressor Station Page 25 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLEINEELDER ft-5h(itvpJe. Rgh;Solution! • Complete the STI SP001 AST Record for each AST or tank site as designated in the checklists. Note special conditions and changes or alterations to the tank. • Complete the STI SP001 Monthly Inspection Checklist each month . Take note of instructions on the checklist. Note special conditions. • Complete the STI SP001 Annual Inspection Checklist each year. Take note of instructions on the checklist. Note special conditions. • For portable containers , the owner's inspector is to complete only the STI SP001 Portable Container Monthly Inspection Checklist each month . Take note of the instructions on the checklist. Note special conditions. • Monitor for water accumulation monthly. If corrosion is found due to Microbial Influenced/Induced Corrosion , treat the AST with a proper biocide or otherwise sterilize the AST. In addition , take necessary steps to repair or remove the AST from service, if warranted by the extent of the corrosion . The Monthly and Annual Inspection Forms based on the SP001 checklists are provided in Appendix F. Also included in the inspections are container supports and foundations, signs of deterioration , and observations of discharges or accumulation of oil inside diked areas. Records of inspections, tests, and comparisons are kept under usual and customary business practices and are maintained at the facility or the Sterling Yenter Office. (7) Internal heating coils control The tanks on-site do not contain internal heating coils. (8) Liquid level sensing devices to avoid discharges The bulk storage containers at the facility must be equipped with at least one of the following liquid level sensing devices: (i) Alarms — High liquid level alarms with an audible and/or visual signal set to alarm when the liquid level in the tank reaches 80-85 percent of the total tank capacity, depending on the tank. Hemberger Compressor Station Page 26 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KL E/NFEL DER Bright People.Righr Sokitiom. (ii) Pump Cutoff Devices — High liquid level pump cutoff devices set to stop flow when the liquid level in the tank reaches 90-95 percent of the total tank capacity, depending on the tank. (iii) Signals — When the liquid level in the tank reaches 85 percent, a light is illuminated at the pumping facility that indicates which tank has reached the high level alarm . (iv) Direct Vision Gauges — A person is present at all times to monitor the gauge during the filling of these bulk storage containers, and the tank is only filled to 75 percent of capacity, as indicated by the gauge, to prevent overfilling. For the 500-gallon tanks, 275-gallon tanks, and 55-gallon drums that are refilled, equivalent environmental protection is provided by manually gauging the tank prior to filling the tank manually to determine if enough capacity exists in the tank. In addition, the nozzles used to fill the tanks are equipped with manual liquid level shut-offs and are continually monitored while the transfer is taking place. (9) Treatment facility effluent The facility does not have an on-site wastewater treatment plant (WWTP). ( 10) Corrective action for visible discharges Visible discharges from any oil storage container or appurtenance, including seams, gaskets, piping , pumps, valves, rivets, and bolts, are quickly corrected upon discovery and reported to the FRC . ( 11 ) Mobile or portable oil storage containers Mobile and portable oil storage containers at the facility consist of 55-gallon drums and a 500-gallon red diesel tank. The on-site 55-gallon drums are stored on secondary containment pallets, which will provide a secondary means of containment for the entire capacity of the single largest container (55 gallons). Hemberger Compressor Station Page 27 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KL EINFEL DER B;ighl People.Right Sohrfionf. §112.8 (d ) Facility Transfer Operations, Pumping and Facility Process The oil transfer operations at the site occur at the following locations: • One load out line located at the slug catch ; • Two 55-gallon lube oil drums — manual oil transfer area to compressor units; • Three 275-gallon lube oil ASTs — manual oil transfer area to compressor units; • One 500-gallon compressor fluid AST -- manual oil transfer area to compressor units; and • One 500-gallon red diesel AST — this is a mobile tank which may be loaded on a truck or trailer using a forklift. Oil transfer operations associated with this tank are manually performed and may occur at various locations provided that the transfer procedures listed below are followed. The following general oil product transfer procedures are followed: 1 . Prior to transfer, all valves and pipelines involved should be visually examined for correct positioning and possible leaks. The receiving containers are also gauged to determine the amount of oil to be transferred without overfilling the container. 2. Absorbent material and personal protective equipment are available and ready to use in case of spills originating from hoses associated with the transfer of oil . 3 . The transfer process shall be attended continuously by a person qualified to conduct oil transfer operations (e.g . , truck driver, certified operator, etc.). 4. During transfer, the receiving container's oil level gauge (if equipped) is constantly monitored to prevent overfilling the container. 5. Upon completion of the transfer process, all valves shall be checked for correct positioning and oil leaks. 6. Should a leak occur during transfer, transfer shall be stopped immediately and the site-specific spill response procedures shall be implemented . ( 1 ) Buried piping The buried piping currently onsite is located between the process equipment and compressor unit. If buried piping at the facility is installed or replaced , the new buried pipelines will have a protective wrapping and coating and be cathodically protected or Hemberger Compressor Station Page 28 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder erTh KLEINFELDER DER snot Frop/e Right Solulioni have equivalent corrosion protection . If buried piping at the facility is installed or replaced after the date of this Plan and is uncovered during construction or other activity, it will be inspected for corrosion and leakage. The results of these inspections are kept on the Inspection Log (Appendix F). (2) Terminal connection There are no terminal connections at the facility. (3) Pipe supports Aboveground piping is located between the inlet separator, the slug catch , and at the three compressor units. Pipe supports appear to be in good condition , adequately spaced , designed to minimize abrasion and corrosion and allow for expansion and contraction . (4) Inspections and Testing The site conducts regular monthly inspections of all aboveground valves, piping , and appurtenances. During the inspection the general condition of the following items are assessed , if present: • Flange joints, • Expansion joints, • Valve glands and bodies, • Catch pans, • Pipeline supports, • Locking of valves, and • Metal surfaces. Sterling will conduct integrity and leak testing of buried piping at the time of installation , modification, construction , relocation , or replacement. (5) Warnings and traffic control Traffic cones will be placed around the equipment when oil transfer operations are taking place to divert traffic and warn all vehicles entering the facility that oil transfer Hemberger Compressor Station Page 29 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KL EM/FEL DER aright Pe**.,�t Solutions. operations are taking place. Vendors making deliveries are told to follow designated driveways and to obey facility signing. Hemberger Compressor Station Page 30 of 30 SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLEINFELOER &qht Rop$_Rrgh!$040 oni FIGURES Hemberger Compressor Station SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder 4.) ,...._....---d-- II ••• ) ( c ti it" 1 jr\---e- \ii \ kilt \ its \ I \ I (7)1 , f Wale+ Tank \ \ 17..."-/ t' In ...siii • . / U 23 4 iMm..-i ----— )—.... ... ——7 A... i -- �� " it aid I r (.' ) i) i ' Vit.:, N v I. yd (I �� is 4`O • I� M + ��J t ~1 Eater Tank 6 iw. `9`0 1. /jr-- `. `I41 ) 94% i \ a• r J. 2 ••• , j i I\ woleNo E ........ 0 8.: .........., .1 .'' \* t. _ p•W A) / CI' ti lc • liel ri /Cc • s _ �_ y sas: , a Q::::_. ¢ a - d r T^rr' w a„ �.-. M �! a 19 4. Hemtierger Compressor Station`` df enk \\\ s 27 *Water lair y. �� ` JI s -- _,, ` :' e� La ,:.: .r:• �L . _ ,:'Low Flat ��. Q • �p" W�rd�nlp I -ON \ R f i{�p .- t:7 M f4.. a \g A y N\rr........1:Lj �1. \Th r � fl 4 sall b,- coda nt (/ Q I . li‘\ %1 \\\ 4- I - N1/4............,Ljri ° ' 1896 `+_f �� Z ��v- , its..")\.............. NJ 1;\ ‘ \IL, NI } 4 ThtelL7 k r �, c t, �, �.� a S3/4—eekII • \` l r PI e % .ire 351 3 - > 1 Legend 4� T p ' 9 N A Compressor Station IsIo Streams I 1\.. Lakes I " `.N, \ 1 aIM Nonntaon tnthvd.d at thn p.pht torsi ontron hat beer compded kum s variety a _ ti fuurYN aM s subjecl bu change.tIlaut noes* kwlnOM1.r nukes no n(Me.Mt00n.a I � • wsrraMaa .sprat t or rmptrt as to pautay.tctrp•t.netL fewcon at eighle b the O O.G 0. 1 use of such hbmaboo this daar.nt w not trrand.4 rot wean a land survey pmducl 1 nor n a(*myna,co Wended as a cantata,design docun ent The use a w me . f " � at t al.Sormon oor$Saed oh%his graphic npns.ntalion is M Ow sole risk th k e Miles ''_ Mg tang or mttw.q the Smat aon •i i/ \/ /� �� l \ v PROJECT NO. 20152191 FIGURE ra Sterling Energy Investments, LLC DRAWN: 4/16/2015 Hemberger Compressor Station KL EINFEL DER DRAWN BY: J. Weber Bright People. Right Solutions. CHECKED BY: K. Howe Site Topographic Map FILE NAME:www.kleinfelder.corn Weld County, Colorado SterlingSPCC_mapbodc-mxd 500-GAL RED DIESEL OIL TRANSFER AREA 74" x 60" x 31" CONTAINMENT INLET GAS X r -� X LA, \rk) FUEL LINE X OIL LINE X INLET/OUTLET OUTLET GAS SEP ' '�' 600 GAL ; X 15 BBL TOTAL COMPRESSOR FLUID r 8' 0 x 2' CONTAINMENT INLET/OUTLET OO O OO 0o SEP ; 15 BBL TOTAL COMPRESSOR 1 © COMPRESSOR 2 COMPRESSOR 3 e , 20'L 20'L 20'L I 275-GAL 275-GAL 275-GAL ❑ LUBE OIL 200-3AL ❑ LUBE OIL ❑ LUBE OIL ' 1 WASTE OIL o' Ox2' CONTIANMEN 15'W 9"H 15'W 9"H 15'W 9"H OIL TRANSFER (2X) 55-GAL LUBE OIL ; AREA DRUMS L - 1 4'x2'x18" CONTAINMENT I L t i i t t t i I PLANT INLET %!/L. OIL TRANSFER AREA METER r METER SLUG CATCH 153 BBL 60" 0 x 44' 48" 0x10' INLET SEP 22 BBL .‘2,.2 -n FENCE r NZ PLANT OUTLET I— Legend itnr:.w-,ai,-n irk.L.h-Jon tin I sorest"tr..naeml An hcatorgrthd It.c.a BBL = Barrels Aboveground Piping .amity 01 nut('s and or(title.(I todon{c'.riding'rime K4uJcld(t mar.", r ritt..am...64railataxi(trai.'urntpLY.tMN.atitilKy.(Vlrl*t(at11. GAL = Gallons limit Iglu it ra Olin la ti.(uw of oat;.rd+rmMmn Thu(laCVaMla 4 IY.t rtuer.kut far wr"arift.nl. ;141:irr(aJ(ngMJ.rinusi(Jna(emuvdr.:J.u"3 SEP = Separator Belowground Piping r ocuo v.t n(n11n 4 n(tix,ot.rnution tnatanrrd nn ii.,,m.y.hn nlr(arn- lion to at the wk risk of the pasty wing ur mummy tin rnformatioa PROJECT NO. 20155174 FIGURE DRAWN: 5/12/2015 Sterling Energy Investments, LLC KL E/NFEL DER DRAWN BY: J. Weber Hemberger Compressor Station ' Bright People. Right Solutions. CHECKED BY: L. Bott 2 Facility Site Diagram FILE NAME: Weld County, Colorado www.kie'snfelder.com Hemberger.pub KLE/NPELOER 8r;yn:Peet0e.Mr sohittn. APPENDIX A PLAN REVIEW AND AMENDMENT LOG Hemberger Compressor Station SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder KLEINFEL DER Bight!tOp1r. Right Solutions PLAN REVIEW AND AMENDMENT LOG Management Review: Management is to review the SPCC plan at least once every five years and document the review on the form below (40 CFR § 112 . 5(b)). Non-Technical Amendments (P. E. certification not required): Non-technical amendments that do not require P.E. certification should be documented on the form below. Examples of changes may include: telephone number, name change, non-technical text changes, facility reconfiguration that does not materially affect the potential for oil discharge. Technical Amendments (P.E. certification is required) : An amendment is required when there is a change that materially affects the facility's potential to discharge oil (67 Federal Register 47091 ). Technical amendments that require P. E. certification should be documented on the form below. Examples of changes may include: commissioning or decommissioning containers and/or piping systems, replacement of containers and/or piping systems, reconstruction of containers and/or piping systems, movement of containers and/or piping systems, construction or demolition that may alter secondary containment structures, changes to the product or service, and addition/deletion of standard operation or maintenance procedures relating to the discharge measures. Technical amendments affecting various pages within the SPCC plan can be P. E. certified on those pages, certifying those amendments only, and will be documented on the form below. A Professional Engineer will certify technical amendments in accordance with 40 CFR § 112.5(c). Technical amendments made to this SPCC Plan will be prepared within six months of any qualifying change and implemented as soon as possible, but no later than six months following preparation of the amendment. Page 1 © 2015 Kleinfelder W Z ¢ W � a 0 re a a. Q z w a a f- Q z 0 • Z O 0 J wz Q a O Z F" p E_ W V3 w O wLL O �- - W t7 w a � � U � C zw < 0 ° I- U ~ w 5 rew � W W (0 > W cc W Z m J W 0- I p z w 2 Q w 0 z 0 H d 2 U N W p Ow rpsm wD pd Z 45 c W Y Q `n p o O rKLE/NFEL DER &rght People.Right SoAttions_ APPENDIX B CERTIFICATION OF THE APPLICABILITY OF THE SUBSTANTIAL HARM CRITERIA CHECKLIST Hemberger Compressor Station SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder rc-Th KL EINFEL DER \ . J &qhi People P/9ht Solutions APPLICABILITY OF SUBSTANTIAL HARM CRITERIA Hemberger Compressor Station 1 . Does the facility transfer oil over-water ' to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? Yes No 2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and, within any storage area, does the facility lack secondary containmentA that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation? Yes [ No 3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula in Appendix C or a comparable formula) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments?8 Yes No 4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distanceA (as calculated using the appropriate formula in Appendix C or a comparable formula) such that a discharge from the facility would shut down a public drinking water intake? Yes No 5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil spill2 in an amount greater than or equal to 10,000 gallons within the last 5 years? Yes ❑ No ❑ A Explanations of the above-referenced terms can be found in Appendix C to this part (40 CFR 112). If a comparable formula to the ones contained in Attachment C-Ill is used to establish the appropriate distance to fish and wildlife and sensitive environments or public drinking water intakes, documentation of the reliability and analytical soundness of the formula must be attached to this form. B For further description of fish and wildlife and sensitive environments, see Appendices I, 1I, and III to DOC/NOAA's "Guidance for Facility and Vessel Response Plans: Fish and Wildlife and Sensitive Environments" (see Appendix D to this part (40 CFR 112), section 13, for availability) and the applicable ACP. CERTIFICATION I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining information, I believe that the submitted information is true, accurate, and complete. Signature Date Name (Please type or print) Title © 2015 Kleinfelder KLE/NFELDER 9ry4t F Pte-Thght SohlUoru- APPENDIX C BULK STORAGE CONTAINER, PIPING, AND TRANSFER AREAS CONTAINER & CONTAINMENT INFORMATION SPILL PREDICTION CONTAINMENT CAPACITY CALCULATIONS FOR DIKED AREAS Hemberger Compressor Station SPCC Plan 20155174/DEN 15O18231 April 2015 © 2015 Kleinfelder v — --_ (} C ^ I _, , O 1O I O I O I O , 0 , O ; CO w a) i- a) L-O a) '-- W " C) O'- 0 O a) O- Q ; n 0 Q m C Q m C Q 0) C •a 0) a ` cm O " O) C C a) C 0 — a) c c c c ac 0 ac a) ac a) ac Z Z Z Z J1'' O a, 00 asa = cva = 0313 = tea = ca13 = ro 'a = ca a = roa = Ws. r.+ • > 4) LT- > CO c= > a) tom.. > 4) c� > a) y= > a) c� > a) > O 4=, W a X O N •5 •O O •5 0) •5 0) O O 5 rn •5 O) 5 0) Z If (5 & r W� W� W� W� W� W� W � W� ZI. Or —, . . \ **-1 ) a) a) a) a) m a) c T a) a) a) a) Cl) (1) c a) a) a) C U) co cn ( CO U) a >+ a) (A U) U) tt C) '�0+ "� a a a a 'C3 _ 0 a) a) O G a o c}a >' cu>' c c ro c ._. L 8 o o ci c O O a ca o v I— o1O 0- 0 0 a a a a a a 6. a a U t.,1 o o O O O O �_ OO O O � O U Z a co ca d c g. N c 12• -a -a a 1 u a) a -a -o a a co re m e td L L .1 L p +•, z a o O ) o f Q C d C ^ NCM � M � M m � C � Nlf 4) tj a u) co con wco O E ,w w�., 6L) Q) - 4) - N � N) � r2N g � E � C N CV is a .-- a a — o 'cis Is W N icu ce'' fl- U o 0 o O c c = U V U zZO 0 � CD O 0 0 0 U U coo Q U �' ^ - � Q � 0) o I— I— C in +. C 73 a a a o -O a a c O 4) Cl) m Cl) a) a) a) m Cl) Cl) a) a) Z o -.al c}a a CO 5 �' E V O _ O _ O O O 8 U O O •O •U _ _ Q O R c 7 L N a w 1... m a N a w a w •f... Q) •L cp a 0 L a) c q) •L Q) - � 0 Oa) � 0 m0 � 0 a .00 � °' � 0 aca o ao ca� 0 Z W 0.— etO 0 a a a a a a C a a 0 0 0 a, U U w V) c/)) U) U) CO V) Cl) CC/) U) U) i O v W V o c O to to o a v 0 O 0 Z Lt cc; 0 Ln N N N. O `� '� coe co H O v ay Z CC • W L _ m a) a) a) V m O 0 VA 7:-.., O O O 0) O O O CO c c c O W a 0 Q n _o _ V e c c -C c H d p J J Jit J J O U 0 O U O I-co _ L L L L Q) CO ` ` O L L L Y C C O u) a) op) u) rn s) C 0 C 0 C 2 a) T ccnn p) vI) O) cV) a7 J O 0 cn co c 'n c cn c o a) CU a) in." ?� = C c c CO c m a Em Em a m E m E m E 5. � om om Qm J m o O O O •L p 0 O O O U 0 O 0 0 O U U U to U W C Q Q 8 J O ca L Pis N m •— c is c c c CO c E o ca ca CO O ,� 5 CO 0 0 �- H 0 aai aa) aai I- H F- 0 7 C C a U) U) 0 O sc `o O O Oco O o o O L.c)nj a J J J C Lo ll[r)) c a) a) a) N �O c c c a N U c a) Y 6 cn z r 0 O N I �.. C /E 1„ D 'C W {L Jw ° (1.! / I \...; Ti J a) co Z k C ° cNi r- ZQ ct T-- I—. a " ,I �, U ed C Z — cp O _8) O -ac s azc C ` O cz Q a) C C 2 woo UU U) Ce 0 ° U- z c (13 Q. u >% Q C >, W �, E- _° E te m c `° a c pe EP, " i W u c O o LL � 'Rico cC U Z c a zO ° 0 ( U _ Q U v a re H H 00 cc a Z re a) < 0 coca :� � I To OW d C Ris C a 0 45 CL—Zs U U I 2 a2 WV - C (0 _m Z a c O. W ca to -o , U C Z Ce O o w +r 4-' co 41 > Pot m H d o -5 n N U — OLL. 0 II immt II II oaF- J ° 0 - 03 w (13 m c.) al LL J 2 4- i Va O I U J I. a) m C cC C v, x C Q a+ ° L Fe co U d 0 o V a c N _= �O O N -1O > C U 6-) O Z I U T 0 O ¢ u� II J Z `_' CL II II II h N o O -J9 ¢ v) ¢ � � Z ¢ 0 Cl ! 4, 0 C L4) N 8 � N � LON d LO NO 't Nto O C:.) d Zs laj Cl C m O 7- O U) 7- 004 r' OLo 7- 004 rdU CD a itU a (t 2a ( ) �� W a) a' C) 0 y a C 0 TJ O C_ O — O C O C_ O ,__ N i U) 0 CO C tnN_ ' LONE toN tr, _ ' to N_ ' in c., E 0 O O CO ees, 0 �'2to of N LO `-'-p0 �s• � „t d' d N N .,.-m .� N r N N N N C C) y a N a so lt ft 03 G ELO 7— N Lo tfJr' N vsr+ N WO. _ O O . . O Q r r r ILL V 44-'" it CO 'El' .92- C0n � CO Q � co 2-:„ C�O .O — No iv 0) .1 -1 `ice v CJ Z Q c g a I— Z O 'D I V) a I. C oj be in re q O O O O O O O O O CZ O O OO O O .� �. O 0 3ti F-- CO o(0 0 LL a) a) a) a) a) y... C 4 .4 L_ t L L_ .C _ _" re c E en en cn cn en en cpn en O a O .c 00 a- o L U p v Cn IX Z W - U -OC D F.—. re O � 0 � c 2 � c � c c - Ti = Q OWe E ! C5 N N I Et a u I p Na c .= N .n a) al a I I . I •� aa)) 'a3 c' ow coal 5 ac) Os 1 d OU +M' cc } a aa)) c ac >-. cn oC } a oc � _ � � O } 8 >' U } U U Z .4.-, a Zo (, V U -J a) V) o ( ca CO CO 0.. t't3 a) m a a) a) 0 _ _ _ - Q) - - N - N ^ Cl) - Cl)N Q1 Co co as `� sY Lac r � �c � 2 �e NLE :L m m a) N O o4- o °? as o °--- ° 04- 4) > m „� Cl) � C V � cY �cc .5e xc � � c .x ccE W CO � m cnu � cca cno � ccoo cOo � ccoo 2c2 m Cr) O) J = ea F- }- I- I- F- H f- f- F- f- I- t- 01- C _C a a C1 d d. CO O co •!_......' .12,-S c.) co 9c) m n U cone [L a a a I- L.. .Y N a) a t_ C O -a C us se C C O 2 4..6 _0 -,o C N N n �- CO t C co I- F-- . a w �"' H a co O CO U .Q' u�i p a a) 0 U _p Q) a) O N )co; ts a) o N - j O 1O CU O) a) La a -J _ `n 0 a) ' • U c O 2 Z to r Q O N KL EINFEL DER \ _ BrrgAt pcopfc Rghr Soiul%OnS CONTAINMENT CAPACITY CALCULATIONS FOR DIKED AREAS © 2015 Kleinferder Secondary Containment Capacity Calculation Site Name: Hemberger Compressor Station (500 gallon tank) (._-- 25-year 24-hour precipitation event: 3.1 inches Tank Information / Largest Tank (bbis) Tank Diameter(ft) Tank Deduction (bbis) 11 .9 5 0.0 Diameter Tank #2 (bbis) Tank Diameter(ft) Tank Deduction(bbis) Containment 0.0 Dimensions Tank #3 (bbls) Tank Diameter(ft) Tank Deduction(bbis) Diameter (ft) 0.0 8 Tank #4(bbis) Tank Diameter(ft) Tank Deduction(bbis) Containment Height (ft) 0.0 2 Tank #5(bbis) Tank Diameter(ft) Tank Deduction(bbis) 0.0 Effective Containment Height (ft) Tank #6(bbls) Tank Diameter(ft) Tank Deduction(bbls) (less 100-yr 24-hr Storm) 0.0 1 .7 Tank #7(bbis) Tank Diameter(ft) Tank Deduction (bbls) 0.0 Containment Capacity Tank #8(bbis) Tank Diameter(ft) Tank Deduction(bbls) 0.0 Gross Containment Capacity (bbls) 16 Total Tank Net Containment Capacity Deduction (bbis) (bbls) 0.0 16 Is Secondary Containment Adequate for _ YES the Largest Vessel Kleinfelder, Inc. 1801 California Street, Suite 1100 KL E/IVFEL DER Denver, Colorado 80202 Bright People. Right Solutions. (303) 237-6601 www.kleinfelder.com Secondary Containment Capacity Calculation Site Name: Hemberger Compressor Station (200 gallon tank) 25-year 24-hour precipitation event: 3.1 inches Tank Information Largest Tank(bbls) Tank Diameter(ft) Tank Deduction(bbls) 4.8 3 0.0 Diameter Tank #2(bbis) Tank Diameter(ft) Tank Deduction (bbls) Containment 0.0 Dimensions Tank#3 (bbis) Tank Diameter(ft) Tank Deduction(bbis) Diameter (ft) 0.0 5 Tank#4(bbls) Tank Diameter(ft) Tank Deduction(bbls) Containment Height (ft) 0.0 2 Tank #5(bbls) Tank Diameter(ft) Tank Deduction(bbls) 0.0 Effective Containment Height (ft) Tank#6(bbls) Tank Diameter(ft) Tank Deduction(bbls) (less 100-yr 24-hr Storm) 0.0 1 .7 Tank #7 (bbls) Tank Diameter(ft) Tank Deduction (bbls) 0.0 Containment Capacity Tank#8(bbis) Tank Diameter(ft) Tank Deduction (bbls) 0.0 Gross Containment Capacity (bbls) 6 Total Tank Net Containment Capacity Deduction (bbls) (bbls) 0.0 6 Is Secondary Containment Adequate for - YES the Largest Vessel Klcinfelder, Inc. 1801 California Street, Suite 1100 KL E/NFEL DER Denver, Colorado 80202 Bright People. Right Solutions. (303) 237-6601 www.kleinfelder.com Secondary Containment Capacity Calculation (Square) Site Name: Hemberger Compressor Station Precipitation Information F -1 25-year 24-hour Precipitation Event (in.): 3.1 r 1 Precipitation Volume (bbls): 1 .5 1 1 Berm Thickness --.1—� --r B - I I II Tank Information I-- Inside Bottom Dimension ----I Diameter Volume I L A I Largest Tank ID (ft) (bbls) Red Diesel Tank 4 1 'L9 L J Other Tanks Not Including the Largest Tank Berm Thickness — [..-- i — Volume Tank ID Diameter Quantity Below Berm (ft) ^ (. Inside Bottom Dimension -- (bbl) Height 0.0 0.0 Secondary Containment Information 0.0 (all length measurements to be taken from the 0.0 inside bottom of berm) 0.0 A (ft.) 5 0.0 B (ft.) 6.1 0.0 Berm Thickness (ft.) 0.1 TOTAL 0.0 Berm Height (ft.) 2.58 Secondary Containment Capacity Excess Required Capacity Gross Containment Capacity (bbls) 14.5 (State/Local) Volume Occupied by Other Tanks (bbls) 0.0 Day of Production (bbls) NA Volume Occupied by Precipitation (bbls) 1 .5 Volume of Excess Required Capacity (bbls) NA Net Containment Capacity (bbls) 13.0 Is Secondary Containment Adequate for the Largest Vessel? YES Kleinfelder, Inc. 1801 California Street, Suite 1100 KL E/NFEL OER Denver, Colorado 80202 Bright People. Right Solutions. (303) 237-6601 www.kleinfelder.com Secondary Containment Capacity Calculation (Square) Site Name: Hemberger Compressor Station Precipitation Information F -I 25-year 24-hour Precipitation Event (in.): Precipitation Volume (bbls): 0.0 I I Berm Thickness I Tank Information I Inside Bottom Dimension —►I Diameter Volume L A Largest Tank ID J (ft) (bbls) I Inlet/Outlet Separator 4 15 L. J Other Tanks Not including the Largest Tank Berm Thickness -- Volume Tank ID Diameter Quantity Below Berm "1--- Inside Bottom Dimension ---� (bbl) Height Lube Oil AST 4 1 1 .7 0.0 Secondary Containment Information 0.0 (all length measurements to be taken from the Inside bottom of berm) Notes: The inlet/outlet separator and lube oil AST are located inside a compressor building. Because the roof A (ft.) 20 of the building will prevent stormwater from entering the secondary containment structure, precipitation has B (ft.) 15 been excluded from this calculation. Berm Thickness (ft.) 0.1 TOTAL 1.7 Berm Height (ft.) 0.75 Secondary Containment Capacity Excess Required Capacity Gross Containment Capacity (bbls) 40.5 (State/Local) Volume Occupied by Other Tanks (bbls) 1 .7 Day of Production (bbls) NA Volume Occupied by Precipitation (bbls) 0.0 Volume of Excess Required Capacity (bbls) NA Net Containment Capacity (bbls) 38.9 Is Secondary Containment Adequate for the Largest Vessel? YES Kleinfelder, lnc. 1801 California Street, Suite 1100 K"L E/NFEY DER Denver, Colorado 80202 Bright People. Right Solutions. (303) 237-6601 www.kleinfelder.com Secondary Containment Capacity Calculation (Square) Site Name: Hemberger Compressor Station (each 55-gal drum pallet) Precipitation Information F r1 25-year 24-hour Precipitation Event (in.): 3.1 r' 1 Precipitation Volume (bbls): 0.4 I I Berm Thickness -+I -»-- I8 II Tank Information F.— inside Bottom Dimension —I Largest Tank ID Diameter Volume L A J (ft) (bbls) I Lube Drum 2 1 .3 L -1 Other Tanks Not Including the Largest Tank Berm Thickness --- `— Volume I � Diameter ^ -- Inside Bottom Dimension --- Tank ID (ft) Quantity Below Berm f (bbl) Height 0.0 0.0 Secondary Containment information 0.0 (all length measurements to be taken from the 0.0 inside bottom of berm) 0.0 A (ft.) 4 0.0 B (ft.) 2 0.0 Berm Thickness (ft.) 0.01 TOTAL 0.0 Berm Height (ft.) 1 .5 Secondary Containment Capacity Excess Required Capacity Gross Containment Capacity (bbls) 2.2 (State/Loca!) Volume Occupied by Other Tanks (bbls) 0.0 Day of Production (bbls) NA Volume Occupied by Precipitation (bbls) 0.4 Volume of Excess Required Capacity (bbls) NA Net Containment Capacity (bbls) 1 .8 Is Secondary Containment Adequate for the Largest Vessel? YES Kieinfelder, Inc. 1801 California Street, Suite 1100 KL E/NFEL DER Denver, Colorado 80202 Bright People. Right Solutions. (303) 237-6601 www.kleinfelder.com KLrNFELDER &tnt ittoSt RNA(Sots APPENDIX D SPILL/INCIDENT REPORT FORM AND SPILL REPORTING REQUIREMENTS Hemberger Compressor Station SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder c 0 td Jc JF ca 111 4 x E ca Z ` C W � o (1( ..-1 ) o E co z a) E o a a �; u a) m e s 0) co w o a) c 0 o 0 Q Zcc P O y a) O C c c o a) co r co 0 z d o o z o 0 `. ❑ a 0. O ce• ~ I N c E CD 1— °' > co y 3 Q Q �/ O z Z O N ❑ 0 0.. 0 WW � W W o z 2 ) ca N U O (o W 0 w :_ U -co co -- o to Qco ? W *a:) Z ❑ $ —, 0 E ❑ O J re F= J a) W to N co C >- 3 co 4) 0 CO W �_ - c co co = a) O co co Q N w co O N a) d N U, C C L C = of ca t v) cu co 2 co o ui F— o N- GG c Q 1— 0 t.l. U (/) co W cn ❑ c6 •v E a) a) co CO L O n O a .5 co V N C N O U a) Ea.co ❑ Q o °) =ICI w a •aaa)) 0 CL Z O 0 W W a) a) a) aw 2 o E o (p U 0) a G a) 1 - Ni N C co ❑ m p +.. i' .c of C Y 3 3 01 o a) o a u a) a) E •v U ` C Q _ ^ Q ^ C N Q a) Z V .0 N 5 co Cr) c. o j .5 Y C c E N c �' Z Q gc m E c E c Q,3 C51 47, Mr 0 m c L ° ° ' E' = Ca a) f° Q co o .C U) r to Z *0 b a " "- Q co cn ttlV v �. a co W N .r o CO C N - x vc '8 0 0 rota) © p a c a) co 2 ,, z t .c 0) Q 0 p) +. 0 U V z, u. 0 acn o 1 Q) m p p o c — •c .- Q a. u. © ¢ Q z c a — `�' KLEINFELDER Cori Peopk.Rhr Sohnions SPILL REPORTING REQUIREMENTS HEMBERGER COMPRESSOR STATION Reporting Agency Reportable Quantity Deadline Type of Report National Response Any release of oil to a navigable Immediately Telephone Center water unless exempted (800) 424-8802 EPA Region VIII A discharge of 1 ,000 gallons of 60 days Written oil into or upon navigable waters in a single spill event or US EPA — Region 8 1595 Wynkoop St. A discharge of oil more than 42 Denver, CO 80202 U.S. gallons into or upon navigable waters in each of two spill events occurring within any 12-month period Colorado Oil and Spills/releases of any size that Verbal Telephone Gas Conservation impacts or threatens to impact notification (303) 894-2100 Commission any Water of the State, a within 24- (COGCC) residence or occupied structure, hours; livestock, or a public byway. written report Written: within 10- Colorado Oil and Gas days. Conservation Commission 1120 Lincoln Street, Suite Spills/releases >5 bbl, including Verbal 801 those contained within lined or notification Denver, CO 80203 unlined berms. within 24- hours; written report within 10- days. Spills/releases >1 bbl but <5bbl Verbal NOT contained within a berm or notification secondary containment. within 24- hours; written report within 10- days. Spills/releases >1 bbl but <5 bbl No verbal or and contained within a berm or written secondary containment. notification necessary. Spills/releases <1 bbl. No verbal or written notification necessary. © 2015 Kleinfelder KLEINFELOER bright—.Rsght � Reporting Agency Reportable Quantity Deadline Type of Report Colorado Any spill that enters waters of the Immediately Telephone Department of State. (877) 518-5608 Public Health and Environment CDPHE recommends releases Written: (CDPHE) be reported immediately even if Colorado Department of the quantity of the release has Public Health and not yet been determined. Environment 4300 Cherry Creek Drive South Denver, CO 80246 NOTE: ALL SPILLS MUST TO BE REPORTED TO THE FACILITY RESPONSE COORDINATOR WHO WILL MAKE THE APPROPRIATE AGENCY NOTIFICATIONS. IF THE FACILITY RESPONSE COORDINATOR CAN NOT BE CONTACTED, THEN THE ALTERNATE FACILITY RESPONSE COORDINATOR IS RESPONSIBLE FOR NOTIFYING THE APPROPRIATE AGENCIES. © 2015 Kleinfelder KLE/NPELDER 10,ghl{bopk.Right Solutions. APPENDIX E TRAINING ATTENDANCE FORMS AND RECORDS Hemberger Compressor Station SPCC Plan 201551741DEN 15O18231 April 2015 © 2015 Kleinfelder £51 Q O 0 ►. W c = Q ! O J ' tin 1 IL & Z `[Incu / O E •E co P a a) a am -0 U -O E cv = mZ cll L re 'it' 4..s w c 0 o c 0 to o U U N re a) Z N 0 - c 5 a C) H to E O W O J CO U a� Z cU ED � Z_ a> CO .2 cni is 2 cn ,C) . . (u -idO ,_ ,c C a a- 03 E cu c E . as o z 6 .°' i a c in •12 N O 0 © KLE�NFELDER Sight kW*.Right So/rtmont. APPENDIX F INSPECTION CHECKLISTS, FORMS, AND RECORDS Hem berger Compressor Station SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder t`'' o C O Z Co k c Q S O i 4r O Q C) a) a) C .Q a a) C Z m o 4-+ 75 C C ti Q E Q a) LL E U ♦'^ �, N V! C -. (7 ce U2 �S o ° a) 0 zww o o — a o o U C - Wo Boa) aU o00 in zw C — a) o CD L. in CD Oat CO I. w — cn 2 O se CJo U S a) = a a) a) �t N a1io ` � C o � c — it to L a) 3 � c) � o n '5, a 22ocv a o o. 'v a O n)t CO aa)) ro a) O ;i, 3 Q ..o a `oCD coW N F. C a�) o -5o a:- oc — L N L O ,C w N m C P 00 E C Q) C) r sv o f Lo 03 CC 0 I- CO Q ij Q N z C N M J 0 Wt 0 " t ..1 if Lk & � ) ` Z 0 0 W O 0 1 d 2 J0 C C = U O C) iia) a) o a) d' a) a) is L tQ .co_" (d w co" Cu U .r -t-I; 5 a c O C aC O o, co a) c c Q) C O t0 a) El o Cl) ts co 0 J 0 ri J ----- C 4] to ❑ a) ``) N E 0 co '5 0 Z 1 U •v Q ai N ) c0A Cu Ta 111co C U to tn C o 0 2 J 'C ❑ af J U a) N O L > O C ❑ ii O c O �' in ,, co o Cl) 0 0 co u) m0 c a) ❑ c a) o _ — c 0 To c C o coOii o c u) a) 0 O Cam.) o o f, o al ra 0 N• C C N 'E N •O C 0 N t C OC z a 0 _`ii 2 U _` ii C6 LE a) O a) mcta u' o ill = ❑ O c a D ca c a Ce 1033Q E J vI— a J U Q 0 ❑ ❑ o c ❑ ❑ o a 0 U 0 a) a) a) �' CL U >, t 0 � I- I- 1D a) v ai IS E N v a) co m 0 2 Z --a a a Q _> ca = CO cu @ > •- N o 0 > ..]L a a) 0 _ ` ,E. U �O b 4) ❑ Q) = U D ° 2 Q) 0c a .C C ari Q] - 0 a • 0 O ,_ C0 Ca a) (n O 0 0 0 0 0 (n 0 (/) O 0 0 0 0 0) ii ❑ ❑ DODO To ❑ ❑ OOOO N C C Y Ifs 0 0 a) Q) x a) x_ a ca ❑ in- Chi 2 5 c o ai c a) -E a) a) t Y O 75 ("n m Li 0 D ai m w 0 ❑ ( ) -0 (1) (A 0 ` vro ❑ 2 r ❑ O O 0 J CL CO O 0 DC m00 •E a CO ❑ CO4-11 ❑ ❑ ❑ ❑ ❑ CO ❑ ❑ ❑ D ❑ m Y 0 O to c CI r y O hi N C C c ❑ 2 C 2 i C N ❑ 2 @ cEv L 9 = c ° a) d ? c0 E a" Z o ca c c • a) — ° v N 2 .c �; Q 4—�- c ca c 'co 2 m Y r o) r o N C 2 ca Y O z a) .o) = a) ❑ Z 0 0 ❑ N H i E U , (0� U r $-- co O a:co O U C V) � � ° c o O O O O O O O O O O O -O -o 0 o IX M Z z z Z Z Z z z z z z z C =O N O C a) Ti. Q�' 0 N o U N N N N N N N N N N N W .p Y `� U 0.1°) a) a)>- a)>- Q)>- Q) a) a) a) 4) Q) a)>-I4 - 0 - aoEcr) {,W{ x ` . { 12 x c° >,(• O O O O O O O O O O O O c C U) Z •O z z z z z z z z z z z z x 41 ( ..- 0) Q. w .- __ - - �. �. O `v Cl) Cl) Cl) CO Cl) Cl) N N N N U) N Q w a a) a) a) w a) a) a) m>- a) a)>- a) a)>- V a O >- 0 C. � m a c� a O a a a a a a O a a a E 5 ks m •n C z Z z z Z Z z Z Z Z Z Z o o- m a) O .° ,. -_ , , O Y O1 fII N Cl) N N IR N N N Cl) Cl) N N N Q) C a) v C C a) a) a) a) a) a) a) a) AT N Q) Q) Q) ra > co — OU } } } >- >- } >- > } } } } C = O N a) O O O O O O O O O O O O a) 0Vii o) O oy Z Z z z z Z Z Z Z Z z z a) o E — 1 '^^ cn v J 73 co n td .O-• C Z7 a) a) a) a) a) a) a) a) a) a) a) a) J U — a) L- } >- >- >- > >- >- >- >- >. >- > ZZ _ 3 a) < 0 `� co O Q NID Q N O a a' W 1 - c O a) o .C ca O O O O O O O O O O O O X to c n E cis Z Z Z z Z Z Z Z Z Z Z Z o N a) o ..-,m c� vi- N) a) a) a) a) Q) N Q) Q} Q) N Q) _N N 0 O > cu al >- >- >- >- >- >- >- >- >- >- >- } > toc " •cco 0 °' cu . LI- re Z T" 0 Q O O O O O O O O O O 0 O O O ci,C cru Z Z Z Z Z Z Z Z Z Z Z Z C cc - U V � O = o U) W N CO N Cl) N Cl) N N N CO N N W o 2 o o r >- } >- >- r co >- >- >- >- >- W Ornmo Z re �,, W 0 O O O O O O O O O O O O J m to N �j o Z z Z Z Z Z Z Z Z Z Z Z4.4 -.. co �' a : C C m U N CO N N N CO CO Cl) N N N N N ZW O a) N 4) Q) Q) a) Q) Q) 4) Q) a) a) = ca o Q � a } } } } } >- } } } } } } in 0 5 E. sa C C O O O O O O O O O O O O ` O Z Z Z Z Z Z Z Z Z Z Z Z N N c _ to -2 N) aa)) a) C)) CO CO Q) CO N Cl)) N CO a) -c o >- >- >- >- >- >- >- >- >- >- >- } ci T C O O O O O O O O O O O O O O c « fa o a. c z z z z z z z z z z z z V 11.? r C C C N 03 !U o 0 O N O U) N N N CO N N N N N E o c m _ a) a) a) a) a) a) a) a) a) a) a) a) c N o c •-x >- >- >- >- >- >- >- >- >- >- >- } a. o -- 0- U) r a) a) c L u_ Cl) 0 c 4- Osj o O Q Q Q ¢ C O n0 O O O a o ` C N Q) O Q O Q) Q) v E In 0) Cam) E J J co 0E is r N a � O Ts J © t5 o o O. 5 Z Q c v)r c • F.-1 o.) ,_ 0 0 .a a a o o o 0 o o o o O O > > z Z Z Z Z Z Z Z Z Z Z Z N CU - flA a) to V C C O N N N N Cl) 0 N N Cl) U) N Q C p 0 0 Q) Q) Q) a) a) a) Cl) a) a) a) a) a) ...le Z u c >- >- >- >- >- >- >- >- >- >- >- >- O � e 6 'O W L ) O — l0 to c p o o O o 0 0 o O o O o O c 0 ta.o z z z z z z z z z z z z a mO off. a) (uct, V) U) 0 U) Cl) co N Cl) Cl) U) Cl) U) c a) N a) a) a) a) Cl) Cl) a) a) Cl) a) O N to c >- > > >- > > >- > >- > U 5 t9 C 0v RI O 0 ^� T c o Z Z Z Z Z Z Z Z Z Z Z Z W a W -g v U) co N co N CO Cl) u) Cl) N Z a—.) v : a) a) a) Cl) d) Cl) a) Cl) a) a) a) a) ° ° as ° >- >- >- >- >- >- r >- >- >- >- >- < w Z 0) O O U Hc o- w a a -o 0 0 o a o 0 0 0 0 0 0 0 0 ,J }-- >To C N z z z z z z z z z z z z CO > a ° — -... — a LL Cfl N N N Co N N N N N N O C13 Ci30 ¢ 0 >- > >- >- > > >-. >4 >- >. > >. re O 0 10 o v 0. W - Et o LL 5 C O 0 O O 0 O O O 0 O O 0 5 cn 0 z Z Z Z Z Z Z Z Z Z Z Z O LL U .co — g C to co N to N N N U) co to co N Z I- U co co a) a) a) a) a) a) a) a) a) a) A/ N CO > >- >- >- >' > > >' > >' > Q? O WCI = U re M - dm LEI ° cp `• cn (n ? V C 4- z z z o z z z z z z z z 0 ro ---• , — — — — Z w N E c a, Uf t9 ._ Cl) in V) 0 U) U) Cl) Cl) y U) 0 Cl) I p L E a) a) a) a) a) a) Cl) a) a) a) a) 4) J 0 o 0 N > >- > >-. > >- >- >- >- >' >- >- Q w o I-- 0 a ic O a a a a a a a 0 a a a v ° 9 M z z z z z z z z z z z z tit c Cl) U) SS ' Cl) U) N co N N co N N CO N N Y S N CU a) a) Cl) a) Q1 Cl) a) a) a) a) a) o c o >' >- >- >- >- >- >" >- >- >- >- >- }-- o- C o iii c v O J a a) a) CO O F43 '0 75 O o L.. C C° V Y co 8o co 0 Lo _ 2 -a C = 0 N O - < - © O O O 0 O O 0 O O O O y� • Z Z Z Z Z Z Z Z Z Z 2 t .Q 5 c 1\-- - - \ \ - \ - O ` 2 Z g C W g m a> lai a)) o N m ENi V N pr - 82268 >- } >- r } >- } } >- } >- J Z z 0 z° z z 0 z' 0 0 z IC c .£ ?C —IA ..... •••.. — .•... — — — PI a 0 N N N4) CO m (! ) < Ell a8 4) 42 iv 0 0 0 0 0 0 0 0 0 0 0 g • Z Z Z Z Z Z Z Z Z Z Z N N N N in N 0 o 0 0 0 0 0 0 0 0 0 0 O 1 a 4Qp- 2 Z Z Z Z Z Z Z 2 Z Z _ 0 6 !- \ - - - \ - - N in N - N p U ,. N N N y� N N u1 Q C S � S p L N 6) N 6) d C) O N d oiSd1 O F O 0 0 0 0 0 20 20 20 20 20 I2 Fy 2 2 2 2 0 0 0 3 4 - - - - - - - - - - G g 1 , < oQn N = C " O C O oO 61 N 6) 6) 61 a) 6) 6) 0 43 6) ft S .2 6, v O O ao o >- >- >- >- >- >- >- >- >- >- } y�L O O O O O O O O O O O e.. Z 2 2 Z 2 Z 2 Z Z Z 2 zE - - - - - - - - P a V N N N N 0 N (A 0 0 0 15 Q $j g } } } } } } >- 6>- } } } 15 0 0 0 0 0 0 0 0 z Z z 2 z z Z z z z z a i - - - - - - - - - - N N N N N N N N N in N N Q) C) 6) d V N O N 6) N Cal o 0 0 0 0 0 0 0 0 0 0 Z z 2 z Z z z z 2 z z iy Y in 0 CO in N 4) N 0 o S 4 >- >- >- >' >- } r >- >- >- } 6 o 0 o 0 0 o O O O O O c, 0, z 2 Z Z z 2 Z 2 2 2 Z 10 . +.yy`�( C EOg — -- to N N N N N N N — W gaa p {7 6 d m N 1- 0 N a) 61 m - d r } r r )- ›- >" } >"' >- o,• E 0 0 0 0 0 0 0 0 0 0 0 U Z g ° 2 z z z z z z z z z 2 0 a — — — — — — — — — — — m cW • Q 0 ; } } } } } } } } } VI Ce H • o 0 0 0 o n o 0 0 0 0 0 0 Q 4 ? t p c z Z Z z Z 2 z 2 Z Z z ce $ zzg s -2 -- - -- -- --- -- -- -- --- ,.z O ) 2 o t �� in N N N N N N N N N N vi CCD_ NI C3 € ogsos F- w o 0 0 0 0 0 0 0 0 0 0 0 O c vm5 z z z z z z z z z z z Ili CL - - - - - - - - - - a O N N N N tll 4) 4) y y zp w $ b } } } } r } r } } } } _ 0 0 0 0 0 z0 z0 J c � C c 20 0 0 z0 2 w a o F t- < -.- - -- -- \ -- - -- - C= N N N N N in 0 N N N C7 2 8 .2 -E� N 0 d d a m d o d m d o Z a 0 )- >"' } ›- )- } } ›- ›- } a m o Z 2 2 Z Z 2 22 2 Z 2 2 ill C . D I 0 en wg" } } >- r } } >- } r } r a It 0 o 0 Z 2 Z 0 0 2 Z Z Z 2 Z Z Z EZ - — — - — - 3o O. ^ o s II N In 0 €4 yU) N N N N yN� m -`� p C } } >- } >- >- >- } } >- } V d tltltl ` o 0 o o 0 0 0 o 0 0 o ,Z M 3 Z Z Z 2 Z z 2 Z Z 2ia G 6 Q \ \ —� - \ -y - y-y�� \ - - C x 4 x W 6N) 0) in N g 6N) 6) Q) N E 01 } O } } } > } } > } } } } e.jj I0 Z 0 0 0 Z Z Z 2 Z 2 z 0 N in on Ac 421,4 VI g3 .5 § } } }- } } y. } } °}- } S . 0 0 0 0 0 0 0 0 0 0 0 0 0 . 2 Z 2 Z 2 2 2 2 2 2 2 trt ; i v) N y in 0 N VI N N 0) u O l8l } ›- } } 01 } } } r II � 0 0 0 0 0 o Z Z Z Z 2 c z z Z Z Z 2 n$ 1 \ 1 \ \ \ - - \ - C y N N N N N N 2 CA W S a O ,E } >— >— cu } } >- } } } } } S O 0 O o O 0 O a o O 0 elq 2 Z Z Z Z Z Z 2 2 2 Z N N N N N N N N N on N 0 6) 61 61 6) 01 61 6) 6) d N Cl T S 2 >- >- >- >- >- >- > >. } } } o c r._ Z z Z 0 0 0 0 0 0 0 Z — — — — — -- 0 — — a N N 0) N m d d N N V �y.� } >- } } } >- } } } } } c o` F y I-- a s G ¢ ¢ ¢ _ c U ag O O O 0 d c a a 4Q co U o > U G n C J J J 3 ra 2 O O J • Q W0 £3 z' a 6 g ¢ KLEINFELDER I APPENDIX G OIL SPILL CONTINGENCY PLAN (OSCP) - SITE SPECIFIC INFORMATION IS IN OSCP FIGURES (APPENDIX C) Hemberger Compressor Station SPCC Plan 20155174/DEN15O18231 April 2015 © 2015 Kleinfelder Sterling Energy Investments , LLC . Oil Spill Contingency Plan for Operations in Colorado Prepared in Accordance with 40 CFR Part 109 April 17, 2015 Prepared by KL E/NFEL DER Bright People Right Solutions. 1801 California Street, Suite 1100 Denver, Colorado 80202 Copyright 2015 Kleinfelder All Rights Reserved ONLY THE CLIENT OR ITS DESIGNATED REPRESENTATIVES MAY USE THIS DOCUMENT AND ONLY FOR THE SPECIFIC PROJECT FOR WHICH THIS REPORT WAS PREPARED. 20155304/DEN15O18189 Page i of v April 17, 2015 © 2015 Kleinfelder 6 KL EINFEL DER Bilght People Right Solution A Plan Prepared for: Ms. Dena Lund Sterling Energy Investments, LLC Vice President of Operations 1200 17th Street, Suite 2850 Denver, CO 80202 Sterling Energy Investments, LLC. Oil Spill Contingency Plan for Operations in Colorado Prepared by: Katharine Howe Professional Reviewed by: Brad A. Woodard Project Manager III/Regulatory Lead KLEINFELDER 1801 California Street, Suite 1100 Denver, Colorado, 80202 Pi 303.237.6601 Fl 303.237.6602 April 17, 2005 Kleinfelder Project No.: 20155304 20155304/DEN15O18189 Page H of iv April 17, 2015 © 2015 Kleinfelder 1 KL EINFEL DER \------ TABLE OF CONTENTS 1 .0 INTRODUCTION 5 1 . 1 NAME AND ADDRESS OF THE OPERATOR 1 1 .2 OIL DISCHARGE RESPONSE COORDINATOR 1 1 .3 STERLING OIL DISCHARGE RESPONSE OPERATING TEAM 2 1 .4 POTENTIAL MODES OF DISCHARGE 2 2.0 OIL DISCHARGE INITIAL RESPONSE PROCEDURES 5 2. 1 IMMEDIATE RESPONSE ACTIONS 5 2.2 INTERNAL NOTIFICATIONS 5 3.0 EXTERNAL NOTIFICATION PROCEDURES 7 COLORADO OIL AND GAS CONSERVATION COMMISSION 7 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 7 LOCAL EMERGENCY PLANNING COMMITTEE (LEPC) 7 NATIONAL RESPONSE CENTER (NRC) 7 ENVIRONMENTAL PROTECTION AGENCY (EPA) 7 AFFECTED LANDOWNERS 8 4.0 DISCHARGE MITIGATION PROCEDURES 9 4. 1 SURFACE WATER FEATURES AND LAND OWNERSHIP 9 4.2 LIKELY SPILL FLOW DIRECTIONS 10 4.3 INTERCEPT POINTS 10 4.4 OIL DISCHARGE CONTAINMENT 10 4.4.1 LAND CONTAINMENT METHODS 10 4.4.2 CONTAINMENT ON WATERWAYS 11 4.5 OIL RECOVERY 12 4.6 SOIL REMEDIATION 12 4.6.1 INITIAL SOIL REMEDIATION AND TREATMENT 12 4.6.2 SOIL REMEDIATION OPTIONS 13 5.0 TRAINING 14 6.0 REPORTING 15 7.0 REGULATORY BASIS AND CONTINGENCY PLAN UPDATES 16 7. 1 REGULATORY BASIS 16 7.2 CONTINGENCY PLAN UPDATES 16 8.0 LIMITATIONS 17 20155304/DEN15O18189 Page iii of v April 17, 2015 © 2015 Kleinfelder taN KLEINFELOER 0npht Peopie Right Sotvtiont. APPENDICES Appendix A: Colorado Spill Incident Notification Procedures Flowcharts COGCC Spill Forms Appendix B: Sterling Oil Discharge Response Operating Team Emergency Response Contractors Appendix C: Intercept Point Figures Appendix D: Spill Mitigation Figures 20155304/DEN15O18189 Page iv of v April 17, 2015 © 2015 Kleinfelder KL EINFEL DER wyht tape Ryr( Sotunars. OIL SPILL CONTINGENCY PLAN AMENDMENTS Edited Section, Page Date Editor No. Changes Made 20155304/DEN15O18189 Page v of v April 17, 2015 © 2015 Kleinfelder • KL E/NFEL QER Bright hope Afght Sotutran 1 .0 INTRODUCTION This Oil Spill Contingency Plan (OSCP) describes the actions expected of Sterling Energy Investments, LLC (Sterling) employees in the event of a spill of oil or natural gas condensate from facilities in Colorado. This OSCP was prepared for Sterling using components from the Title 40 Code of Federal Regulations (CFR) §109 — Criteria for State, Local, and Regional Oil Removal Plans, and Colorado Oil and Gas Conservation Commission Rule 906 — Spills and Releases. This OSCP is intended to supplement the existing Spill Prevention , Control, and Countermeasure (SPCC) Plan for applicable sites, as required under 40 CFR § 112.7(d)(1 ). This OSCP is intended to provide Sterling operations personnel and supervisors with sufficient information to readily assess an oil discharge, perform containment and cleanup of the discharge, and determine which government agencies to contact and what to report. 1 . 1 NAME AND ADDRESS OF THE OPERATOR Sterling Energy Investments, LLC 1200 17th Street, Suite 2850 Denver, CO 80202 (720) 881 -7100 A copy of this OSCP is on file at the address listed above. 1 .2 OIL DISCHARGE RESPONSE COORDINATOR The Oil Discharge Response Coordinator is charged with the responsibility and delegated commensurate authority for directing and coordinating response operations (40 CFR § 109.5(d)(2). The Oil Discharge Response Coordinator shall be a representative of the operator, located in the United States, available on a 24-hour basis. The Oil Discharge Response Coordinator (24-Hour contact) for Sterling for this OSCP is: Rodney Barnes — Response Coordinator Sterling Energy Investments, LLC Centennial Gas Plant 47285 County Rd 100 Briggsdale, CO 80611 Office: 720.881 .7775 Cell: 303.589.6214 The Oil Discharge Response Coordinator is responsible for the following items: • Assessing the location and source of the discharge and determining if it can be contained; • Assessing the hazards associated with responding to a discharge; • Determining the extent/impact of the discharge; 20155304/DEN15O18189 Page 1 of 17 April 17, 2015 © 2015 Kleinfelder KL EINFEL DER aught PecOre Right Sotutionk • Contacting and dispatching the designated Sterling Oil Discharge Response Operating Team ; • Providing a reliable communications system for the Sterling Oil Discharge Response Operating Team and contractors; • Controlling access to the discharge location and affected areas; • Coordinating the containment and recovery of surface fluids; and • Scheduling clean-up and repairs. 1 .3 STERLING OIL DISCHARGE RESPONSE OPERATING TEAM Appendix B lists the Sterling Oil Discharge Response Operating Team (ODR0T) personnel. These personnel should be called to assist the Oil Discharge Response Coordinator. The ODROT will respond to oil discharges from tank batteries and other facilities in Colorado. ODROT is composed of Sterling staff with knowledge of the potential modes of discharge of oil and natural gas condensate at the facilities; reporting requirements; and materials and equipment available in the event of an oil discharge. ODROT will be prepared, available, and trained in the appropriate safety and discharge response procedures, as detailed in this plan. The Oil Discharge Response Coordinator will lead ODROT. 1 .4 POTENTIAL MODES OF DISCHARGE The reasonably expected modes of failure or accident for which oil could be released from the referenced facilities are as follows: • Bulk Storage Tank Leak or Failure o Failure Modes: Corrosion, vandalism, lightning strikes, valve or piping failure, overfilling. o Rate of Flow: Variable, depending upon the type, size and location of the tank failure. The ambient temperature at the time of the release may affect the viscosity of the oil and thereby impact the rate of flow. Flow rates for corrosion failure are typically low, ranging from less than a gallon per day to a gallon per hour. Flows resulting from valve and piping failures or vandalism typically range from a gallon per hour to the working capacity of the largest tank. Lightning strikes may result in a release that is essentially instantaneous. o Discharge Quantity: Variable depending upon the type and location of the failure. The total quantity discharged would generally not exceed the working capacity of the largest tank. o Preventative Measures: Personnel routinely perform visual inspections of storage tanks. Storage tanks are constructed in accordance with API industry standards. Materials used in constructing the tanks are compatible with the substances stored. Where practicable, earthen berms or other diversionary structures are utilized to control any released fluids. Tanks are appropriately sized to minimize the risk of overfilling. 20155304/DEN 16O18189 Page 2 of 17 April 17, 2015 © 2015 Kleinfelder KLEINFELDER DER fkigh;People Rig h(5ofutnons. • Tanker Truck Loading and Unloading Operations o Failure Modes: Piping or valve failure, tank failure, overflow, and human error. o Rate of Flow: Variable depending upon the type, size and exact location of the failure, and the amount of oil in the tanker truck and storage tank. The ambient temperature at the time of the release may affect the viscosity of the oil and thereby impact the rate of flow. Flow rates resulting from piping and valve failures can range from 1 gallon per hour up to 400 barrels (bbls) per hour. The flow rate for tank truck overflows typically will not exceed 5 to 10 bbls per minute. Tank failures may result in releases that are essentially instantaneous. o Discharge Quantity: Variable depending upon the type and location of the failure. The total quantity discharged would not exceed the working capacity of the largest tank. o Preventative Measures: Tanker truck loading and unloading operations are conducted in accordance with United States Department of Transportation regulations (49 CFR 177). All loading operations are attended by the truck driver. No smoking or open flames are allowed in the vicinity of the storage tanks and loading area. Wheel chocks are placed at the wheel nearest the truck loading connection to reduce the risk of the truck movement during loading operations. Following the completion of loading operations, the transfer line is disconnected and all valves and outlets on the tanker truck and the storage tank are visually inspected for leakage prior to vehicle departure. o In addition, for truck loading where the loading occurs outside of containment, absorbents are readily available for use in the case of a release. • Process Unit Failure (Separator/Heater Treater/Gun Barrel) o Failure Modes: Process vessels may potentially rupture, or associated lines, valves and gauges may fail or leak. o Rate of Flow: Variable, depending upon the mode and extent of the failure. The maximum expected rate of flow from a process unit failure is the oil process rate of the equipment plus any additional fluid volume contained in the vessel above the elevation of the rupture. o Discharge Quantity: Variable, depending on the type of failure and the length of time that the failure went undetected. o Preventative Measures: Personnel routinely perform visual inspections of process units. Process units are constructed in accordance with API and ASME industry standards. Where practicable, earthen berms or other diversionary structures are utilized to control any released fluids. 20155304/DEN15O18189 Page 3 of 17 April 17, 2015 © 2015 Kleinfelder Kt E/NFEL OER HrigM..t.rc re Rsyhf so!,tiom • Piping Failure o Failure Modes: Both aboveground and buried pipelines may rupture or corrode and leak. Associated flanges, screwed connections, valves and gauges are also subject to corrosion and may fail or leak. Where practicable, earthen berms or other diversionary structures are utilized to control any released fluids. o Rate of Flow: Variable, depending on the size and location of the piping related failure. o Discharge Quantity: Variable depending upon the type and extent of the failure and the length of time that the failure went undetected. o Preventative Measures: Personnel routinely perform visual inspections of aboveground piping and buried flowline right-of-ways to detect failures. As warranted by soil conditions, corrosion protection is provided for buried pipelines. • Compressor Engine Oil Sump Failure o Failure Modes: Corrosion, vandalism , valve or piping failure, overfilling, mechanical damage to sump. o Rate of Flow: Variable, depending upon the type, size and location of the failure. Flow rates for corrosion failure are typically low, ranging from less than a gallon per day to a gallon per hour. Flows resulting from valve and piping failures or vandalism typically range from a gallon per hour to instantaneous. Mechanical damage to the engine sump may result in a release that is essentially instantaneous. o Discharge Quantity: Variable depending upon the type and location of the failure. The total quantity discharged would not exceed the working capacity of the oil sump. o Preventative Measures: Where practicable, floor drains, containment structures, or sorbent materials are utilized to control releases of lubricating oil. Oil changes are attended to prevent accidental spills of used and unused oils. 20155304/DEN15O18189 Page 4 of 17 April 17, 2015 © 2015 Kleinfelder ra EINFEL DER itigM. Plcpte Right Soluttont 2.0 OIL DISCHARGE INITIAL RESPONSE PROCEDURES Facilities are visually inspected on each visit by the operator. These visual inspections are made to insure that the facility is operating properly and to verify that there are no signs of spills, releases, or potential for spills. Production records are available for review to indicate anomalies in flow which may be an indicator of a spill or release. 2.1 IMMEDIATE RESPONSE ACTIONS If a spill or release is discovered using the above methods, then the following steps could be taken to reduce the magnitude of the spill and initiate containment and cleanup: • Account for personnel and assure the safety of personnel. In the case of fire, explosion, or exposure hazards, evacuate all personnel . • Stop the release at the source, if such action can be performed without risk of injury, and remove all sources of ignition. • Position fire suppression equipment, if necessary. • Alert the local fire department, if necessary. • Shut off pumps and close valves that allow oil to flow to the segment of the system from where the spill is occurring. • Alert adjacent property owners/operators, as necessary. • If conditions have been deemed safe, qualified personnel are to attempt to contain the spill. Prevent or divert spilled oil from approaching structures, in particular, water or storm drains. Sorbent material, spark-proof shovels, brooms, neoprene gloves, and other spill response materials may be obtained and utilized as necessary. • Repair, plug , or patch the leaking equipment if practical and can be done without injury. • Contact Sterling's Oil Discharge Response Coordinator or other Oil Discharge Response Operating Team members listed in Appendix B to provide details of the situation and to receive further instruction regarding additional and cleanup actions, as needed. The Flowcharts in Appendix A provide guidance on when and how to report incidents to federal, tribal, and state agencies. Appendix A also contains forms for organizing incident information for these external notifications. 2.2 INTERNAL NOTIFICATIONS Table B-1 in Appendix B provides internal notification numbers for the Sterling Oil Discharge Response Operating Team . The Colorado Oil Discharge Response Procedures Flowcharts in Appendix A also describe the actions that the Oil Discharge Response Coordinator should take upon initial notification of a discharge. Following the initial notification , the Oil Discharge Response Coordinator and field personnel will work collectively to: 20155304/DEN15O18189 Page 5 of 17 April 17, 2015 © 2015 Kleinfelder KLE/NFELQER Prcx>. �t 9Mivaor 3. • Dispatch the Sterling Oil Discharge Response Operating Team along with emergency response contractors as needed. A list of emergency response contractors is included in Table B-2 (Appendix B); • Notify the response contractors of pertinent preliminary information outlined on the Release Notification Form; and • Utilize the Discharge Mitigation Procedures provided in Section 4.0 of this OSCP to provide initial containment, recovery, and soil remediation. 20155304/DEN15O18189 Page 6 of 17 April 17, 2015 © 2015 Kleinfelder KL E/NFEL DER Hngnt',cope Right 5olutiom. 3.0 EXTERNAL NOTIFICATION PROCEDURES Spill reporting is an important part of environmental management. There can be fines and penalties imposed upon a company for not properly reporting a spill if it is considered a reportable spill. This section outlines external notification procedures and to whom the spill must be reported. External discharge reporting requirements are required by state and federal regulations relating to reportable discharges. However, Sterling personnel are not to contact state or federal authorities unless requested to do so by Oil Discharge Response Coordinator or his designee. Appendix A Flowcharts can be used to determine which agencies should be contacted . The following regulatory agencies may need to be contacted in the event of a reportable spill or other emergency. Contact information for agencies is included in the Appendix A Flowcharts. COLORADO OIL AND GAS CONSERVATION COMMISSION Discharges associated with oil and gas production activities in the State of Colorado are managed under the jurisdiction of the Colorado Oil and Gas Conservation Commission (COGCC). COGCC must be contacted in the event of a spill or any discharge that has left the vicinity of the wells or tanks. COGCC must be notified verbally within 24 hours in the event of any discharge that impacts or threatens to impact any Water of the State, a residence or occupied structure, livestock, or a public byway, or a spill greater than 5 bbls. A written report of the spill must be submitted within 10 days. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT Any spill that enters Waters of the State should be immediately reported to the Colorado Department of Public Health and Environment (CDPHE) by phone. LOCAL EMERGENCY PLANNING COMMITTEE Local Emergency Planning Committees (LEPCs) work to understand chemical hazards in the community, develop emergency plans in case of an accidental release, and look for ways to prevent chemical accidents. The LEPC should be contacted if a release is not contained or threatens the health or safety of the local population. Contact information is included in Appendix A. NATIONAL RESPONSE CENTER The National Response Center (NRC) is notified in the event of an oil spill that has reached or could potentially reach Waters of the U.S. The NRC will in turn notify the U.S Coast Guard. They will contact the region in which the spill occurs and a regional coordinator may be dispatched to the site depending on severity of the spill. ENVIRONMENTAL PROTECTION AGENCY The NRC will notify the United States Environmental Protection Agency (EPA) regarding a discharge. 20155304/DEN15O18189 Page 7 of 17 April 17, 2015 © 2015 Kleinfelder KL E/NFEL DER ` Bright Peopte Rrght$olutionc z_easAFFECTED LANDOWNERS The Oil Discharge Response Coordinator will also notify any potentially affected landowners along the discharge route. The land use in most of the area includes farmland . Notification to affected landowners will enable ranchers to withdraw livestock from areas where they may drink water impacted by the spill. Following cleanup and the return to fresh water conditions, Sterling will notify the affected landowners that it is safe to allow livestock to drink from affected creeks again. 20155304/DEN15O18189 Page 8 of 17 April 17, 2015 © 2015 Kleinfelder KL E/NFEL DER Wight oeop%e Right Souuoanz 4.0 DISCHARGE MITIGATION PROCEDURES The information contained within this section is intended to provide guidance on containment, recovery, and initial treatment measures to be applied to oil/natural gas condensate spills which may be managed with the equipment and expertise readily available to the ODROT. Larger, uncontrolled spills may require specialized equipment and expertise. Immediately upon observance of a discharge that leaves the facility and notification to the Oil Discharge Response Coordinator, the ODROT and/or contracted field personnel shall initiate containment, recovery, and cleanup actions in order to mitigate potential pollution of navigable waters and soil contamination. The Sterling Centennial Gas Plant office in Briggsdale, CO will serve as the discharge operations center: Sterling Energy Investments, LLC Centennial Gas Plant Office 47285 County Rd 100 Briggsdale, CO 80611 Office: 720.881 .7775 A 120 minute response-time is possible from the Sterling Centennial Gas Plant to Sterling operations in Weld and Logan Counties. The following equipment is deployable within 2 hours from the Sterling Centennial Plant: • Shovels • Booms • Absorbent materials • Backhoes • Two-way radios Contractors listed in Table B-2 (Appendix B) have incident response materials and equipment including vacuum trucks and earth movers. Major incident response materials would come from Belfor Environmental (Located in Denver, CO). Safely prevent oil contact with surface waters whenever possible. Oil discharges that do reach water should be contained quickly with floating booms or other mechanical barriers. Free oil may be removed from the water by the use of a vacuum truck or by oil-skimming equipment. Remaining free oil may be removed from the water by the use of oil-absorbent materials such as spray-sorb. Oil-absorbent materials remove oil from shoreline soils, rocks, and vegetation. Oil-contaminated materials may require removal to a suitable treatment site for cleanup. 4. 1 SURFACE WATER FEATURES AND LAND OWNERSHIP Figures in Appendix C show the surface water features in the vicinity of Sterling's facilities in Weld and Logan Counties, Colorado. The areas along the potentially affected waterways are private land . 20155304/DEN15O18189 Page 9 of 17 April 17, 2015 © 2015 Kleinfelder KL E/NFELOER &rght Peop'e Night Sofutiom 4.2 LIKELY SPILL FLOW DIRECTIONS Discharge from Sterling facilities could potentially flow toward various waterways, depending on the area in which the facility is located. The predominant direction of flow in the area as well as the potential waterways which could be impacted are listed below by location within Weld and Logan Counties: • Bob White Compressor Station — Southeast to an unnamed pond • Hill Compressor Station — South/southwest to unnamed streams • Hemberger Compressor Station — Southwest to unnamed stream • Grover Compressor Station — East to unnamed stream • New Raymer Compressor Station — Southwest to unnamed stream • Yenter Gas Plant — South to unnamed stream • Centennial Gas Plant — Southeast to unnamed stream 4.3 INTERCEPT POINTS An "Intercept Point" is defined as a point where a waterway intercepts a roadway, and provides an accessible point for the ODROT to respond to oil discharges to water. Proposed intercept points for the Sterling operations in Colorado are shown in Appendix C figures. The goal is to capture discharge at the earliest point along affected waterways. The ODROT should always search for additional intercept points closer to a discharge than the mapped intercept points. Mapped intercept points in Appendix C were determined from the best GIS information available. Where no road/stream intersections were found down gradient of facilities, however, it was not possible to map intercept points. In those cases, ODROT will have to rely on knowledge of un-mapped local roads and topography to determine alternative intercept points. Be aware of man-made features, like canals and ditches, which may unexpectedly influence flow directions. 4.4 OIL DISCHARGE CONTAINMENT Efforts should be made to prevent or stop spilled product from entering any water body. Oil discharges confined to the land surface are easier to manage than discharges that have reached a waterway. The first oil spill response action should be containment to prevent migration to Waters of the U.S. Oil containment measures may be broadly categorized into two groups: land-based and water- based, as described below. Appendix D provides examples of various containment methods. 4.4.1 LAND CONTAINMENT METHODS Land containment of oil discharges can be achieved by using minor earthworks such as trenches and earth dams. Trenches would be constructed using a backhoe and dozer. In emergency situations when heavy equipment is not immediately available, small trenches and dams can be constructed with shovels to provide a temporary hindrance to the migration of spills. Figure D-1 (Appendix D) provides details of a typical interceptor trench. Trench construction should include the use of a plastic liner, when possible, to prevent downward migration into subsurface soils and groundwater. Relatively shallow trenches may be 20155304/DEN15O18189 Page 10 of 17 April 17, 2015 © 2015 Kleinfelder I KL E/NFEL DER BnglR Peop:e Rlgnt Sorutroni strategically placed downslope of a spill. This method is effective in preventing subsurface contamination of water and eventual discharge to streams and other water bodies. Earthen dams may be constructed across ditches or low areas to contain a discharge and stop its flow. The entire flow of the spilled material and any surface drainage may be contained in this fashion. Construction materials include earth, wood , and sandbags. The dam should be lined with plastic sheeting , whenever possible. Dams should be of sufficient size to contain the entire discharge volume; insufficient capacity may result in overtopping and/or dam failure. 4.4.2 CONTAINMENT ON WATERWAYS Containment measures on waterways generally include the use of booms, barriers, or temporary dams. The type and size of a boom will depend on the specific location and the conditions within which the boom will be used . Given the size of the water bodies that could initially be impacted , approximately 100 feet of boom material may initially be necessary. It is important that buoyant material be used within the boom; otherwise it will become water logged and sink after several hours. Commercial sorbents have greater capacity to absorb oil and other petroleum products, last longer, and can be reused. Foam sections have good sorbent capacity and excellent buoyancy. Rope or wire can be used to hold the boom sections in place. Figures D-4 and D-5 (Appendix 0) illustrate methods of connecting booms together and construction of a "jellyroll" or "sausage roll" using improvised sorbent barriers. Attention to proper boom deployment is critical. The angle of the boom relative to the flow direction must be related to water flow velocity in order to achieve effective containment. Several booms arranged in parallel may be necessary to contain the discharge. In addition, the use of several booms permits the removal of a boom for cleaning . Figures D-6 to D-8 (Appendix D) illustrates boom deployment methods. The chart at the bottom of Figure D-6 illustrates the proper angle to deploy the boom based on water velocity. The higher the stream velocity, the more perpendicular the boom will be with respect to the crossing . In the example shown, proper boom deployment is at an angle of 24° for a stream flow velocity of 175 feet/minute. Dams and weirs may also be used for ditches with flowing water and for smaller streams. The use of dams may be applicable during low-flow conditions. However, a 404 Permit from the U.S. Corps of Engineers may need to be obtained before a dam can be constructed. Figure D-2 (Appendix D) illustrates the use of dams and weirs. Weirs made from plywood , lumber and sheet metal may be used in ditches with flowing water and may be placed to completely or partially block culvert openings. These barriers may be suspended from stakes on either side of the culvert openings and raised or lowered to maintain the desired water flow while retaining the oil . Recovery of material collected behind dams and weirs may be made with the use of sorbents, skimmers or by direct suction. These methods are typically used where it is necessary to allow the water to flow. Water bypass or underflow dams may also be constructed on small, slow-flowing streams. Water bypass involves first constructing an earthen dam to stop the flow of water, and then inserting a pipe below the level of the spilled material and discharging the water on the other side of the dam (Figure D-3, Appendix D). It is important to note that the discharge end of the pipe should be inclined , but not above the level of the dam or overtopping and failure will result. Fixed barriers can be used in streams with soft beds where stakes can be driven. A fence barrier may be installed to span the width of a stream less than 3 feet deep and may be 201553041DEN 15O18189 Page 11 of 17 April 17, 2015 © 2015 Kleinfelder KL E/NFEL CER Bright.^rove Rrghi Solutions. anchored at both ends with steel or wooden stakes. Stakes are driven into the stream bottom at 3 to 6 foot intervals. Straw bales or commercial sorbents are placed on the upstream side. The barrier should be angled against the current for collection of product along the shore. Multiple fence barriers can be used to provide backup against potential losses from upstream barriers. Net or chicken wire barriers can be constructed for the same purpose. 4.5 OIL RECOVERY Recovery efforts from an oil discharge must be undertaken as soon as it is practical and safe to do so. Focus on rapid recovery of spilled materials is required to mitigate potential dangers or hazards to the environment. Recovery methods generally include the construction of interception trenches, direct suction, and the use of sorbent materials. Oil may be recovered from an interception trench or the ground surface using direct suction. The most common means of applying suction would be the use of vacuum trucks or portable pumps. Large capacity wet service shop vacuums may also be used if there is an available power source nearby. Suction screens may be required to prevent hose plugging by floating debris and to prevent pump damage. Care should be taken to reduce the uptake of fresh water in order to minimize the amount of material which requires disposal. Oil recovered from a discharge can be taken to a recycling facility for reprocessing . Sorbent materials may also be used to soak up oil or other fluids. They are commonly used for final clean up and recovery of small amounts of product or to remove product in places that are inaccessible by other means of recovery. 4.6 SOIL REMEDIATION This section is intended to be used as an overview of soil remediation techniques for oil discharges, but is not intended to be a complete guide to remediation planning and execution. Depending on the severity of the spill, outside expertise may be required to design and execute a soil remediation plan. 4.6.1 INITIAL SOIL REMEDIATION AND TREATMENT Initial soil remediation and treatment should be conducted to the extent possible. Initial treatments are designed to minimize the potential long-term impacts to soils which can be costly to remediate. Remediation is most easily accomplished if the spill is dealt with immediately, thereby not allowing the discharge to soak into the ground . The techniques for initial clean-up of small discharges may consist of simply shoveling affected soil into a drum, labeling the drum, and disposing of it in a landfill. When remediating small discharges it is important to ensure that all of the affected soils have been removed or otherwise managed, and all actions taken to clean-up the discharge, repair the problem, and prevent further occurrences are well documented . Larger discharges may require excavation using a backhoe, trackhoe, or dozer. Soil handling must be minimized to the extent possible during wet soil conditions. Typically if there is a potential to create ruts that are greater than 3 inches deep, equipment should be kept off the soils and the discharge should be accessed on foot. It may be necessary to strip the topsoil ahead of the machinery when accessing the site to prevent compaction and destruction of the soil structure. Stockpile topsoil away from spoil materials to avoid mixing the two together. 20155304/DEN15O18189 Page 12 of 17 April 17, 2015 © 2015 Kleinfelder KL E/NFEL CER Gogh(People Nigh(SoNj(ions. When backfilling , fill the excavation first with spoil materials, leaving a low mound to account for settling, then re-spread topsoil evenly on top of the mound. During winter, do not replace the topsoil until the spoil pile has settled. 4.6.2 SOIL REMEDIATION OPTIONS For larger discharges, evaluation of site conditions is first conducted to determine which cleanup option(s) are best suited to the site. Factors evaluated include the slope of the site, the soil matrix and chemistry, the depth to groundwater, the extent of contamination, and the applicable cleanup goals. The cleanup goals may differ depending on the land ownership and regulatory agencies involved. Soil sampling is typically conducted to evaluate remediation options. There are several potential soil remediation methods for petroleum-impacted soils, including natural attenuation, bioremediation, soil-vapor extraction, excavation and on-site or off-site land farming , and excavation and off-site disposal. The results of the site assessment and sampling will be used to select the most viable option. If off-site disposal is selected , a local landfill permitted to accept such wastes must be contacted prior to transporting affected soils to determine profiling and sampling requirements for disposal. After implementation of the remediation, confirmation sampling is typically performed to document that the oil has been removed to below the applicable standards and cleanup goals. Monitoring of the growth of vegetation on the site may also be required . 20155304/DEN15O18189 Page 13 of 17 April 17, 2015 © 2015 Kleinfelder Th KL EINFEL DER 8nght Prop)e /NM Sofunoni. 5.0 TRAINING Appendix B lists the current members and contact information for the ODROT. The ODROT will be trained in discharge prevention and spill response prior to the assignment of job responsibilities. Training will be completed under the charge of the Oil Discharge Response Coordinator or another qualified, designated representative of Sterling. At a minimum, the training will include: • Personnel responsibilities under this OSCP; • Procedure for contacting the Oil Discharge Response Coordinator for emergency response; • Proper deployment of discharge response equipment and materials; • Applicable pollution control laws, rules, and regulations; and • General facility and pipeline operations. A discharge prevention briefing for appropriate oil-handling personnel will be scheduled at least annually (this may be done in conjunction with other required annual training) and will be documented in the area training logs. At a minimum, annual briefings will include: • The contents of and any revisions to this OSCP; • Descriptions of known discharges or failures and their corrective actions; • Recently developed precautionary measures. 20155304/DEN15O18189 Page 14 of 17 April 17, 2015 © 2015 Kleinfelder KL E/NFEL C?ER Bright People Right Solutions 6.0 REPORTING The COGCC requires a Form 19, Spill/Release Report to be submitted no less than 72 hours after the discovery of the spill, if the initial report to the COGCC was not made using Form 19. See Appendix A for a hard copy of Form 19 with reporting instructions. The Form 19 includes the following: • The operator's name and operator number; • The date of the incident; • The facility name, number, and legal description; • Material spilled , and volume spilled and recovered ; • A description of the spilled materials, including type and amount; • A description of the circumstances creating the spill; • The location of the spill with respect to the nearest fresh and usable water resources if less than a mile away; • Corrective actions taken; • Additional agency/party notifications; and • Any other information that the commission may require. The COGCC requires a written supplemental report on Form 19 to be submitted within 10 days of any release which is reported to them. This supplemental report includes the following: • 8 'A x 11 inch topographic map showing the governmental section and location of the spill; or • An aerial photograph showing the location of the spill; • All pertinent information about the spill/release not previously reported; and • Information relating the initial mitigation, site investigation, and remediation measured conducted . Surface owners are to be notified of any spill or escape that is required to be reported to the COGCC. This notification must occur within 24 hours from the discovery or knowledge of the spill or escape and must include, at a minimum , the information provided to the COGCC in the initial report. Other reports may be required by the EPA or other agencies with jurisdiction. 20155304/DEN15O18189 Page 15 of 17 April 17, 2015 © 2015 Kleinfelder KL EINFEL DER \ ' angM People Elk So/miens 1 —Y 7.0 REGULATORY BASIS AND CONTINGENCY PLAN UPDATES 7.1 REGULATORY BASIS The Oil Pollution Act of 1990 established requirements for contingency planning by both government and industry. There are rules under §4202 for: ( 1 ) providing for the establishment of spill contingency plans for all areas of the U .S . ; (2) mandating the development of response plans for individual tank vessels and certain facilities for responding to a worst case discharge or a substantial threat of such a discharge; and (3) providing requirements for spill removal equipment and periodic inspections. Criteria for state, local and regional oil removal contingency plans are located in Title 40 CFR §109. This legislation was used to guide the creation of this document. Title 40 CFR §109.2 defines "OH" as, "any kind or in any form, including, but not limited to, petroleum, fuel oil , sludge, oil refuse, and oil mixed with wastes other than dredged spoil." For the purpose of this document, natural gas condensate liquids and produced water fall under the definition of oil as "petroleum," and may be regulated as oil. This OSCP describes response and reporting requirements in the event of spills leaving Sterling facilities located in Colorado. Such spills could potentially enter waters of the United States which include ". . . lakes, rivers, streams; waters which are used for recreation; and waters from which fish or shellfish are taken and sold in interstate or foreign commerce. " (Title 49 CFR §194.5). Waters of the US are protected by the 1972 Clean Water Act. SARA Title Ill , Section 304 (CFR 40 Section 355.40 (b) (3)) requires written follow-up emergency notices to be provided after a release as soon as practical after the release. COGCC requires a written notification within 10 days of the initial clean-up activities associated with a release. 7.2 CONTINGENCY PLAN UPDATES When a new or different operating condition becomes in effect or new information substantially affects the implementation of a response plan, the operator should modify this OSCP to address such a change. Examples of changes in operating conditions that would cause a significant change to an operator's response plan might be: • Construction of major new facilities not covered by this plan; • Relocation or replacement of facilities in a way that substantially affects the information included in the response plan, such as a change to the worst case discharge volume; • Emergency response procedures; • The Oil Discharge Response Coordinator changes; • A change in the National Contingency Plan or an Area Contingency Plan that has significant impact on the equipment appropriated for response activities; and • Any other information relating to circumstances that may affect full implementation of this OSCP. Updates to this OSCP should be noted in the Amendments section. 20155304/DEN15O18189 Page 16 of 17 April 17, 2015 © 2015 Kleinfelder KL EINFFL DER wy,e rev,* AVM 5Ph/tAfK 8.0 LIMITATIONS This work was performed in a manner consistent with that level of care and skill ordinarily exercised by other members of Kleinfelder's profession practicing in the same locality, under similar conditions and at the date the services are provided . Our conclusions, opinions, and recommendations are based on a limited number of observations and data. It is possible that conditions could vary between or beyond the data evaluated . Kleinfelder makes no other representation , guarantee, or warranty, express or implied, regarding the services, communication (oral or written), report, opinion, or instrument of service provided . This report may be used only by the Client and the registered design professional in responsible charge and only for the purposes stated for this specific engagement within a reasonable time from its issuance, but in no event later than two years from the date of the report. The work performed was based on project information provided by Client. If Client does not retain Kleinfelder to review any plans and specifications, including any revisions or modifications to the plans and specifications, Kleinfelder assumes no responsibility for the suitability of our recommendations. 1n addition, if there are any changes in the field to the plans and specifications, Client must obtain written approval from Kleinfelder's engineer that such changes do not affect our recommendations. Failure to do so will vitiate Kleinfelder's recommendations. 20155304/DEN15O18189 Page 17 of 17 April 17, 2015 © 2015 Kleinfelder KLEINFELAER APPENDIX A Colorado Spill Incident Notification Procedures Flowcharts COGCC Spill Forms 20155304/DEN15O18189 April 17, 2015 © 2015 Kleinfelder Flowchart 1 — Colorado Spill Incident Notification Procedures (1. Authorized personnel must immediately telephone: 1. Has the spilled material contacted • National Response Center (NRC) 800.424.8802 surface water or Waters of the State, • Colorado Oil and Gas Conservation Commission (COGCC) 303.894.2100 resulted in a "visible sheen" on water, or • Colorado Department of Public Health and Environment (CDPHE) threatened groundwater? Yes 303.756.4455 or 877.518.5608 (after hours) 2. Was the spilled material a "Hazardous • Local Emergency Planning Committee (LEPC) or local fire department 911 Chemical" defined by 40 CFR 302? 2. The following written reports are required within the timeframes indicated: • Report to COGCC verbally or in writing as soon as practicable, but no more than twenty-four (24) hours after discovery of the spill/release. Written • reports to COGCC should be done using Form 19. • • Send a written report to the local fire department or LEPC representative as Was the spill less than one barrel (42 gallons)? _ soon as practicable. Yes No ♦♦ �.i Not required to be reported to the COGCC. Do maintain )--,•-i Was the spill more than one barrel (42 gallons) and records to furnish upon request by regulators. outside of berms or other secondary containment? • Yes C • Telephone COGCC at 303.894.2100 within 24 hours and file --► a COGCC Form 19, Spill/Release Report within 72 hours. Was the spill more than 5 barrels (210 gallons) and inside of Yes • Make a supplemental report on Form 19 not more than 10 berms or secondary containment? calendar days after the spill/release is discovered t describing mitigation, investigation, and cleanup efforts completed. • • Does the spill or release travel . 4 offsite of the facility Yes The affected surface owner or tenant must be notified of all ��= reportable spills within 24 hours Did the incident occur on a lease managed by the ULM Yes _, Not Applicable for this IRP Did the incident occur on leased Indian [ Lands? Yes Not Applicable for N ' • this IRP Does the incident involve transportation of product or a .-- - pipeline as listed below? • a person is killed or injured and required hospitalization • there is an evacuation of the general public lasting Yes more than an hour /' 1. Notify the NRC within 12 hours of the incident, • a major transportation artery is shut down for an hour 800.424.8802, http://www.nrc.uscg.miljindex.html or more 2. Natural gas releases from interstate pipelines that result in • the flight pattern of an aircraft is altered injury or death must be reported to the Colorado Public • there is fire, spillage or suspected contamination Utilities Commission Pipeline Safety Group, 800.888.0170, • there is estimated property damage of $50,000 or more and appropriate LEPC. • there is an event that results in emergency shutdown of a liquid natural gas facility • if there is a leak on a gas pipeline, a liquid natural gas I Report radioactive spills to: system, a master meter system or a propane system 1. NRC 800.424.8802 http://www.nrc.uscg.mil/lndex.html that results in the closure of a roadway. 2. Look up and contact the Local Emergency Planning • there is any situation that, in the judgment of the Committee (LEPC) representative listed at operator should be reported even though it does not Yes lutp://www.coemergency.com/o/local•Info- meet the above criteria. II ` sources.html N i Does the spill involve radiation? Contact the Colorado Parks and Wildlife (CPW) Yes Headquarters, 303.297.1192 l';', 1, til Does the incident involve a threat to fish or wildlife? �1. Contact the NRC 800.424.8802 Nu http://www.nrc.uscg.mil/index.html Yes 1. Look up and contact the Local Emergency Planning Is the release not contained or threatens the health ` Committee (LEPC) representative listed at or safety of the local population? http://www.coemergency.com/p/local•info- sources.html I KL E/NFEL DER 6•n,hr rh•gp;o .F,.,tr Sohn,., Flowchart 2 — LEPC and SERC Notification Procedures Does the spill threaten the health and safety of the public? Does the release threaten waters of the State? Yes (0 Contact one of the following Colorado State Emergency Response Commission (SERC) Contacts Mr. Jack Cobb, CEPC Co-Chair Mr. Greg Stasinos, CEPC Co-Chair Mr. Dave Hard, CEPC Co-Chair Colorado Division of Emergency Management Colorado Dept. of Public Health and Environment Department of Public Safety 9195 East Mineral Avenue #200 4300 Cherry Creek Drive South Division of Homeland Security and Emergency Centennial, CO 80112 Denver, CO 80246 Management, Office of Emergency Management 720.852.6603 303.692.3023 720.852.6611 greg.stasinos@state.co.us dave.hard@state.co.us i v e Call the applicable Colorado Local Emergency Planning Committee (LEPC) Contacts listed below Mr. Todd Norris, Commander Logan County Weld County Police - Emergency Management Bob Owens Office of Emergency Management 9195 East Mineral Avenue #200 CERT Government Advisor 1150 "O" St Centennial, CO 80112 421 North 4th Street Greeley, CO 80631 720.382.5700 Sterling, CO 80751 970.356-4015X3990 720.641.0887 970.522.9700 (24 HOUR) 970.304.4015 X2700 I KL E/NFEL ADE'R' Aright People Right Solutions Flowchart 3 — Colorado Non-Spill Incident Notification Procedures / Unanticipated bypasses that cause an exceedance of the Does the incident involve a National Pollutant Discharge Elimination Yes effluent limits or any violations of maximum daily * discharge limits need to be reported within 24 hours to System (NPDES) permit? the NRC 800.424.8802 http://www.nrc.uscg.mil/index.html Also contact the state agency who issued the permit. y TIf a facility has an air permit but the permit does not allow for • ?' or a substance, or if the facility does not have an air permit, Does the incident involve the release of Hazardous Air Yes then all releases in excess of the CERCLA / EPCRA reportable * quantity for that substance must be reported to the Pollutants? NRC 800.424.8802 http://www.nrc.uscg.mil/index.html and the appropriate Local Emergency Planning Committee - (LEPC). J= Did the incident t % \ result in any of the 1. Verbally report to OSHA within 8 / 1. Call 911. l following; hours 800.321.5742 or the OSHA 2. Supervisors should death, days away Denver Area Office, 303.844.5285 Does the incident Yes complete an from work, Yes 2. COGCC is to be informed within Involve an injury to * Incident * restricted work or * 24 hours of all accidents or fires an employee? Investigation Form transfer to another of major consequence at located in Appendix job, medical 303.894.2100. Form 22, Accident B for each incident treatment beyond Report available at and near-miss first aid, or loss of http://cogcc.state.co.us/ ` incident. i consciousness? ` ea Yes Call local law enforcement and Does the incident involve a theft? Company insurance provider NNo V C • Notify the NRC within 12 hours if a person is killed or injured, Does the incident involve a transportation of Yes there is an evacuation of the genera! public lasting more than an product or a pipeline? * hour, a major transportation artery is shut down for an hour or more, the flight pattern of an aircraft is altered, or there is fire, spillage or suspected contamination at 800.424.8802 or littw//www.nrc.uscg.mil/index.html Does the incident involve a fire or blowout? f • Notify the CO Public Utilities Commission pipeline safety group, 800.888.0170 J Yes' Is the incident a large fire or a fire No beyond the incipient phase Is the fire a non-emergency? and/or a blowout? ' Yes • Yes I 1. Call 911 Supervisors should complete an 2. Contact well control specialists (e.g. Wild Well, 281.784.4700) Incident Investigation Form 3. If the fire threatens the health or safety of the local population also located in Appendix B for each contact the appropriate LEPC. incident and near-miss incident 4. COGCC is to be informed within 24 hours at 303.894.2100 and a written report is to follow within 15 days. J — t Does the incident affect offsite properties? Yes I Land owner notificationis required in the State [. of Colorado. ! KLE/NFELDER Bright People Right Solutions FORM FOR OGCC USE ONLY 19 State of Colorado ' ifArt OP COtOCAPO Rev 6/99 Oil and Gas Conservation Commission *� o , '1120 Lincoln Street, Suite 801 , Denver, Colorado 80203 (303)894-2100 Fax:(303)894-2109 SPILL/RELEASE REPORT Spill report taken by: ['This form is to be submitted by the party responsible for the oil and gas spill or release. Any spill or release which may impact waters of the State must be reported as soon as practicable; any spill over 20 bbls must be reported within 24 hours and all spills over five bbls must be reported within ten days. FACILITY ID: Submit a Site Investigation and Remediation Workplan (Form 27) when requested by the Director. J OPERATOR INFORMATION Name of Operator: OGCC Operator No: Phone Numbers Address: No: _ City: State: Zip: Fax: Contact Person: E-Mail: DESCRIPTION OF SPILL OR RELEASE Date of Incident Facility Name & No.: County: Type of Facility (well, tank battery, flow line, pit): QtrQtr: _ Section: Well Name and Number: - Township: Range: API Number: Meridian: Specify volume spilled and recovered (in bbls) for tie following materials: Oil spilled: Oil recov'd: Water spilled: Water recov'd: Other spilled: Other recov'd: Ground Water impacted? ❑ Yes ❑ No Surface Water impacted? ❑ Yes No Contained within berm? ❑ Yes ❑ No Area and vertical extent of spill: x flurrent land use: _ Weather conditions: .3oil/geology description: -IF LESS THAN A MILE, report distance IN FEET to nearest. . . . Surface water: wetlands: buildings Livestock: water wells: Depth to shallowest ground water: Cause of spill (e.g., equipment failure, human error, etc.): Detailed description of the spill/release incident: CORRECTIVE ACTION Describe immediate response (how stopped, contained and recovered): Describe any emergency pits constructed: How was the extent of contamination determined: Further remediation activities proposed (attach separate sheet if needed): Describe measures taken to prevent problem from reoccurring: OTHER NOTIFICATIONS List the parties and agencies notified (County, BLM, EPA. DOT, Local Emergency Planning Coordinator or other). Date Agency Contact Phone Response Spill/Release Tracking No: FORM ;;I` �„�^ State of Colorado �,O FOR O6CG USE ONLY 22 Oil and Gas Conservation Commission Cov Graff 1120 Lincoln Street, Suite 801, Denver, Colorado 80203 (303) 894-2100 Fax: (303) 894-2109 ACCIDENT REPORT Report taken by: As required by Rule 602.b. DESCRIPTION OF ACCIDENT(Please be as specific as possible) Location Name of Operator. Date of Incident County: Type of Faciiity (well, tank battery, flow line, pit); Field Name: Well Name and Number. QtrQtr: Section:_ API Number - Township: Range: Connect to Accident (land owner, royalty owner, etc).: Meridian: Provide a detailed description of the accident, problem, and cause (equipment failure, human error, etc): OTHER NOTIFICATIONS List the parties and agencies notified (County, BLM, EPA, DOT, Local Emergency Planning Coordinator or other). Date Agency Contact Person Response Accident Tracking No: FORM 27 i� start c', O State of Colorado FOR OGCC USE ONLY Rev 6/99 +tea• Oil and Gas Conservation Commission VAt 1120 Lincoln Street, Suite 801 , Denver, Colorado 80203 (303)894-2100 Fax :(303)894-2109 SITE INVESTIGATION AND REMEDIATION WORKPLAN This form shall be submitted to the Director for approval prior to the initiation of site investigation and remediation , OGCC Employee: activities. Form 27 is intended to be used whenever possible. Additional documentation will be required when large Spill Complaint volumes of soil and groundwater have been impacted or involve large facilities with multiple source areas. See Rule Inspection NOAV 910. Attach as many pages as needed to fully describe the proposed work. Tracking No: CAUSE OF CONDITION BEING INVESTIGATED AND REMEDIATED Spill or Release n Plug & Abandon Central Facility Closure Site/Facility Closure Other (describe): OGCC Operator Number: - — - _ Contact Name and Telephone: Name of Operator: - - - Address: - No: City: State:_ Zip: - Fax: API Number: - _ County: Facility Name: Facility Number: Well Name: Well Number: — Location: (QtrQtr, Sec, Twp, Rng, Meridian): - - - Latitude: _ Longitude: TECHNICAL CONDITIONS Type of Waste Causing Impact (crude oil, condensate, produced water, etc): -Site Conditions: Is location within a sensitive area (according to Rule 901e)? Y N If yes, attach evaluation. Adjacent land use (cultivated, irrigated, dry land farming, industrial, residential, etc.): - Soil type, if not previously identified on Form 2A or Federal Surface Use Plan: _ - Potential receptors (water wells within 1/4 mi, surface waters, etc.): Description of Impact (if previously provided, refer to that form or document): Impacted Media (check): Extent of Impact: How Determined: Soils Vegetation Groundwater - Surface Water REMEDIATION WORKPLAN Describe initial action taken (if previously provided, refer to that form or document): Describe how source is to be removed: Describe how remediation of existing impacts is to be accomplished, including removal and disposal at an injection well or licensed facility, land treatment on site, removal of impacted groundwater, insitu bioremediation, burning of oily vegetation, etc.: Submit Page 2 with Page 1 E&P WASTE MANAGEMENT 901 . INTRODUCTION a. General. The rules and regulations of this series establish the permitting, construction, operating and closure requirements for pits, methods of E&P waste management, procedures for spill/release response and reporting, and sampling and analysis for remediation activities. The 900 Series rules are applicable only to E&P waste, as defined in § 34-60-103(4.5), C.R.S., or other solid waste where the Colorado Department Of Public Health And Environment has allowed remediation and oversight by the Commission. b. COGCC reporting forms. The reporting required by the rules and regulations of this series shall be made on forms provided by the Director. Alternate forms may be used where equivalent information is supplied and the format has been approved by the Director. c. Additional requirements. Whenever the Director has reasonable cause to believe that an operator, in the conduct of any oil or gas operation, is performing any act or practice which threatens to cause or causes a violation of Table 910-1 and with consideration of water quality standards or classifications established by the Water Quality Control Commission ("WQCC" ) for waters of the state, the Director may impose additional requirements, including but not limited to, sensitive area determination, sampling and analysis, remediation, monitoring, permitting and the establishment of points of compliance. Any action taken pursuant to this Rule shall comply with the provisions of Rules 324A. through D. and the 500 Series rules. d. Alternative compliance methods. Operators may propose for prior approval by the Director alternative methods for determining the extent of contamination, sampling and analysis, or alternative cleanup goals using points of compliance. e. Sensitive area determination. When the operator or Director has data that indicate an impact or threat of impact to ground water or surface water, the Director may require the operator to make a sensitive area determination and that determination shall be subject to the Director's approval_ The sensitive area determination shall be made using appropriate geologic and hydrogeologic data to evaluate the potential for impact to ground water and surface water, such as appropriate percolation tests that demonstrate that seepage will not reach underlying ground water or waters of the State and impact current or future uses of these waters. Operators shall submit data evaluated and analysis used in the determination to the Director. f. Sensitive area operations. Operations in sensitive areas shall incorporate adequate measures and controls to prevent significant adverse environmental impacts and ensure compliance with the concentration levels in Table 910-1 , with consideration to WQCC standards and classifications. 902. PITS - GENERAL AND SPECIAL RULES a. Pits used for exploration and production of oil and gas shall be constructed and operated to protect public health, safety, and welfare and the environment, including soil, waters of the state, and wildlife, from significant adverse environmental, public health , or welfare impacts from E&P waste, except as permitted by applicable laws and regulations. b. Pits shall be constructed, monitored, and operated to provide for a minimum of two (2) feet of freeboard at all times between the top of the pit wall at its point of lowest elevation and 900.1 As of February 1 , 2014 the fluid level of the pit. A method of monitoring and maintaining freeboard shall be employed. Any unauthorized release of fluids from a pit shall be subject to the reporting requirements of Rule 906. c. Any accumulation of oil or condensate in a pit shall be removed within twenty-four (24) hours of discovery. Operators shall use skimming, steam cleaning of exposed liners, or other safe and legal methods as necessary to maintain pits in clean condition and to control hydrocarbon odors. Only de minim is amounts of hydrocarbons may be present unless the pit is specifically permitted for oil or condensate recovery or disposal use. A Form 15 pit permit may be revoked by the Director and the Director may require that the pit be closed if an operator repeatedly allows more than de minimis amounts of oil or condensate to accumulate in a pit. This requirement is not applicable to properly permitted and properly fenced, lined, and netted skim pits that are designed, constructed, and operated to prevent impacts to wildlife, including migratory birds. d. Where necessary to protect public health, safety and welfare or to prevent significant adverse environmental impacts resulting from access to a pit by wildlife, migratory birds, domestic animals, or members of the general public, operators shall install appropriate netting or fencing. e. Pits used for a period of no more than three (3) years, or more than three (3) years if the Director has issued a variance, for storage, recycling, reuse, treatment, or disposal of E&P waste or fresh water, as applicable, may be permitted in accordance with Rule 903 to service multiple wells, subject to Director approval. f. Unlined pits shall not be constructed on fill material. g. Except as allowed under Rule 904.a, unlined pits shall not be constructed in areas where pathways for communication with ground water or surface water are likely to exist. h. Produced water shall be treated in accordance with Rule 907 before being placed in a production pit. i. Operators shall utilize appropriate biocide treatments to control bacterial growth and related odors as needed. 903. PIT PERMITTING/REPORTING REQUIREMENTS a. An Earthen Pit Report/Permit, Form 15, shall be submitted to the Director for prior approval for the following pits: (1 ) All production pits. (2) Special purpose pits except those reported under Rule 903.b.(1 ) or Rule 903.b.(2). (3) Drilling pits designed for use with fluids containing hydrocarbon concentrations exceeding 10,000 ppm TPH or chloride concentrations at total well depth exceeding 15,000 ppm . (4) Multi-well pits containing produced water, drilling fluids, or completion fluids that will be recycled or reused, except where reuse consists only of moving drilling fluids from one (1 ) oil and gas location to another such location for reuse there. b. An Earthen Pit Report/Permit, Form 15, shall be submitted within thirty (30) calendar days after construction for the following: 900-2 As of February 1 , 2014 (1 ) Special purpose pits used in the initial phase of emergency response. (2) Flare pits where there is no risk of condensate accumulation. c. An Earthen Pit Report/Permit, Form 15, shall not be required for drilling pits using water-based bentonitic drilling fluids with concentrations of TPH and chloride below those referenced in Rule 903.a.(3). d. An Earthen Pit Report/Permit, Form 15, shall be completed in accordance with the instructions in Appendix I. Failure to complete the form in full may result in delay of approval or return of form. a The Director shall endeavor to review any properly completed Earthen Pit Report/Permit, Form 15, within thirty (30) calendar days after receipt. In order to allow adequate time for pit permit review and approval, operators shall submit an Earthen Pit Report/Permit, Form 15, at the same time as the Application for Permit to Drill, Form 2, is submitted. The Director may condition permit approval upon compliance with additional terms, provisions, or requirements necessary to protect the waters of the state, public health, or the environment. 904. PIT LINING REQUIREMENTS AND SPECIFICATIONS a. Pits that were constructed before May 1 , 2009 on federal land, or before April 1 , 2009 on other land, shall comply with the rules in effect at the time of their construction. The following pits shall be lined if they are constructed on or after May 1 , 2009 on federal land, or on or after April 1 , 2009 on other land: (1 ) Drilling pits designed for use with fluids containing hydrocarbon concentrations exceeding 10,000 ppm TPH or chloride concentrations at total well depth exceeding 15,000 ppm . (2) Production pits, other than skim pits, unless the operator demonstrates to the Director's satisfaction that the quality of the produced water is equivalent to or better than that of the underlying groundwater or the operator can clearly demonstrate by substantial evidence, such as by appropriate percolation tests, that seepage will not reach the underlying aquifer or waters of the state at contamination levels in excess of applicable standards. Subject to Rule 901 .c, this requirement shall not apply to such pits in Huerfano or Las Animas Counties constructed before May 1 , 2011 , or to such pits in Washington, Yuma, Logan, or Morgan counties constructed before May 1 , 2013. (3) Special purpose pits, except emergency pits constructed during initial emergency response to spills/releases, or flare pits where there is no risk of condensate accumulation. (4) Skim pits. (5) Multi-well pits used to contain produced water, drilling fluids, or completion fluids that will be recycled or reused, except where reuse consists only of moving drilling fluids from one oil and gas location to another such location for reuse there. Subject to Rule 901 .c, this requirement shall not apply to multi-well pits used to contain produced water in Huerfano or Las Animas Counties constructed before May 1 , 2011 , or to multi-well 900-3 As of February 1 , 2014 pits used to contain produced water in Washington, Yuma, Logan, or Morgan counties constructed before May 1 , 2013. (6) Pits at centralized E&P waste management facilities and UIC facilities. b. The following specifications shall apply to all pits that are required to be lined: (1 ) Materials used in lining pits shall be of a synthetic material that is impervious, has high puncture and tear strength, has adequate elongation, and is resistant to deterioration by ultraviolet light, weathering, hydrocarbons, aqueous acids, alkali, fungi or other substances in the produced water. (2) All pit lining systems shall be designed, constructed, installed, and maintained in accordance with the manufacturers' specifications and good engineering practices. (3) Field seams must be installed and tested in accordance with manufacturer specifications and good engineering practices. Testing results must be maintained by the operator and provided to the Director upon request. c. The following specifications shall also apply to pits that are required to be lined, except those at centralized E&P waste management facilities, unless an oil and gas operator demonstrates to the satisfaction of the Director that a liner system offering equivalent protection to public health, safety, and welfare, including the environment and wildlife resources, will be used: (1 ) Liners shall have a minimum thickness of twenty-four (24) mils. The synthetic or fabricated liner shall cover the bottom and interior sides of the pit with the edges secured with at least a twelve (12) inch deep anchor trench around the pit perimeter. The anchor trench shall be designed to secure, and prevent slippage or destruction of, the liner materials. (2) The foundation for the liner shall be constructed with soil having a minimum thickness of twelve ( 12) inches after compaction covering the entire bottom and interior sides of the pit, and shall be constructed so that the hydraulic conductivity shall not exceed 1 .0 x 10-7 cm/sec after testing and compaction. Compaction and permeability test results measured in the laboratory and field must be maintained by the operator and provided to the Director upon request. (3) As an alternative to the soil foundation described in Rule 904.c.(2), the foundation may be constructed with bedding material that exceeds a hydraulic conductivity of 1 .0 x 10-7 cm/sec, if a double synthetic liner system is used; however, the bottom and sides of the pit shall be padded with soil or synthetic matting type material and shall be free of sharp rocks or other material that are capable of puncturing the liner. Each synthetic liner shall have a minimum thickness of twenty-four (24) mils. d. The following specifications shall also apply to pits used at centralized E&P waste management facilities, unless an oil and gas operator demonstrates to the satisfaction of the Director that a liner system offering equivalent protection to public health, safety, and welfare, including the environment and wildlife resources, will be used: (1 ) Liners shall have a minimum thickness of sixty (60) mils. The synthetic or fabricated liner shall cover the bottom and interior sides of the pit with the edges secured with at least a twelve (12) inch deep anchor trench around the pit perimeter. The 900-4 As of February 1 , 2014 anchor trench shall be designed to secure, and prevent slippage or destruction of, the liner materials. (2) The foundation for the liner shall be constructed with soil having a minimum thickness of twenty-four (24) inches after compaction covering the entire bottom and interior sides of the pit, and shall be constructed so that the hydraulic conductivity shall not exceed 1 .0 x 10"7 cm/sec after testing and compaction. Compaction and permeability test results measured in the laboratory and field must be maintained by the operator and provided to the Director upon request. (3) As an alternative to the soil foundation described in Rule 904.d.(2), a secondary liner consisting of a geosynthetic clay liner, which is a manufactured hydraulic barrier typically consisting of bentonite clay or other very low permeability material, supported by geotextiles or geomembranes, which are held together by needling, stitching, or chemical adhesives, may be used . e. In Sensitive Areas, the Director may require a leak detection system for the pit or other equivalent protective measures, including but not limited to, increased record-keeping requirements, monitoring systems, and underlying gravel fill sumps and lateral systems. In making such determination, the Director shall consider the surface and subsurface geology, the use and quality of potentially-affected ground water, the quality of the produced water, the hydraulic conductivity of the surrounding soils, the depth to ground water, the distance to surface water and water wells, and the type of liner. 905. CLOSURE OF PITS, AND BURIED OR PARTIALLY BURIED PRODUCED WATER VESSELS. a. Drilling pits shall be closed in accordance with the 1000-Series Rules. b. Pits not used exclusively for drilling operations, buried or partially buried produced water vessels, and emergency pits shall be closed in accordance with an approved Site Investigation and Remediation Workplan, Form 27. The workplan shall be submitted for prior Director approval and shall include a description of the proposed investigation and remediation activities in accordance with Rule 909. Emergency pits shall be closed and remediated as soon as the initial phase of emergency response operations are complete or process upset conditions are controlled. ( 1 ) Operators shall ensure that soils and ground water meet the concentration levels of Table 910-1 . (2) Pit evacuation. Prior to backfilling and site reclamation, E&P waste shall be treated or disposed in accordance with Rule 907. (3) Liners shall be disposed as follows: A. Synthetic liner disposal. Liner material shall be removed and disposed in accordance with applicable legal requirements for solid waste disposal. B. Constructed soil liners. Constructed soil liner material may be removed for treatment or disposal, or, where left in place, the material shall be ripped and mixed with native soils in a manner to alleviate compaction and prevent an impermeable barrier to infiltration and ground water flow and shall meet soil standards listed in Table 910-1 . 900-5 As of February 1 , 2014 (4) Soil beneath the low point of the pit must be sampled to verify no leakage of the managed fluids. Soil left in place shall meet the standards listed in Table 910-1 . c. Discovery of a spill/release during closure. When a spill/release is discovered during closure operations, operators shall report the spill/release on the Spill/Release Report, Form 19, in accordance with Rule 906. Leaking pits and buried or partially buried produced water vessels shall be closed and remediated in accordance with Rules 909. and 910. d. Unlined drilling pits. Unlined drilling pits shall be closed and reclaimed in accordance with the 1000 Series rules and operators shall ensure that soils and ground water meet the concentration levels in Table 910-1 . 906. SPILLS AND RELEASES a. General. Operators shall, immediately upon discovery, control and contain all spills/releases of E&P waste or produced fluids to protect the environment, public health, safety, and welfare, and wildlife resources. Operators shall investigate, clean up, and document impacts resulting from spills/releases as soon as practicable. The Director may require additional activities to prevent or mitigate threatened or actual significant adverse environmental impacts on any air, water, soil or biological resource, or to the extent necessary to ensure compliance with the concentration levels in Table 910-1 , with consideration to WQCC ground water standards and classifications. b. Reporting spills or releases of E&P Waste or produced fluids. (1 ) Report to the Director. Operators shall report a spill or release of E&P Waste or produced fluids that meet any of the following criteria to the Director verbally or in writing as soon as practicable, but no more than twenty-four (24) hours after discovery (the "Initial Report"). A. A spills/release of any size that impacts or threatens to impact any waters of the state, a residence or occupied structure, livestock, or public byway; B. A spill/release in which one ( 1 ) barrel or more of E&P Waste or produced fluids is spilled or released outside of berms or other secondary containment; C. A spill/release of five (5) barrels or more regardless of whether the spill/release is completely contained within berms or other secondary containment. The Initial Report to the Director shall include, at a minimum, the location of the spill/release and any information available to the Operator about the type and volume of waste involved. If the Initial Report was not made by submitting a COGCC Spill/Release Report, Form 19 the Operator must submit a Form 19 with the Initial Report information as soon as practicable but not later than 72 hours after discovery of the spill/release unless extended by the Director. In addition to the Initial Report to the Director, the Operator shall make a supplemental report on Form 19 not more than 10 calendar days after the spill/release is discovered that includes an 8 1 /2 x 11 inch topographic map showing the governmental section and location of the spill or an aerial photograph showing the location of the spill; all pertinent 900-6 As of February 1 , 2014 information about the spill/release known to the Operator that has not been reported previously; and information relating to the initial mitigation, site investigation, and remediation measures conducted by the Operator. The Director may require further supplemental reports or additional information. (2) Notification to the local government. In addition to the Initial Report to the Director, as soon as practicable, but not more than 24 hours after discovery of a spill/release of E & P Waste or produced fluids reportable under Rule 906.b.( 1 )A or B, above, an Operator shall provide verbal or written notification to the entity with jurisdiction over emergency response within the local municipality if the spill/release occurred within a municipality or the local county if the spill/release did not occur within a municipality. The notification shall include, at a minimum, the information provided in the Initial Report to the Director. (3) Notification to the Surface Owner. In addition to the Initial Report to the Director, within 24 hours after discovery of a spill/release of E & P Waste or produced fluids reportable under Rule 906.b.(1 )A or B, an Operator shall provide verbal notification to the affected Surface Owner or the Surface Owner's appointed tenant. If the Surface Owner cannot be reached within 24 hours, the Operator shall continue good faith efforts to notify the Surface Owner until notice has been provided. The verbal notification shall include, at a minimum , the information provided in the Initial Report to the Director. (4) Report to Environmental Release/Incident Report Hotline. A_spill/release of any size which impact or threaten to impact any surface water supply area shall be reported to the Director and to the Environmental Release/Incident Report Hotline (1 -877-518-5608). Spills and releases that impact or threaten a surface water intake shall be verbally reported to the emergency contact for that facility immediately after discovery. (5) Reporting chemical spills or releases. Chemical spills and releases shall be reported in accordance with applicable state and federal laws, including the Emergency Planning and Community Right-to-Know Act, the Comprehensive Environmental Response, Compensation, and Liability Act, the Oil Pollution Act, and the Clean Water Act, as applicable. c. Remediation of spills/releases. When threatened or actual significant adverse environmental impacts on any air, water, soil or other environmental resource from a spill/release exist or when necessary to ensure compliance with the concentration levels in Table 910-1 with consideration to WQCC ground water standards and classifications, the Director may require operators to submit a Site Investigation and Remediation Workplan, Form 27. (1 ) Such spills/releases shall be remediated in accordance with Rules 909 and 910. (2) The operator shall make good faith efforts to notify and consult with the affected Surface Owner, or the Surface Owner's appointed tenant, prior to commencing operations to remediate E&P waste from a spill/release in an area not being utilized for oil and gas operations. Such efforts shall not unreasonably delay commencement of remediation approved by the Director. 900-7 As of February 1 , 2014 d. Spill/release prevention. ( 1 ) Secondary containment. Secondary containment structures shall be sufficiently impervious to contain discharged material. Secondary containment that was constructed before May 1 , 2009 on federal land, or before April 1 , 2009 on other land, shall comply with the rules in effect at the time of construction. Secondary containment constructed on or after May 1 , 2009 on federal land, or on or after April 1 , 2009 on other land shall be constructed or installed around all tanks containing oil, condensate, or produced water with greater than 3,500 milligrams per liter (mg/l) total dissolved solids (TDS) and shall be sufficient to contain the contents of the largest single tank and sufficient freeboard to contain precipitation. Operators are also subject to tank and containment requirements under Rules 603. and 604. This requirement shall not apply to water tanks with a capacity of fifty (50) barrels or less. (2) Spill/release evaluation. Operators shall determine and document the cause of a spill/release of E & P Waste or produced fluids and, to the extent practicable, identify and timely implement measures to prevent spills/releases due to similar causes in the future. 907. MANAGEMENT OF E&P WASTE a. General requirements. (1 ) Operator obligations. Operators shall ensure that E&P waste is properly stored, handled, transported, treated, recycled, or disposed to prevent threatened or actual significant adverse environmental impacts to air, water, soil or biological resources or to the extent necessary to ensure compliance with the concentration levels in Table 910-1 , with consideration to WQCC ground water standards and classifications. (2) E&P waste management activities shall be conducted, and facilities constructed and operated, to protect the waters of the state from significant adverse environmental impacts from E&P waste, except as permitted by applicable laws and regulations. (3) Reuse and recycling. To encourage and promote waste minimization, operators may propose plans for managing E&P waste through beneficial use, reuse, and recycling by submitting a written management plan to the Director for approval on a Sundry Notice, Form 4, if applicable. Such plans shall describe, at a minimum , the type(s) of waste, the proposed use of the waste, method of waste treatment, product quality assurance, and shall include a copy of any certification or authorization that may be required by other laws and regulations. The Director may require additional information. b. Waste transportation. (1 ) E&P waste, when transported off-site within Colorado for treatment or disposal, shall be transported to facilities authorized by the Director or waste disposal facilities approved to receive E&P waste by the Colorado Department of Public Health and Environment. When transported to facilities outside of Colorado for treatment or disposal, E&P waste shall be transported to facilities authorized and permitted by the appropriate regulatory agency in the receiving state. 900.8 As of February 1 , 2014 (2) Waste generator requirements. Generators of E&P waste that is transported off- site shall maintain, for not less than five (5) years, copies of each invoice, bill, or ticket and such other records as necessary to document the following requirements A through F: A. The date of the transport; B. The identity of the waste generator; C. The identity of the waste transporter; D. The location of the waste pickup site; E. The type and volume of waste; and F. The name and location of the treatment or disposal site. Such records shall be signed by the transporter, made available for inspection by the Director during normal business hours, and copies thereof shall be furnished to the Director upon request. c. Produced water. ( 1 ) Treatment of produced water. Produced water shall be treated prior to placement in a production pit to prevent crude oil and condensate from entering the pit. (2) Produced water disposal. Produced water may be disposed as follows: A. Injection into a Class II well, permitted in accordance with Rule 325.; B. Evaporation/percolation in a properly permitted pit; C. Disposal at permitted commercial facilities; D. Disposal by roadspreading on lease roads outside sensitive areas for produced waters with less than 3,500 mg/I TDS when authorized by the surface owner. Roadspreading of produced waters shall not impact waters of the state, shall not result in pooling or runoff, and the adjacent soils shall meet the concentration levels in Table 910-1 . Flowback fluids shall not be used for dust suppression. E. Discharging into state waters, in accordance with the Water Quality Control Act and the rules and regulations promulgated thereunder. i. Operators shall provide the Colorado discharge permit number, latitude and longitude coordinates, in accordance with Rule 215.f, of the discharge outfall, and sources of produced water on a Source of Produced Water for Disposal, Form 26, and shall include a U .S.G.S. topographic map showing the location of the discharge outfall. ii. Produced water discharged pursuant to this subsection (2).E. may be put to beneficial use in accordance with applicable state statutes and regulations governing the use and administration of water. 900.9 As of February 1 , 2014 F. Evaporation in a properly lined pit at a centralized E&P waste management facility permitted in accordance with Rule 908. (3) Produced water reuse and recycling. Produced water may be reused for enhanced recovery, drilling, and other approved uses in a manner consistent with existing water rights and in consideration of water quality standards and classifications established by the WQCC for waters of the state, or any point of compliance established by the Director pursuant to Rule 324D. (4) Mitigation. Water produced during operation of an oil or gas well may be used to provide an alternative domestic water supply to surface owners within the oil or gas field, in accordance with all applicable laws, including, but not limited to, obtaining the necessary approvals from the WQCD for constructing a new "waterworks," as defined by Section 25-1 -107( 1 )(X)(Il)(A), C.R.S. Any produced water not so used shall be disposed of in accordance with subsection (2) or (3). Providing produced water for domestic use within the meaning of this subsection (4) shall not constitute an admission by the operator that the well is dewatering or impacting any existing water well. The water produced shall be to the benefit of the surface owner within the oil and gas field and may not be sold for profit or traded. d. Drilling fluids. ( 1 ) Recycling and reuse. Drilling pit contents may be recycled to another drilling pit for reuse consistent with Rule 903. (2) Treatment and disposal. Drilling fluids may be treated or disposed as follows: A. Injection into a Class II well permitted in accordance with Rule 325; B. Disposal at a commercial solid waste disposal facility; or C. Land treatment or land application at a centralized E&P waste management facility permitted in accordance with Rule 908. (3) Additional authorized disposal of water-based bentonitic drilling fluids. Water- based bentonitic drilling fluids may be disposed as follows: A. Drying and burial in pits on non-crop land. The resulting concentrations shall not exceed the concentration levels in Table 910-1 , below; or B. Land application as follows: i. Applicability. Acceptable methods of land application include, but are not limited to, production facility construction and maintenance, and lease road maintenance. ii . Land application requirements. The average thickness of water- based bentonitic drilling fluid waste applied shall be no more than three (3) inches prior to incorporation. The waste shall be applied to prevent ponding or erosion and shall be incorporated as a beneficial amendment into the native soils within ten ( 10) days of application. The resulting concentrations shall not exceed those in Table 910-1 . 900-10 As of February 1 , 2014 iii. Surface owner approval. Operators shall obtain written authorization from the surface owner prior to land application of water-based bentonitic drilling fluids. iv. Operator obligations. Operators shall maintain a record of the source, the volume, and the location where the land application of the water-based bentonitic drilling fluid occurred. Upon the Director's written request, this information shall be provided within five (5) business days, in a format readily reviewable by the Director. Operators with control and authority over the wells from which the water-based bentonitic drilling fluid wastes are obtained retain responsibility for the land application operation, and shall diligently cooperate with the Director in responding to complaints regarding land application of water-based bentonitic drilling fluids. v. Approval. Prior Director approval is not required for reuse of water- based bentonitic drilling fluids for land application as a soil amendment. e. Oily waste. Oily waste includes those materials containing crude oil, condensate or other E&P waste, such as soil, frac sand, drilling fluids, and pit sludge that contain hydrocarbons. (1 ) Oily waste may be treated or disposed as follows: A. Disposal at a commercial solid waste disposal facility; B. Land treatment onsite; or C. Land treatment at a centralized E&P waste management facility permitted in accordance with Rule 908. (2) Land treatment requirements: A. Free oil shall be removed from the oily waste prior to land treatment. B. Oily waste shall be spread evenly to prevent pooling, ponding, or runoff. C. Contamination of stormwater runoff, ground water, or surface water shall be prevented. D. Biodegradation shall be enhanced by disking, tilling, aerating, or addition of nutrients, microbes, water or other amendments, as appropriate. E. Land-treated oily waste incorporated in place or beneficially reused shall not exceed the concentrations in Table 910-1 . F. When a threatened or significant adverse environmental impact from onsite land treatment exists, operators shall submit a Site Investigation and Remediation Workplan, Form 27, for approval by the Director. Treatment shall thereafter be completed in accordance with the workplan and Rules 909. and 910. G. When land treatment occurs in an area not being utilized for oil and gas operations, operators shall obtain prior written surface owner approval. 900-11 As of February 1 , 2014 f. Other E&P Waste. Other E&P waste such as workover fluids, tank bottoms, pigging wastes from gathering and flow lines, and natural gas gathering, processing, and storage wastes may be treated or disposed of as follows: (1 ) Disposal at a commercial solid waste disposal facility; (2) Treatment at a centralized E&P waste management facility permitted in accordance with Rule 908; (3) Injection into a Class II injection well permitted in accordance with Rule 325; or (4) An alternative method proposed in a waste management plan in accordance with rule 907.a.(3) and approved by the Director. 907A. MANAGEMENT OF NON-EM' WASTE a. Certain wastes generated by oil and gas-related activities are non-E&P wastes and are not exempt from regulation as solid or hazardous wastes. These wastes need to be properly identified and disposed of in accordance with state and federal regulations. b. Certain wastes generated by oil and gas-related activities can either be E&P wastes or non- E&P wastes depending on the circumstances of their generation. c. The hazardous waste regulations require that a hazardous waste determination be made for any non-E&P solid waste. Hazardous wastes require storage, treatment, and disposal practices in accordance with 6 C.C.R. 1007-3. All non-hazardous/non-E&P wastes are considered solid waste which require storage, treatment, and disposal in accordance with 6 C.C.R. 1007-2. 908. CENTRALIZED E&P WASTE MANAGEMENT FACILITIES a. Applicability. Operators may establish non-commercial, centralized E&P waste management facilities for the treatment, disposal, recycling or beneficial reuse of E&P waste. This rule applies only to non-commercial facilities. which means the operator does not represent itself as providing E&P waste management services to third parties, except as part of a unitized area or joint operating agreement or in response to an emergency. Centralized facilities may include components such as land treatment or land application sites, pits, and recycling equipment. b. Permit requirements. Before any person shall commence construction of a centralized E&P waste management facility, such person shall file with the Director an application on Form 28 and pay a filing and service fee established by the Commission (see Appendix III), and obtain the Director's approval. The application shall contain the following: (1 ) The name, address, phone and fax number of the operator, and a designated contact person. (2) The name, address, and phone number of the surface owner of the site, if not the operator, and the written authorization of such surface owner. (3) The legal description of the site. (4) A general topographic, geologic, and hydrologic description of the site, including immediately adjacent land uses, a topographic map of a scale no less than 900-12 As of February 1 , 2014 1 :24,000 showing the location, and the average annual precipitation and evaporation rates at the site. (5) Centralized facility siting requirements. A. A site plan showing drainage patterns and any diversion or containment structures, and facilities such as roads, fencing, tanks, pits, buildings, and other construction details. B. Scaled drawings of entire sections containing the proposed facility. The field measured distances from the nearer north or south and nearer east or west section lines shall be measured at ninety (90) degrees from said section lines to facility boundaries and referenced on the drawing. A survey shall be provided including a complete description of established monuments or collateral evidence found and all aliquot corners. C. The facility shall be designed to control public access, prevent unauthorized vehicular traffic, provide for site security both during and after operating hours, and prevent illegal dumping of wastes. Appropriate measures shall also be implemented to prevent access to the centralized facility by wildlife or domestic animals. D. Centralized facilities shall have a fire lane of at least ten (10) feet in width around the active treatment areas and within the perimeter fence. In addition, a buffer zone of at least ten (10) feet shall be maintained within the perimeter fire lane. E. Surface water diversion structures, including, but not limited to, berms and ditches, shall be constructed to accommodate a one hundred (100) year, twenty four (24) hour event. The facility shall be designed and constructed with a run-on control system to prevent flow onto the facility during peak discharge and a run-off control system to contain the water volume from a twenty-five (25) year, twenty-four (24) hour storm . (6) Waste profile. For each type of waste, the amounts to be received and managed by the facility shall be estimated on a monthly average basis. For each waste type to be treated, a characteristic waste profile shall be completed. (7) Facility design and engineering. Facility design and engineering data, including plans and elevations, design basis, calculations, and process description. A. Geologic data, including, but not limited to: i. Type and thickness of unconsolidated soils; ii. Type and thickness of consolidated bedrock, if applicable; iii. Local and regional geologic structures; and iv. Any geologic hazards that may affect the design and operation of the facility. B. Hydrologic data, including, but not limited to: i. Surface water features within two (2) miles; As of February 1 , 2014 900-13 ii. Depth to shallow ground water and major aquifers; iii. Water wells within one (1 ) mile of the site boundary and well depth, depth to water, screened intervals, yields, and aquifer name; iv. Hydrologic properties of shallow ground water and major aquifers including flow direction, flow rate, and potentiometric surface; v. Site location in relation to the floodplain of nearby surface water features; vi. Existing quality of shallow ground water; and vii. An evaluation of the potential for impacts to nearby surface water and ground water. C. Engineering data, including, but not limited to: i. Type and quantity of material required for use as a liner, including design components; ii. Location and depth of cut for liners; iii. Location, dimensions, and grades of all surface water diversion structures; iv. Location and dimensions of all surface water containment structures; and v. Location of all proposed facility structures and access roads. (8) Operating plan. An operating plan, including, but not limited to: A. A detailed description of the method of treatment, loading rates, and application of nutrients and soil amendments; B. Dust and moisture control; C. Sampling; D. Inspection and maintenance; E. Emergency response; F. Record-keeping; G. Site security; H. Hours of operation; I. Noise and odor mitigation; and J . Final disposition of waste. Where treated waste will be beneficially reused, a description of reuse and method of product quality assurance shall be included. 900-14 As of February 1 , 2014 (9) Ground water monitoring. A. Water Wells. Water samples shall be collected from water wells known to the operator or registered with the Colorado State Engineer within a one ( 1 ) mile radius of the proposed facility and shall be analyzed to establish baseline water quality. Analytical parameters shall be selected based upon the proposed waste stream and shall include, at a minimum , all major cations and anions, total dissolved solids, iron and manganese, nutrients (nitrates, nitrites, selenium ), benzene, toluene, ethylbenzene, xylenes, pH, and specific conductance. Operators shall use reasonable good faith efforts to identify and obtain access to such water wells for the purpose of collecting water samples. If access cannot be obtained , then the operator shall notify the Director of the wells for which access was not obtained and sampling of such wells by the operator shall not be required. Not conducting sampling because access to water wells cannot be obtained shall not be grounds for denial of the proposed facility. Copies of all test results described above shall be provided to the Director and the water well owner within three (3) months of collecting the samples. Laboratory results shall also be submitted to the Director in an electronic data deliverable format. B. Site-specific monitoring wells. i. Where applicable, the Director shall require ground water monitoring to ensure compliance with the concentration levels in Table 910- 1 and WQCC standards and classifications by establishing points of compliance, unless an oil and gas operator demonstrates to the satisfaction of the Director that an alternative method offering equivalent protection of public health, safety, and welfare, including the environment and wildlife resources, can be employed and provided the operator employs a dual liner with a leak detection system that provides for immediate leak detection from the uppermost liner. All monitoring well construction must be completed in accordance with the State Engineer's regulations on well construction, "Water Well Construction Rules" (2 C.C.R. 402-2). ii. Where monitoring is required, the direction of flow, ground water gradient and quality of water shall be established by the installation of a minimum of three (3) monitor wells, including an up-gradient well and two (2) down-gradient wells that will serve as points of compliance, or other methods authorized by the Director. (10) Surface water monitoring. Where applicable, the Director shall require baseline and periodic surface water monitoring to ensure compliance with WQCC surface water standards and classifications. Operators shall use reasonable good faith efforts to obtain access to such surface water for the purpose of collecting water samples. If access cannot be obtained, then the operator shall notify the Director of the surface water for which access was not obtained and sampling of such surface water by the operator shall not be required. Not conducting sampling because access to surface water cannot be obtained shall not be grounds for denial of the proposed facility. As of February 1 , 2014 900-15 (11 ) Contingency plan. A contingency plan that describes the emergency response operations for the facility, 24-hour contact information for the person who has authority to initiate emergency response actions, and an outline of responsibilities under the joint operating agreement regarding maintenance, closure, and monitoring of the facility. c. Permit approval. The Director shall endeavor to approve or deny the properly completed permit within thirty (30) days after receipt and may condition permit approval as necessary to prevent any threatened or actual significant adverse environmental impact on air, water, soil or biological resources or to the extent necessary to ensure compliance with the concentration levels in Table 910-1 , with consideration to WQCC ground water standards and classifications. d. Financial assurance. The operator of a centralized E&P waste management facility shall submit for the Director's approval such financial assurance as required by Rule 704. prior to issuance of the operating permit. e. Facility modifications. Throughout the life of the facility the operator shall submit proposed modifications to the facility design, operating plan, permit data, or permit conditions to the Director for prior approval. f. Annual permit review. To ensure compliance with permit conditions and the 900 Series rules, the facility permit shall be subject to an annual review by the Director. To facilitate this review, the operator shall submit an annual report summarizing operations, including the types and volumes of waste actually handled at the facility. The Director may require additional information. g. Closure. (1 ) Preliminary closure plan. A general preliminary plan for closure shall be submitted with the centralized E&P waste management facility permit, Form 28. The preliminary closure plan shall include, but not be limited to: A. A general plan for closure and reclamation of the entire facility, including a description of the activities required to decommission and remove all equipment, close and reclaim pits, dispose of or treat residual waste, collect samples as needed to verify compliance with soil and ground water standards, implement post-closure monitoring, and complete other remediation, as required. B. An estimate of the cost to close and reclaim the entire facility and to conduct post-closure monitoring. Cost estimates shall be subject to review by the Director. (2) Final closure plan. A detailed Site Investigation and Remediation Workplan, Form 27, shall be submitted at least sixty (60) days prior to closure for approval by the Director. The workplan shall include, but not be limited to, a description of the activities required to decommission and remove all equipment, close and reclaim pits, dispose of or treat residual waste, collect samples as needed to verify compliance with soil and ground water standards, implement post-closure monitoring, and complete other remediation, as required. h. Operators may be subject to local requirements for zoning and construction of facilities and shall provide copies of any approval notices, permits, or other similar types of Fps of February 1 , 2014 900-16 notifications for the facility from local governments or other agencies to the Director for review prior to issuance of the operating permit. 909. SITE INVESTIGATION, REMEDIATION, AND CLOSURE a. Applicability. This section applies to the closure and remediation of pits other than drilling pits constructed pursuant to Rule 903.a.(3); investigation, reporting and remediation of spills/releases; permitted waste management facilities including treatment facilities; plugged and abandoned weilsites; sites impacted by E&P waste management practices; or other sites as designated by the Director. b. General site investigation and remediation requirements. (1 ) Sensitive Area Determination. Operators shall complete a sensitive area determination in accordance with Rule 901 .e. (2) Sampling and analyses. Sampling and analysis of soil and ground water shall be conducted in accordance with Rule 910. to determine the horizontal and vertical extent of any contamination in excess of the concentrations in Table 910-1 . (3) Management of E&P waste. E&P waste shall be managed in accordance with Rule 907. (4) Pit evacuation. Prior to backfilling and site reclamation, E&P waste shall be treated or disposed in accordance with Rule 907. and the 1000 Series rules. (5) Remediation. Remediation shall be performed in a manner to mitigate, remove, or reduce contamination that exceeds the concentrations in Table 910-1 in order to ensure protection of public health, safety, and welfare, and to prevent and mitigate significant adverse environmental impacts. Soil that does not meet concentrations in Table 910-1 shall be remediated. Ground water that does not meet concentrations in Table 910- 1 shall be remediated in accordance with a Site Investigation and Remediation Workplan, Form 27. (6) Reclamation. Remediation sites shall be reclaimed in accordance with the 1000 Series rules for reclamation. c. Site Investigation And Remediation Workplan, Form 27. Operators shall prepare and submit for prior Director approval a Site Investigation and Remediation Workplan, Form 27, for the following operations and remediation activities: (1 ) Unlined pit closure when required by Rule 905. (2) Remediation of spills/releases in accordance with Rule 906. (3) Land treatment of oily waste in accordance with Rule 907.e.(2).F. (4) Closure of centralized E&P waste management facilities in accordance with Rule 908.g. (5) Remediation of impacted ground water in accordance with Rule 910.b.(4). d. Multiple sites. Remediation of multiple sites may be submitted on a single workplan with prior Director approval. 900-17 As of February 1 , 2014 e. Closure. (1 ) Remediation and reclamation shall be complete upon compliance with the concentrations in Table 910-1 , or upon compliance with an approved workplan. (2) Notification of completion. Within thirty (30) days after conclusion of site remediation and reclamation activities operators shall provide the following notification of completion: A. Operators conducting remediation operations in accordance with Rule 909.b. shall submit to the Director a Site Investigation and Remediation Workplan , Form 27, containing information sufficient to demonstrate compliance with these rules. B. Operators conducting remediation under an approved workplan shall submit to the Director, by adding or attaching to the original workplan, information sufficient to demonstrate compliance with the workplan. f. Release of financial assurance. Financial assurance required by Rule 706. may be held by the Director until the required remediation of soil and/or ground water impacts is completed in accordance with the approved workplan, or until cleanup goals are met. 910. CONCENTRATIONS AND SAMPLING FOR SOIL AND GROUND WATER a. Soil and groundwater concentrations. The concentrations for soil and ground water are in Table 910-1 . Ground water standards and analytical methods are derived from the ground water standards and classifications established by Waco. b. Sampling and analysis. (1 ) Existing workplans. Sampling and analysis for sites subject to an approved workplan shall be conducted in accordance with the workplan and the sampling and analysis requirements described in this rule. (2) Methods for sampling and analysis. Sampling and analysis for site investigation or confirmation of successful remediation shall be conducted to determine the nature and extent of impact and confirm compliance with appropriate concentration levels in Table 910-1 . A. Field analysis. Field measurements and field tests shall be conducted using appropriate equipment, calibrated and operated according to manufacturer specifications, by personnel trained and familiar with the equipment. B. Sample collection. Samples shall be collected, preserved, documented, and shipped using standard environmental sampling procedures in a manner to ensure accurate representation of site conditions. C. Laboratory analytical methods. Laboratories shall analyze samples using standard methods (such as EPA SW-846 or API RP-45) appropriate for detecting the target analyte. The method selected shall have detection limits less than or equal to the concentrations in Table 910-1 . 900-18 As of February 1 , 2014 D. Background sampling. Samples of comparable, nearby, non-impacted, native soil, ground water or other medium may be required by the Director for establishing background conditions. (3) Soil sampling and analysis. A. Applicability. If soil contamination is suspected or known to exist as a result of spills/releases or E&P waste management, representative samples of soil shall be collected and analyzed in accordance with this rule. B. Sample collection. Samples shall be collected from areas most likely to have been impacted, and the horizontal and vertical extent of contamination shall be determined. The number and location of samples shall be appropriate to the impact. C. Sample analysis. Soil samples shall be analyzed for contaminants listed in Table 910-1 as appropriate to assess the impact or confirm remediation. The analytical parameters shall be selected based on site-specific conditions and process knowledge and shall be agreed to and approved by the Director. D. Reporting. Soil Analysis Report, Form 24, shall be used when the Director requires results of soil analyses. E. Soil impacted by produced water. For impacts to soil due to produced water, samples from comparable, nearby non-impacted native soil shall be collected and analyzed for purposes of establishing background soil conditions including pH and electrical conductivity (EC). Where EC of the impacted soil exceeds the level in Table 910-1 , the sodium adsorption ratio (SAR) shall also be determined. F. Soil impacted by hydrocarbons. For impacts to soil due to hydrocarbons, samples shall be analyzed for TPH. (4) Ground water sampling and analysis. A. Applicability. Operators shall collect and analyze representative samples of ground water in accordance with these rules under the following circumstances: (i) Where ground water contamination is suspected or known to exceed the concentrations in Table 910-1 ; (ii) Where impacted soils are in contact with ground water; or (iii) Where impacts to soils extend down to the high water table. B. Sample collection. Samples shall be collected from areas most likely to have been impacted, downgradient or in the middle of excavated areas. The number and location of samples shall be appropriate to determine the horizontal and vertical extent of the impact. If the concentrations in Table 910-1 are exceeded, the direction of flow and a ground water gradient shall be established, unless the extent of the contamination and migration can otherwise be adequately determined. 900-19 As of February 1 , 2014 C. Sample analysis. Ground water samples shall be analyzed for benzene, toluene, ethylbenzene, xylene, and API RP-45 constituents, or other parameters appropriate for evaluating the impact. The analytical parameters shall be selected based on site-specific conditions and process knowledge and shall be agreed to and approved by the Director. D. Reporting. Water Analysis Report, Form 25, shall be used when the Director requires results of water analyses. E. Impacted ground water. Where ground water contaminants exceed the concentrations listed in Table 910-1 , operators shall notify the Director and submit to the Director for prior approval a Site Investigation and Remediation Workplan, Form 27, for the investigation, remediation, or monitoring of ground water to meet the required concentrations in Table 910-1 . 911 . PIT, BURIED OR PARTIALLY BURIED PRODUCED WATER VESSEL, BLOWDOWN PIT, AND BASIC SEDIMENT/TANK BOTTOM PIT MANAGEMENT REQUIREMENTS PRIOR TO DECEMBER 30, 1997. a. Applicability. This rule applies to the management, operation, closure and remediation of drilling, production and special purpose pits, buried or partially buried produced water vessels, blowdown pits, and basic sediment/tank bottom pits put into service prior to December 30, 1997 and unlined skim pits put into service prior to July 1 , 1995. For pits constructed after December 30, 1997 and skim pits constructed after July 1 , 1995, operators shall comply with the requirements contained in Rules 901 . through 910. b. Inventory. Operators were required to submit to the Director no later than December 31 , 1995, an inventory identifying production pits, buried or partially buried produced water vessels, blowdown pits, and basic sediment/tank bottom pits that existed on June 30, 1995. The inventory required operators to provide the facility name, a description of the location, type, capacity and use of pit/vessel, whether netted or fenced, lined or unlined, and where available, water quality data. Operators who have failed to submit the required inventory are in continuing violation of this rule. c. Sensitive area determination. ( 1 ) For unlined production and special purpose pits constructed prior to July 1 , 1995 and not closed by December 30, 1997, operators were required to determine whether the pit was located within a sensitive area in accordance with the Sensitive Area Determination Decision Tree, Figure 901 -1 (now Rule 901 .e.) and submit data evaluated and analysis used in the determination to the Director on a Sundry Notice, Form 4. In December 2008, Figure 901 -1 was deleted from the 900- Series Rules. (2) For steel, fiberglass, concrete, or other similar produced water vessels that were buried or partially buried and located in sensitive areas prior to December 30, 1997, operators were required to test such vessels for integrity, unless a monitoring or leak detection system was put in place. d. The following permitting/reporting requirements applied to pits constructed prior to December 30, 1997: (1 ) A Sundry Notice, Form 4, including the name, address, and phone number of the primary contact person operating the production pit for the operator, the facility 900.20 As of February 1 , 2014 name, a description of the location, type, capacity and use of pit, engineering design, installation features and water quality data, if available, was required for the following: A. Lined production pits and lined special purpose pits constructed after July 1 , 1995. B. Unlined production pits constructed prior to July 1 , 1995 which are lined in accordance with Rule 905. by December 30, 1997. (2) An Application For Permit For Unlined Pit, Form 15 was required for the following: A. Unlined production pits and special purpose pits in sensitive areas constructed prior to July 1 , 1995, and not closed by December 30, 1997. B. Unlined production pits outside sensitive areas constructed after July 1 , 1995 and not closed by December 30, 1997. (3) An Application For Permit For Unlined Pit, Form 15 and a variance under Rule 904.e.(1 ). (repealed, now Rule 502.b.) was required for unlined production pits and unlined special purpose pits in sensitive areas constructed after July 1 , 1995. (4) A Sundry Notice, Form 4 was required for unlined production pits outside sensitive areas receiving produced water at an average daily rate of five (5) or less barrels per day calculated on a monthly basis for each month of operation constructed prior to December 30, 1997. a The Director may have established points of compliance for unlined production pits and special purpose pits and for lined production pits in sensitive areas constructed after July 1 , 1995. f. Closure requirements. ( 1 ) Operators of production or special purpose pits existing on July 1 , 1995 which were closed before December 30, 1997, were required to submit a Sundry Notice, Form 4, within thirty (30) days of December 30, 1997. The Sundry Notice, Form 4 shall include a copy of the existing pit permit, if a permit was obtained, and a description of the closure process. (2) Pits closed prior to December 30, 1997 were required to be reclaimed in accordance with the 1000 Series rules. Pits closed after December 30, 1997 shall be closed in accordance with the 900 Series rules and reclaimed in accordance with the 1000 Series rules. (3) Operators of steel, fiberglass, concrete or other similar produced water vessels buried or partially buried and located in sensitive areas were required to repair or replace vessels and tanks found to be leaking. Operators shall repair or replace vessels and tanks found to be leaking. Operators shall submit to the Director a Sundry Notice, Form 4, describing the integrity testing results and action taken within thirty (30) days of December 30, 1997. (4) Closure of pits and steel, fiberglass, concrete or other similar produced water vessels, and associated rem ediation operations conducted prior to December 30, 1997 are not subject to Rules 905. , 906., 907., 909. and 910. 900-21 As of February 1 , 2014 912. VENTING OR FLARING NATURAL GAS a. The unnecessary or excessive venting or flaring of natural gas produced from a well is prohibited. b. Except for gas flared or vented during an upset condition, well maintenance, well stimulation flowback, purging operations, or a productivity test, gas from a well shall be flared or vented only after notice has been given and approval obtained from the Director on a Sundry Notice, Form 4, stating the estimated volume and content of the gas. The notice shall indicate whether the gas contains more than one (1 ) ppm of hydrogen sulfide. If necessary to protect the public health, safety or welfare, the Director may require the flaring of gas. c. Gas flared, vented or used on the lease shall be estimated based on a gas-oil ratio test or other equivalent test approved by the Director, and reported on Operator's Monthly Production Report, Form 7. d. Flared gas that is subject to Sundry Notice, Form 4, shall be directed to a controlled flare in accordance with Rule 903.b.(2) or other combustion device operated as efficiently as possible to provide maximum reduction of air contaminants where practicable and without endangering the safety of the well site personnel and the public. e. Operators shall notify the local emergency dispatch or the local governmental designee of any natural gas flaring. Notice shall be given prior to flaring when flaring can be reasonably anticipated, or as soon as possible, but in no event more than two (2) hours after the flaring occurs. Table 910-1 CONCENTRATION LEVELS' Contaminant of Concern Concentrations Organic Compounds in Soil TPH (total volatile and extractable petroleum 500 mg/kg hydrocarbons) Benzene , 0.17 mg/I92 Toluene 85 mg/kg Ethylbenzene 100 mg/kg2 Xylenes (total 175 mg/kg2 Acenaphthene 1 ,000 mg/kg Anthracene 1 ,000 mg/kg" Benzo(A)anthracene 0.22 mg/kg Benzo(B)fluoranthene 0.22 mg/kg2 Benzo(K)fluoranthene 2.2 mg/kg Benzo(A)pyrene 0.022 mg/kg" Chrysene 22 mg/kg2 Dibenzo(A,H)anthracene 0.022 mg/kg2 Fluoranthene 1 ,000 mg/kg2 Fluorene 1 ,000 mg/kg2 Indeno(1 ,2,3,C,D)pyrene 0.22 mg/k Napthalene 23 mg/kg Pyrene 1 ,000 mg/kg' Organic Compounds in Ground Water Benzene 5µg/l3 Toluene 560 to 1 ,000 µg/I3 Ethylbenzene 700 µg/I3 900-22 As of February 1 , 2014 Xylenes (Total) 1 ,400 to 10,000 µg/l3'4 Inorganics in Soils Electrical Conductivity (EC) <4 mmhos/cm or 2x background Sodium Adsorption Ratio (SAR) <125 pH 6-9 Inorganics in Ground Water Total Dissolved Solids (TDS) <1 .25 x background3 Chlorides <1 .25 x background3 Sulfates <1 .25 x background3 Metals in Soils Arsenic 0.39 mg/kg2 Barium (LDNR True Total Barium) 15,000 mg/kg2 Boron (Hot Water Soluble) 2 mg/I3 Cadmium 70 mg/kg3,6 Chromium (III) 120,000 m9/kg2 Chromium (VI) 23 mg/kr Copper 3,100 mg/k92 Lead (inorganic) 400 mg/k Mercury 23 mg/kg Nickel (soluble salts) 1 ,600 mg/k2'6 Selenium 390 mg/kg Silver 390m 2 Zinc 23,000 mg/kg" Liquid Hydrocarbons in Soils and Ground Water Liquid hydrocarbons including condensate Below detection level and oil COGCC recommends that the latest version of EPA SW 846 analytical methods be used where possible and that analyses of samples be performed by laboratories that maintain state or national accreditation programs. 1 Consideration shall be given to background levels in native soils and ground water. 2 Concentrations taken from CDPHE-HMWMD Table 1 Colorado Soil Evaluation Values (December 2007). 3 Concentrations taken from CDPHE-WQCC Regulation 41 - The Basic Standards for Ground Water. 4 For this range of standards, the first number in the range is a strictly health-based value, based on the WQCC's established methodology for human health-based standards. The second number in the range is a maximum contaminant level (MCL), established under the Federal Safe Drinking Water Act which has been determined to be an acceptable level of this chemical in public water supplies, taking treatability and laboratory detection limits into account. The WQCC intends that control requirements for this chemical be implemented to attain a level of ambient water quality that is at least equal to the first number in the range except as follows: 1 ) where ground water quality exceeds the first number in the range due to a release of contaminants that occurred prior to September 14, 2004 (regardless of the date of discovery or subsequent migration of such contaminants) clean-up levels for the entire contaminant plume shall be no more restrictive than the second number in the range or the ground water quality resulting from such release, whichever is more protective, and 2) whenever the WQCC has adopted alternative, site-specific standards for the chemical, the site-specific standards shall apply instead of these statewide standards. 5 Analysis by USDA Agricultural Handbook 60 method (20B) with soluble cations determined by method (2). Method (20B) = estimation of exchangeable sodium percentage and exchangeable potassium percentage from soluble cations. Method (2) = saturated paste method (note: each analysis requires a unique sample of at least 500 grams). If soils are saturated, USDA Agricultural Handbook 60 with soluble cations determined by method (3A) saturation extraction method. 6 The table value for these inorganic constituents is taken from the CDPHE-HMWMD Table 1 Colorado Soil Evaluation Values (December 2007). However, because these values are high, it is possible that site- specific geochemical conditions may exist that could allow these constituents to migrate into ground water at levels exceeding ground water standards even though the concentrations are below the table values. Therefore, when these constituents are present as contaminants, a secondary evaluation of their leachability must be performed to ensure ground water protection. 900-23 As of February 1 , 2014 KLEINPELDER &r,ytrt Ptctp4e Yas i sot APPENDIX B Table B1 . Sterling Oil Discharge Response Operating Team Table B2. Emergency Response Contractors 20155304/DEN 15O18189 April 17, 2015 © 2015 Kleinfelder (KL E/NFEL DER Table B1 . Sterling Oil Discharge Response Operating Team Name Position Office Cell City Rodney Barnes Facility Response 720.881 .7775 303.589.6214 Briggsdale, CO Coordinator Sean Miller 1 Facility Manager 970.522.5101 970.520.5717 Sterling, CO Shawna Moser-Mese I Safety Officer 970.768. 1113 Milliken, CO Table B2 . Emergency Response Contractors Company Service Address 24-Hour Office Belfor Environmental 24-hour 5075 Kalamath Street, 800.930.0011 303.425.7526 Responder and Denver, CO 80221 cleanup. Kleinfelder Inc. Site 1801 California Street, 303.237.6601 characterization Suite 1100 and cleanup Denver, CO 80202 coordination 20155304IDEN 15O18189 April 17, 2015 © 2015 Kleinfelder rKL- N EINEEL DER &ryh!People NyAt Solut'wn APPENDIX C Intercept Point Figures 20155304/DEN15O18189 April 17, 2015 © 2015 Kleinfelder 3 Banner County J .r *6 215 94 ia a i I.r K I j =23 t c 17 P- , q a Laramie ' County 154 DI' . a is +s Pat 14als ole f a I (� ni Retied —• -Shane Pr �Ie +1*011 FId ;30 To ,f. , m w Cheyenne to,,w is County l Kimball 214 County canal* ti Ito ) n NeA*aska ill Carot410 :: I25 I+'• r.as a :u ST 1:6 • :a r I , • Logan 1 in .: County 17 i • It- 6_ Grover :I a''"^' A Compressor nnt, -2•00. Station ..� Centennial B Gas Plant A Weld ,7 Venter County Gas Plant - -- 'nos is , 4 Hombergor Sterling; � ' viOrr A Compressor :+ + Bob White A A3 Hill Station l� ;al"'.. 2'a"'"" Compressor Compressor Station Station 6 New Raymer A Compressor le Station G aIMon - MO IJ2 Gill p ^i 1.9eld I: Ire / -- I.ptvt I. 4- 99 iti .q � isiimielit 55 1 it,,,,,,. ,,,, Ja'r ' r t , ti "its %IV • �t $ , r wonde 0' CNoerl•> PI2Ond Morgan \ l�fVorul AUPort _9„,,,......4300-e....°°°°°----------- County �'�. �!- 16 Washington pis dull County W - 7 111 a $2 Service layer Credits Frcuuces Esri, HERE, Delon-no USGS tntormap fncrernen t.P Corp , ',ROAN. Esri Japan, METI, Esri Cn a (Hong Kon ). Esrl "' .. r to s. an >c tyvooMv. l— . User Community Legend IM Wwr.ntlon brdded on INS gaphle reeraseMNsn has been corrpl4d from.variety et sowgs end me sublet lo Wipe e.Mmeit eettte ttta daseer makes no r.pcn.ntadons or A Facility Location ...au"it es implied.ts to octal.centptMn.i a tnnln.ss, or rQhls b the O O ^...au"h4+mwen IDY dearnardIs not&MoedaO los ono as a land survey product 5 LU nor It It designedor Intended ate corosuctmen d.srym docanvnt tn. in. or mt.n. . the Wormsdoe contained on trips e pracn representation Is at the sole risk of the Miles County Boundary ICan,usnp of rn.tnnp the Wamaten e =r PROJECT NO. 20155304 FIGURE KL EINFEL DER DRAWN 4/17/2015 Sterling Energy DRAWN BY: J Weber I Bright People. Right Solutions. CHECKED BY: L. Bott Facility Location Map FILE NAME: Weld County and Logan Count Colorado www.kleinfelder.com Fig1_Overview.mxd g y A • O • CW.,nty R4...t U C: 1,. � : . %.tflrr.tf RNd Li Service Layer Credits Source- Esn..Dig Ia•�iohe GeoEye E arthsbr ,eoq,aphtcs, ONES/:Airbus OS, USDA USGS AEX Geri-napping AmuGrid, tl. !GP, swisslopo. and the 315 User Co trru:ity Sources ksn, HERE, Oct Dole, USGS, lotermap,. increment P Co:q., t4RC./41, Esrs Japan METI. Esri China 1ho'c Kann). Esr' (Trmland;. TorrtTorn, Marmylnd.:_: t OpeiStreeiipar. --tributors. and the GIS Use:. ;;orninuniti Legend T o ydonnipat rc<vdsd on this pis eic ter.s nwston his peen tonvd.d horn a winery ct soviss end a sutcin10 chatp..mf.OsA nice kl.ri.4Or muses ro npnnentatdns L. n Intercept Point mut/nL.s.•gross o.ra5.d.es le set.eeey,tomprlen.;t,tlmelrlsss,Cr Wits L the n o. 1 ..:s c1 loch ptbnMt.on The 04u/won n d00 .net Irt.h ton IA ass tend survey pnt s y:rl 11 t O.IOnaO ct Irt.nd/d!)s tMstt.<t.on d.VOA dotvnenl. Th.Use Or MM1we d lM utto.mswn cenUo4 on tin yapnt r Wes'inlet-seis st the tots welt of On Miles Facility Location Putt viva or nww no We vforrruton PROJECT NO. 20155304 FIGURE DRAWN 4/17/2015 Sterling Energy Bob White Compressor Station KL EINFEL DER DRAWN BY: J. Weber 2 Bright People. Right Solutions. CHECKED BY: L. Bott Intercept Point Map FILE NAME: Weld County and Logan County, Colorado www.kleinfeider.com Siteslntercept_Mapbook.mxd A or iii) Lounia itSA.i 11 Tr\rice Layer Credits' Source' Esn DigilaiGtobe GeoEye Earthsrar ,aJgraphics. CNES/Airbus DS, USDA, USC3 AfF.s Gatrllapping Aeroghd N. (GP. swisstopo, and the GIS User Community :,otir_•es Esn. HERE. De:orrne, USGS, inlemtap, inrreir rit P Corp • NRCAN, Esri Japan MET! Esri China it•ioivj Kong), Esti CThat:t;tdr, 1 iornihm. Mapnrylrldia ' OpenStreetMap ccrltrihulors. and the GS Use . Community Legend The tNormaeen ewr.4ed on Mt graph<repretertatno has Dean Coate d hen a varsity or *orate and a tutjnt to thane Strout mace KMeSeber nose►no teptnentaeons a e(lrtaM»t 'press eterrata as toaccwaty.tenp4Mras.prraanen.ot IOU btM 0 0.25 0.5 0 Intercept Point visa d suth rWrmat.n Ina dxumerrt n not MMndedta use as a land army pnd,as net is It designed or intended as a construction defy+document TM ion at rrhus• d the Information Contained on this seethe iaprer.'.tel'n it atiM erig risk d lhs Miles A Facility Location part(us np w MAW•'9 Ine rtkrmaboa PROJECT NO 20155304 FIGURE .."Th DRAWN 4/17/2015 Sterling Energy Hill Compressor Station KL E/NFEL DER DRAWN BY: J Weber 3 Bright People. Right Solutions. CHECKED BY: L BottI Intercept Point Map FILE NAME: Weld Count d Lo Count ,, Colorado wwwkleinfelder.com Siteslntercept_Mapbook.mxd y an gan oun y r� r t 4 I1 z n d S G Service Layer Credits Set.lrce Esn DigilalGlobce GeoEye. Eartnstar ;eographics, CNESIAirtbus DS. USDA. Usas AEX Getn,applrrg Aetogrin. P:. IGP, swisstopo, and the GIS User Community :.or`!ttrces. Esri, HERE. DeLonne, USGS, Intermap, lre.ernent P Corp L'. •;RCAN, Esn Japan MEII Esri China (Hong Kong), Esc, (Tr:atiaixt). tr mTeni. Mapmy!n<Iia r::,Cipen.streetMap contributors and the GIS User 1f Legend the Worn aeon Included VI this graphic ehos shale his been compfed trim a ea+lety of ,o,ac.,andasobislhchang.ftt,.nAhate. Kww.ldermikesthr.ce.,.rttn,.. 0.25 0.5 0Intercept Point lrraMw.,•hes set rebid,at lO KtIIKy,terminates*,ruminant. N runts b the 0 •neof wen nk.manat The docunwre is not Intended loo uf•is a land.u.ay pmdu ct nor II designed c.lfsndedat a coatV,gl Wn 641171 dot InOnt The kite at snit ut• Mi1eS the letormalb[I t9N_11quiltd(ACAS quilt rep"tehaeice i.N ten sole tea of m• A Facility Location [-Arty ultnj ar munend the Wumatun PROJECT NO. 20155304 FIGURE DRAWN: 4/17/2015 Sterling Energy Hemberger Compressor Station KLEINFELDER DER DRAWN BY: J. Weber 4 Bright People. Right Solutions. CHECKED BY: L Bott Intercept Point Map FILE NAME: Weld County and Logan County, Colorado www.kleinfelder.com Siteslntercept_Mapbook mxd I A lik r~ a e. n SS a..' K ♦r a a ta V Secv ce Layer Cie is Source. Esri !.?:gi;al iube is Eye Earthslar r:. GeafJiaphlcS, CNEStstauS DS, USD':k. USOS AEX Gerniapptrig Iserwgrid, IGN- !GP. sw sslapo aril the. GIS US C9n9mynity Sotuces. L ri. I !E It nci..urn�. US �iilt5:mad inuenient P Crap , NRCAN. Esri J.aLlan MET!- Esri Chill -Icong kettlgi, Este ,Th2MEaix1; TrxillArti• Map:Yryl^idla t C e3”S;reRt la ! _:cranhokrYs. af:d no GIS User ;.rr:r -un ! Legend IThe information included on this graphic representation has been compiled from a variety of sources and is subject to change without notice Klelnlekler makes no representations or Intercept Point warranties,express or implied,as to accuracy.completeness.lirneinoss.or rights to Ilse 0 O.2 rJ O-5 1 ne of such information The document h is not intended for use as a land survey product �/ nor Is designed or intended as a construction do sign cumwnl The use or mouse of the Information contained on IMs graphic representation is al the solo ink of the Miles Facility Location party using or misusing the Information PROJECT NO 20155304 FIGURE . 1,4°Th DRAWN: 4/17/2015 Sterling Energy KL EINFEL DER DRAWN BY: J Weber Grover Compressor Station Bright People. Right Solutions. CHECKED BY: L Bott Intercept Point Map FILE NAME: Weld County and Logan County, Colorado www.kleinfelder,com Siteslntercept_Mapbook rnxd K i i A C. I t. 6' ) Service Layer Crodsts Source' Esn. DtgtalGloce GeoEve Earthstar Geographies CNES/Arbus DS. USDA, USCIS AEX Getmapping Aerogrid Uri J. (OP swisstopo, and the GIS User Community Sources Esti, HERE. Del.onne, USGS, Inleonap, increment P Corp rIRCAN, Esri Japan AiEl I, Esr China CHong Kong), Esri (Thailand), romTom, Macmylnd;a, openStreetMap contributors arid the GIS User r :ornnuntty Legend l he WonNtgn wcludoi on gin papAc tape tittle is N+Nto corlpMd trout i vatuy a .Duel as it avtlrtto thongs*bolt holes KI•npid•t moms no re pa o•nb eons* 0 Intercept Point wasting*..*spins etimp*.I,at to KCJKy.ponpllsM N.Wre lrw N.a MN,WO" 0 0.25 0.5 u)t of.Yeti Tinmilun TM Soared n Oatirsndldfut will n t ten ',ow,d',ow,product 1 n)t ii a On cried nr uytndad as t r amtud,0tt d•upi dx nal The unit nr u.• Miles 4t ttt,ttORnaW0n tonti'Ndn(P ea°tithe owns'Notion n at try ID*nth of a• Facility Location C using or ml.)A M the»varrvton PROJECT NO 20155304 FIGURE DRAWN: 4/17/2015 Sterling Energy New Raymer Compressor Station • KL EINFEL O CR DRAWN BY: J. Weber 6 Bright People. Right Solutions. CHECKED BY: L. Bott Intercept Point Map FILE NAME: Weld County and Logan County, Colorado www kleinfeldeccom Sitesintercept_Mapbook mxd • 11 It S; Is is �..s`y Rci 13t :.w:Ay r,i�tl.J6 Caanty ' A • • Legend iN wionneaan nchdad an Uia WO(rap eaanalun hat Pon carryall hem a rat*ty N asurces and r Whitt to things.Ntrout nano ttlanfaider natal no npreaan40ans a wattlrY,H,upatt a/ d,N to KivaCy.<enpMMMti llnwiness et rgNa Ira Os 0 0.25 0.5 1 0 Intercept Point ma of tut,'Sarmatian all distvnard■not m$Nad ter vie as a sand surrey praduil non ke deigned r mtanded at a taraucl.On design*Cumin, the use as nits* 004 iKOnu5tn cordind on t rS'AOC laOnt aNatbn ns OP*cola rat Of Om --■ Miles Facility Location party vi rig or missing IN informaban PROJECT NO. 20155304 FIGURE DRAWN: 4/17/2015 Sterling Energy Yenter Gas Plant KL EIAIFEL DER DRAWN BY: J Weber I Bright People. Right Solutions. CHECKED BY: L Bott Intercept Point Map --_ - FILE NAME: Weld County and Logan County, Colorado www kleinfelder.com Siteslntercept__Mapbook mxd x S C ll c, yi\ I+•J ;ervica Layer Credits- Source Es,n, DiciitatGiobei GeoEye tEarirsiar 3eograph cs. CNESiAirbss OS. USDA, USGS AFX G5unapl:Ir:ct 1.erca?d. N. IGE swisstopo, and the GtS User Community ;ounces: Esri HERE, Delorme, USGS, Intermap. fnc;9ntur:t P Ccm Esri Japan AMETI. Esri China (Hong Kongi. Esn {Ttt^;I1Jnz t. InmTont, Mapmylndia, ' Gpen` tneetMdp ccur;tributurs. and thi.• GtS User Legend 1 M infometwn included on lie grafnc rays v dalun has Man cetrpaad horn a variety al novas and■Wagtail lo ttanq*rebus netts KMkud.r makes no npassantatnnt« 0Intercept Point rip rant** urnsrfeted.n/s ecru,acr.amo4Unass.Ymaanass.a fiefs b the 0 0.25 0. 5 1 cl Luce snbrmaoat.Thu document n nol uasndad In lino as a sves Produce n>�n 1 GsVrtad a rdendad as a curia KUM Msq'daaurnnt The uta or mama J lie information hennaed otitis graphic rpratetaar:on it at fie la fns or lie _- Miles A Facility Location cant usurp asmarling Ina tnlamatun PROJECT NO. 20155304 FIGURE DRAWN Sterling Energy 4117/2015 Centennial Gas Plant KL E/NFEL DER DRAWN BY: J Weber 8 Bright People. Right Solutions. CHECKED BY: L. Bott Intercept Point Map Q FILE NAME. Weld County and Logan County, Colorado www.kleinfelder.com Siteslntercept_Mapbook.mxd KLE/NFELOER eaght People Right Solutions APPENDIX D Spill Mitigation Figures 20155304/DEN15O18189 Apiii u i , 4U I a © 2015 Kleinfelder KL EINEEL DER �. . rahf Solutions. V_. 'mow ;Fitt , •R• c • • lap+ itnZ! Cr ur4 ler) Figure D-1 Detail of a plastic-lined trench to intercept overland and subsurface flow 20155304/DEN 15O18189 April 17, 2015 © 2015 Kleinfelder KL\,....„ „sea lloari + r �� CLL_vcc' Le . e • ' . r- ,:zetz...e: 'PR 3aisd 4 . t a , , + .., . • ,- A,1.QT 7 Figure D-2 Culvert and earth dam weirs 20155304/DEN 15O18189 April 17, 2015 © 2015 Kleinfelder KL EINEEL OER 4:. )3, Figure D-3 Water bypass (underflow) dam 20155304/DEN 15O18189 April 17, 2015 © 2015 Kleinfelder KLE/NFELDER r.,,nc erop'c R,vt 1 Swu:rw• CrA<Ser PIP, LOCO �_�_ r • i ' • _ re • • ar--1:47--ILL3/4.4"sesti .....a • • amr.4-a,a.........-- -sr = I1 7 . ill Lr a ter+.•' err.�.-..j s_r -,-``... •.o —1 aEsa/tsmT I w$t TALL pi, r;;IC ►a •-fS+ilaL.) „i'"r CS.a.aa rr'11 \,......or1/41.....rriessrelie, . o.ostee Vt. ,..ee'eseell C.4:v mil • L a. r �•�''' t . J• MAME Ca (II 4.�% � f �K AC PC �� r /• ,c Yp+ 1 � Cr11►+es5:41� r' `_ /�r _� FASi!�HEa S,H4RM' _ / BURLAP Y Y Y I 41 /4.%es?WC". *ON;IT‘ \ eil% / • 4 # 4,V,,Z AA A 4Ane - S ‘1)4/Sbic STYROFOAM LOGS ix SJR'. AP Figure D-4 Various means of connecting booms 20155304/DEN15O18189 April 17, 2015 © 2015 Kleinfeider v---� KL EINFEL DER Myra People.Sight Solution: CNA ,ea win' I :jet / ATR 0( ::*; \ see:4:4 a ir e - i NAL•s_J. • "414-4..dte . ..-*.. 1 sten NASA LOG f rti....NI / dfi1• sib , �N{.=a . .•s_. f}is .1h At r ~' Vilna Figure D-5 "Jellyroll" and "sausage roll" improvised sorbent 20155304/DEN15O18189 April 17, 2015 © 2015 Kleinfelder KL EINFEL DER -......., ......____:e.. Snght People Right Solutions. • ..+rr.. ;—.•• %e _-.. r—. .l. a ��:•! s•�! .IrF ��.., Peal r1(Zti ti••Ma.1 s"' ta ... . . +►ate ...�•r r'*aua+tes..•• f NrC.�{ • TN � 2 1.• is t w .3 in u, dd x i re .. z g � �- _ }.. .. } r r W s 1 .• } 1.11 Jinn I re 16 I .C 3 Is I 1 i 0 10 :) 10 to Sc PO HOW 60OM AN Cat M Da E2Fo Figure D-6 Boom angle deployment vs. water velocity 20155304/DEN15O18189 April 17, 2015 © 2015 Kleinfelder KL SINFEL DER Li;C;: • tcy�ti K; r,{iJ,�li.r Clit. o-y pt�oceol _r AAEA .fir 71 *_ow ir✓r z_ Ai".UIJULtIC0 liti.zopi / irdlaL'. tiwvst._aa OA? Ea 9_-Ca aSuOvSNS Tilt ,,P$flt w 3•Ar'EA ever aw --.. vedeparee Figure D-7 Multiple angled booms 20155304/DEN15O18189 April 17, 2015 © 2015 Kleinfelder KLEINFELDER Wit,tvpt ifahf So Altars • Let 30cria „Jr. zeceiviry Stray 0: Ganife; `xaa�a Figure D-8 Techniques for boom attachment and deployment 20155304/DEN15O18189 April 17, 2015 © 2015 Kleinfelder Hello