form c-1 - deq.state.wy.usdeq.state.wy.us/wqd/wypdes_permitting/wypdes_pns_and_appr_permits... ·...

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SUBMIT ONE HARD COPY AND ONE ELECTRONIC COPY (CD)

FORM C-1

WYOMING POLLUTANT DISCHARGE ELIMINATION SYSTEM APPLICATION FOR PERMIT TO SURFACE DISCHARGE PRODUCED WATER FROM

OIL AND GAS PRODUCTION UNIT DISCHARGES

Revised 8-29-2011 PLEASE PRINT OR TYPE (Submission of illegible materials will results in return of the application to the applicant) 1. The discharging facility will produce:

Oil Oil and natural gas Natural gas Check the box corresponding to the type of application being applied for:

New Permit

Permit Renewal. Permit number _____________ Expiration Date: _______________

Permit Modification. Permit number _____________ Expiration Date: _______________

(For permit modification, please attach letter explaining modifications requested.) 2. Company, Contact Name, mailing address, e-mail address, and telephone number of the individual or company which

owns the facility producing the discharge, and the person (consultant) responsible for permit submission. Company Contact Name Mike Perius

Consultant Contact Name Allen D. Jones

Company Name Ballard Petroleum Holdings, LLC

Company Name Western Land Services, Inc.

Mailing Address 845 12th Street West

Mailing Address 1662 South Sheridan Ave.

City, State, and Zip Code Billings, MT 59102

City, State, and Zip Code Sheridan, WY 82801

Telephone Number 406-259-8790

Telephone Number 307-673-1817

E-Mail Address [email protected]

E-Mail Address [email protected]

Status of applicant as owner, operator or both ____Operator___________________________________________ Status of applicant as federal, state, private or public___Private____________________________________________ 3. Name of the facility (lease, tank battery #, etc.) producing the discharge (this is the facility name that will appear on the WYPDES

permit. It is not necessary to name every well contributing to this facility’s discharge in this section) ______East Jewel Fowler Discharge______________________________________________________________________

For Agency Use Only

Application Number WY00_______________

Date Received:

__________________

(mo/day/yr)

Ballard Petroleum Holdings LLC: 2011/11/18/NEW/10110201/East Jewel Fowler Discharge Page 1 of 27

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4. Name(s) and mailing address(es) of owner(s) of the surface rights on whose land the discharge occurs (in cases where the land is owned by the state or federal government but surface rights are leased to a private individual, provide lessee’s name and address)

(additional spaces may be added as necessary)

Landowner #1 Name John Fowler

Landowner #2 Name

Mailing Address P.O. Box 3557

Mailing Address

City, State, and Zip Code Gillette, WY 82717

City, State, and Zip Code

Landowner #3 Name Landowner #4 Name

Mailing Address Mailing Address

City, State, and Zip Code City, State, and Zip Code


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5. Provide outfall information in Table 1 below.

TABLE 1. Outfall information

* The mainstem is the closest perennial water (class 2). Stream distance from the outfall to the mainstem should be measured in stream miles versus as “the crow flies”.

Discharge Point

(Outfall) #

Quarter/ Quarter

Section Township

Range

Latitude

(NAD 83, decimal degree format,

accuracy to nearest 5 decimal

places)

Longitude

(NAD 83, decimal degree format,

accuracy to nearest 5 decimal places)

Immediate Receiving

Stream

Mainstem*

(Nearest

Perennial

Water)

Distance from outfall to main stem (stream

miles) *

County

001 NESW 8 54N 67W 44.67645 -104.93703 Unnamed Tributary to Alkali Draw

Little Missouri

River

1.9 Crook

002

003

004

005


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6. Describe measures to prevent access to the skimming ponds by large grazing animals. Pits will be fenced

7. Describe control measures (such as installation of flagging or netting) employed to deter waterfowl from landing on the skimming ponds. Flagging with streamers and ‘guy-line anchoring points’ will provide visual waterfowl deterrent.

8. Attach a description and clear, legible, detailed topographic map of the discharging facility extending one mile beyond the property boundaries of the source. Include the following: See attached Site Map and Treatment Facility Schematic

a. A legend b. Discharge points (outfalls) c. Immediate receiving streams d. Location of nearest downstream irrigator (Not Applicable) e. Section, Township, and Range information f. Water flow lines

9. Attach a site diagram including a schematic line drawing showing the water flow through the facility. Please include:

See attached Treatment Facility Schematic and Siphon & Water Transfer Tanks Operations Schematic. a. Water flow lines b. Treater units c. Skimming tanks d. Skimming Ponds e. Stock tanks If any of the above items in 8 or 9 are not applicable please indicate in the description and include a brief explanation as to why the items are not applicable)

10. Describe the control measures that will be implemented to achieve water quality standards and effluent limits. If proposing to utilize a treatment process, provide a description of the treatment process. Include list of chemicals used and provide a Material Safety Data Sheet (MSDS) for each chemical. Treatment Process: Production water will first pass through a 6’Dx20’L horizontal free-water knockout (FWKO) vessel that will separate approximately 70 to 80% of the water from the oil/gas. Separated water will travel to the first “water tank” that will have a size of 12’Dx25’H= 400 bbl capacity. The first water tank will allow for additional “settling time & available oil will be trapped here and removed. The remaining 30 to 20% water/oil emulsion from the FWKO vessel will go to a 6’Dx20’L horizontal heater-treater vessel. Within this vessel the oil/water emulsion will be heated to +/- 160 deg. F and the oil separated from the water. The oil will go to 12’Dx20’H=400 bbl capacity oil tanks. The separated water will leave the heater vessel and go to the same (first) 400 bbl water tank. The combined water stream from the FWKO and heater-treater vessels will “siphon” from the first water tank over to a second water tank which will be the same size as the first. Any remaining oil will be trapped in the second tank and removed. Water from the second water tank will pumped through a pipe to the final treatment/discharge pits located off the well pad(s). A low pressure water pump (15 psi ) system with a 10 micro sock filter will be installed between the discharge pipe of the 2nd water tank and the entry point of the 1st of the 2 water skimming pits. This filter system will extract minute particles of oil and the construction will provide for changing of the filters ‘on the fly’ via a 2-filter system with a diverter valve to isolate 1 filter for changing, while allowing un-restricted flow through the 2nd filter. Two lined off-channel pits will be constructed in series so that the treated second water tank fluid will will be pumped to the upper pit to a lower pit and then gravity feed to a lower pit and then will discharge to a downstream discharge facility. The pits will contain plastic liners to limit infiltration and will be fenced to limit stock animals from entering. Water flow from the upper to lower pit cells will pass through an oil skimmer. Flows from the lower cell will also pass through an oil skimmer before discharging at a downstream outfall facility. For the purpose of stock and wildlife, an option for water to flow through a stock tank prior to reaching final discharge will be available. All the piping from both wells to the pits and from the pits to the outfall will be 4”. The only chemical to be utilized within the treatment process will be an emulsion called BREAXIT® EC2087B. The MSDS for this product is attached to this application. The emulsion chemical is injected into the flow line at the wellhead. This chemical mixes with the entire flow stream as it leaves the wellhead going to the Free Water Knockout and then the heater-treater. The Fowler 22-8 has 4 qts/day and the Fowler Federal 23-8 gets 6 qts/day. This chemical is oil soluble/water dispersible.


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Flow throw the treatment pits will be such as to maximize detention time for dissipation of Sulfide-Hydrogen Sulfide that may be present within the discharge water. This dissipation will be further enhanced by flow over rock rip-rap associated with the outfall structure resulting in additional oxygenation prior to the actual discharge into the natural downstream channel.

11. Describe the control measures that will be implemented to prevent significant damage to or erosion of the receiving water channel at the point of discharge. Discharges into the pits and at the final discharge outfall will be stabilized using rock rip-rap for energy dissipation. The rate of fall for the discharge water will be kept at a minimum to allow for continuous discharge and to minimize erosion possibilities. A CBNG type stock watering tank will be installed upstream of the outfall. Water entry into this tank will be controlled by a valve system so that the tank can be bypassed when stock watering is not required thereby allowing the full discharge of treated water to flow directly to the downstream outfall structure.

12. Provide the results of a water analyses for a sample collected from a location representative of the quality of water being

proposed for discharge for the parameters listed below, in Table 2.

The analyses must be conducted in accordance with approved EPA test procedures (40 CFR Part 136). Include a signed copy of your lab report that includes the following:

a. detection limits b. results of each of the chemical parameters at the chemical state given below c. quarter/quarter, section, township and range of the sample collection location d. Time and date of sample collection e. Time and date of analysis for each parameter f. Detection limit for each parameter as achieved by the laboratory.

Attached is a representative water quality sample taken from the Fowler 22-8 well. This analysis is also representative of the Fowler Federal 23-8 well. Both wells are completed in the Minnelusa ‘C’ Sand.


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*The values listed in the Standard or Limit column are associated with water quality standards (Chapter 1 of Wyoming Water Quality Rules and Regulations) or technology-based effluent limits (Chapter 2 of Wyoming Water Quality Rules and Regulations). **This parameter is only required for those discharges located within one stream mile of a class 2 water.

13. Which geologic formation is the origin of the produced water? Minnelusa ‘C’ Sand

TABLE 2

PARAMETER

REQUIRED DETECTION LIMIT and Required Units

STANDARD OR LIMIT*

SAMPLE RESULTS for Fowler 22-8

Aluminum, Dissolved 50 ug/L 750 ug/L ND Arsenic, Total Recoverable 1 ug/L 150 ug/L ND Barium, Total Recoverable (New Facilities O l )

100 μg/L 2000 ug/L ND Boron, Dissolved (New Facilities Only) 100 ug/L 5000 ug/L ND Cadmium, Dissolved 5 ug/L 0.25 ug/L (hardness dep) ND Calcium, Dissolved 50 ug/L, report as mg/L 611 Chloride – Technology Based 5 mg/L 2000 mg/L 19 Chloride, For Class 2A and 2B Waters 5 mg/L 230 mg/L na Chromium, Dissolved (III) 1ug/L 74.1 ug/L (hardness

d d )ND

Copper, Dissolved 10 ug/L 9 ug/L (hardness d d )

ND Fluoride, Dissolved (New Facilities Only) 100 ug/L 4,000 ug/L 2340 Hardness (CaCO3) mg/L 10 mg/L as CaCO3 (for metals analyses) 2200 Iron, Dissolved 50 ug/L 1000 ug/L 113 Iron, Dissolved, for Class 2A and 2AB waters 50 ug/L 300 ug/L na Lead, Dissolved 2 ug/L 2.5 ug/L (hardness dep) ND Magnesium, Dissolved 100 ug/L, report as mg/L 161 Manganese, Dissolved 50 ug/L 1462 ug/L (hardness dep) 57 Manganese, Dissolved, for Class 2A and 2AB

t50 ug/L 50 ug/L na

Mercury, Dissolved 1 ug/L 0.77 ug/L ND Molybdenum, Dissolved (New Facilities Only) 100 ug/L 300 ug/L ND Nickel, Dissolved 10 ug/L 52 ug/L (hardness dep) ND Oil and Grease 1 mg/L 10 mg/L 6 pH 0.1 pH unit 6.5-9.0 s.u. 6.70 Radium 226, Total Recoverable 0.2 pCi/L 5 or 60 pCi/L Pending Radium 228, Total Recoverable** 0.2 pCi/L 5 pCi/L Pending Selenium, Total Recoverable 5 ug/L 5 ug/L ND Silver, Dissolved 3 ug/L 3.4 ug/L (hardness dep) ND Sodium Adsorption Ratio Calculated as unadjusted

ti 0.3

Sodium, Dissolved 100 ug/L, report as mg/L 28 Specific Conductance 5 micromhos/cm 7500 micromhos/cm 3210 Sulfates 10 mg/L 3000 mg/L 2100 Sulfide-Hydrogen Sulfide (S2-, HS-) 0.01 mg/L 2 ug/L 81 Total Dissolved Solids 5 mg/L 5000 mg/L 3370 Total Petroleum Hydrocarbons 1 mg/L ND Zinc, Dissolved 50 ug/L 118.1 ug/L (hardness dep) 19


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14. Were the above analyses collected from this facility (referenced in item 3)? Sample taken from Fowler 22-8

YES NO

If no, describe origin of samples including well name, location, depth, geologic formation, field, and date sample was analyzed:

15. For new facilities, provide the expected (estimated) flow rate from each outfall in barrels per day and million gallons per day,

and provide the rationale behind the flow rate estimate. . Flow-rate at the outfall is expected to be at 1200 BWPD or 50,400 GPD. This is the current combined production rates of the Fowler Federal #23-8 and Fowler #22-8 oil wells which will provide the only water production source to this outfall. Current production rates are daily monitoring via 400 Bbl tank strappings and monitoring of water transportation tickets from the water hauling contractor, Kissack Water Services. Permitted Production rates may be increased by 20% (1440 BWPD or 60,480 GPD) should the ‘application for surface discharge’ be granted. For existing facilities, provide actual flow data from each outfall within the last six months

Will discharge be continuous or intermittent?

If the discharge is to be intermittent the following information for each outfall shall be provided: (I) Number of times per year the discharge is to occur. (II) Anticipated duration of each discharge. (III) Anticipated flow of each discharge. (IV) Months in which discharge is expected to occur.

16. Are any of the required chemical constituents in the laboratory analysis present in concentrations above Wyoming Water Quality Standards or limits as identified in the third column in Table 2, page 5?

YES NO

If the answer to question # 16 is yes, answer 16a.–16.c below. If no, proceed to question 17.

a. Which constituents? Sulfide-Hydrogen Sulfide (S2-, HS-) b. Has this constituent been addressed in the response to question 10? Yes c. Describe how the exceedance was addressed. This sample was taken after being treated by the Free-Water

Knockout Vessel, Heater-Treater, Siphon Tanks, a a 10 micron filter. The sample did not have the benefit of the Treatment pits and Final Treatment Rock Rip-Rap Outfall since these items had not been constructed at the time of sampling. Once construction is completed and the entire treatment facility is complete, the elevated value for Sulfide-Hydrogen Sulfide should be reduced to below standard limits.

17. Will blending of fresh water with produced water be used as a treatment option?

YES NO If the answer to question # 17 is yes, answer 17a.–17.c below. If no, proceed to question 18.

a. What is the anticipated blending rate of fresh water and produced water? ____________________________ Be advised that permit will require water quantity and quality monitoring before and after blending occurs. Also, an automated shutdown system must be installed and maintained on site that terminates the discharge of produced water in the event of the shutdown of the fresh water supply.

b. Provide confirmation from the State Engineer’s office of fresh water use. c. What is source of fresh water to be blended? No surface water source is allowed.

18. For facilities new after January 1, 1998: Is there active irrigation in the drainage downstream of the discharge (Please note

that this response includes both artificially and naturally irrigated bottomlands.)


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Not Applicable (Facility is pre-1998) YES NO

If yes, at a minimum, the WYPDES Program requires submission of the following information:

1. Location(s) of irrigation diversions and/or sub-irrigated acreage; 2. Type(s) of Crops grown under irrigation; 3. Description of Irrigation Practices 4. A topographic map showing irrigated acreage, any structures, ownership of irrigated acreage. In addition to the minimum information described above, the WYPDES Program may require additional information should the permittee request site-specific effluent limits protective of irrigation uses. Contact the WYPDES Program for more information regarding requirements for site-specific SAR, TDS, and EC limits. 19. For facilities new after January 1, 1998: Provide name(s) and address(es) for all downstream irrigators between the

outfalls and the mainstem. Not Applicable (Facility is pre-1998)

Irrigator #1 Name NONE – Dry Land Farming Only

Irrigator #2 Name

Mailing Address Mailing Address

City, State, and Zip Code City, State, and Zip Code

(additional spaces may be added as necessary) 20. 40 CFR Part 435 Subpart E requires that the permittee document agricultural and wildlife uses of produced water. Provide

documentation that the produced water will be used for agriculture or wildlife during periods of discharge. Agriculture and wildlife use includes irrigation, livestock watering, wildlife watering, and other agricultural uses. Agricultural and wildlife use documentation includes (but is not limited to) a certified letter from a landowner(s), a formal written statement from a state, federal or local resource management agency, or a formal written statement with supporting documentation from a natural resources or environmental professional accompanied by the credentials of the natural resources or environmental professional. Agriculture and wildlife use documentation must be provided for each outfall included in the application. Agricultural and wildlife certification must be submitted for each outfall’s discharge, and must have original signatures.

Facilities permitted prior to June 10, 2002 are exempt from the above requirement. The Wyoming Game and Fish Department has determined that discharges of produced water from WYPDES-permitted oil production units in Wyoming, existing as of June 10, 2002, are being used to enhance wildlife propagation and habitat.

This facility was WYPDES or NPDES permitted prior to June 10, 2002 Documentation of beneficial use is enclosed. Attached is the Documentation of Beneficial Used with landowner’s

original signature.

21. Provide a listing of all active permits or construction approvals received or applied for by the applicant for the site described in this permit application in accordance with Chapter 2, Section 5.(a).(v). T. of the Wyoming Water Quality Rules and Regulations.

a. Hazardous Waste Management program under the Resource Conservation and Recovery Act. b. Underground injection control program under the Safe Drinking Water Act. c. WPDES program under Clean Water Act. d. Prevention of Significant Deterioration program under the Clean Air Act. e. Non-attainment program under the Clean Air Act. f. National Emission Standards for Hazardous Pollutants under the Clean Air Act. g. Section 404 of the Clean Water Act. h. Impoundments and/or Appropriation of Surface Water under the State Engineer’s Office i. Reservoirs under the Oil and Gas Conservation Commission. j. Other relevant local, state, or federal environmental permits.

Existing Permits: WY O&GCC drilling permits for Fowler Federal 23-8 and Fowler 22-8. BLM drilling permit for the Fowler Federal 23-8.


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Authorized signatories for this application are the following:

For corporations: A principal executive officer of at least the level of vice president, or the manager of one or more manufacturing, production, or operating facilities, provided the manager is authorized to make management decisions which govern the overall operation of the facility from which the discharge originates.

For partnerships: A general partner.

For a sole proprietorship: The proprietor.

For a municipal, state, federal or other public facility:

Either a principal executive officer or ranking elected official.

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

MICHAEL PERIUS___________________________ OPERATIONS SUPERINTENDENT_____________ Printed Name of Person Signing Title _____________________________________________ _____________________________________________ Signature of Applicant Date 406-281-8209__________________________________ 406-259-3884__________________________________ Telephone Fax

Section 35-11-901 of Wyoming Statutes provides that: *All permit applications must be signed in accordance with 40 CFR Part 122.22; “for” or “by” signatures are not acceptable. Section 35-11-901 of Wyoming Statutes provides that: Any person who knowingly makes any false statement, representation, or certification in any application ... shall upon conviction be fined not more than $10,000 or imprisoned for not more than one year, or both. Mail this application to: WYPDES Permits Section Department of Environmental Quality/WQD 122 West 25th Street, Herschler Building, 4W Cheyenne, WY 82002 Please include unique footer information on each page of this application and on all supporting documentation using the following format: Company Name: Year/Month/Day/NEW, MOD, RENEWAL/8Digit HUC Code/Permit # (if a modification or renewal) or Application # (from this particular company) for that particular day


!PXW!X

!X

Reservoir

T54R67

Fowler 22-8

FowlerFederal 23-8

001

Site MapBallard Petroleum Holdings, LLCFowler Federal 23-8 & Fowler 22-8

ADJ November 16, 2011No warranty is made for data usage purposes other than those intended by Western Land Services. Maps are created as part of a GIS that compiles records, information, and data from various sources. This data experiences frequent updates and accordingly WLS shall not be liable for any errors or omissions herein.

.Projection: UTMUnits: MetersDatum: NAD83Zone: 13Scale: 1:24,000

0 0.1 0.2 0.3 0.4 0.5

Miles

Legend!X Production WellXW Outfall!P Stock Tank

Pipeline RoutePit AreaReservoirStream/River

Little Missouri River

Unna

med T

ributa

ry

!PXW

!X

!XFowler 22-8

FowlerFederal 23-8

001

Ballard Petroleum Holdings LLC: 2011/11/18/NEW/10110201/East Jewel Fowler Discharge of 27

Generalized Schematic Drawing of Production

Treatment Process WellProduction

Free-WaterKnockout Vessel

Heater-TreaterVessel

Siphon &Water

FirstTank

TransferTanks

Pit 1

SecondTank

Inline Filter(s)Final TreatmentRock Rip-Rap

Pit 1

Pit 2 Legend

Lined Treatment

Pits

Drop Structure Sampling

Point

Vertical Riser

Pit 2 g

Rock Rip-Rap

Siphon Skimmer

Not to ScaleStock Tank

Treated Water Flow PathNative Channel

Ballard P

etroleum H

oldings LLC: 2011/11/18/N

EW

/10110201/East Jew

el Fowler D

ischarge of 27

Ballard P

etroleum H

oldings LLC: 2011/11/18/N

EW

/10110201/East Jew

el Fowler D

ischarge of 27

SAFETY DATA SHEET PRODUCT

BREAXIT® EC2087B

EMERGENCY TELEPHONE NUMBER(S) (800) 424-9300 (24 Hours) CHEMTREC

Nalco Company 1601 W. Diehl Road • Naperville, Illinois 60563-1198 • (630)305-1000

For additional copies of an MSDS visit www.nalco.com and request access. 1 / 12

1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME : BREAXIT® EC2087B COMPANY IDENTIFICATION : Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 EMERGENCY TELEPHONE NUMBER(S) : (800) 424-9300 (24 Hours) CHEMTREC NFPA 704M/HMIS RATING HEALTH : 2 / 2* FLAMMABILITY : 2 / 2 INSTABILITY : 0 / 0 OTHER : 0 = Insignificant 1 = Slight 2 = Moderate 3 = High 4 = Extreme * = Chronic Health Hazard 2. COMPOSITION/INFORMATION ON INGREDIENTS Our hazard evaluation has identified the following chemical substance(s) as hazardous. Consult Section 15 for the nature of the hazard(s).

Hazardous Substance(s) CAS NO % (w/w) Heavy Aromatic Naphtha 64742-94-5 10.0 - 30.0 Aliphatic hydrocarbon Proprietary 30.0 - 60.0 Xylene 1330-20-7 1.0 - 5.0 Naphthalene 91-20-3 1.0 - 5.0 Ethylbenzene 100-41-4 5.0 - 10.0 3. HAZARDS IDENTIFICATION

**EMERGENCY OVERVIEW**

WARNING Combustible. Repeated exposure may cause skin dryness or cracking. This product contains naphthalene. The International Agency for Research on Cancer (IARC) has evaluated naphthalene and determined it to be possibly carcinogenic to humans (Group 2B, based on sufficient evidence in experimental animals and inadequate evidence in humans). This product contains ethylbenzene. The International Agency for Research on Cancer (IARC) has evaluated ethylbenzene and determined it to be possibly carcinogenic to humans (Group 2B, based on sufficient evidence in experimental animals and inadequate evidence in humans). Do not get in eyes, on skin, on clothing. Do not take internally. Use with adequate ventilation. Avoid breathing vapor. In case of contact with eyes, rinse immediately with plenty of water and seek medical advice. After contact with skin, wash immediately with plenty of water. Use a mild soap if available. Wear suitable protective clothing and gloves. Combustible Liquid; may form combustible mixtures at or above the flash point. Vapors can travel to a source of ignition and flash back. Empty product containers may contain product residue. Do not pressurize, cut, heat, weld, or expose containers to flame or other sources of ignition. May evolve oxides of carbon (COx) under fire conditions.



BREAXIT® EC2087B




PRIMARY ROUTES OF EXPOSURE : Eye, Skin, Inhalation HUMAN HEALTH HAZARDS - ACUTE : EYE CONTACT : May cause irritation with prolonged contact. SKIN CONTACT : Frequent or prolonged contact with product may defat and dry the skin, leading to discomfort and dermatitis. INGESTION : Not a likely route of exposure. May cause nausea and vomiting. Can cause chemical pneumonia if aspirated into lungs following ingestion. Can cause central nervous system depression. INHALATION : Repeated or prolonged exposure may irritate the respiratory tract. Product mist or vapors may cause headache, nausea, vomiting, drowsiness, stupor or unconsciousness. Can cause central nervous system depression. AGGRAVATION OF EXISTING CONDITIONS : Skin contact may aggravate an existing dermatitis condition. HUMAN HEALTH HAZARDS - CHRONIC : This product contains ethylbenzene. The International Agency for Research on Cancer (IARC) has evaluated ethylbenzene and determined it to be possibly carcinogenic to humans (Group 2B, based on sufficient evidence in experimental animals and inadequate evidence in humans). This product contains naphthalene. The International Agency for Research on Cancer (IARC) has evaluated naphthalene and determined it to be possibly carcinogenic to humans (Group 2B, based on sufficient evidence in experimental animals and inadequate evidence in humans). 4. FIRST AID MEASURES EYE CONTACT : Immediately flush with plenty of water for at least 15 minutes. If symptoms develop, seek medical advice. SKIN CONTACT : Flush with large amounts of water. Use soap if available. If symptoms develop, seek medical advice. INGESTION : Do not induce vomiting: contains petroleum distillates and/or aromatic solvents. If conscious, washout mouth and give water to drink. Get medical attention. INHALATION : Remove to fresh air, treat symptomatically. If symptoms develop, seek medical advice. NOTE TO PHYSICIAN : Based on the individual reactions of the patient, the physician's judgement should be used to control symptoms and clinical condition.



BREAXIT® EC2087B




5. FIRE FIGHTING MEASURES FLASH POINT : 129.0 °F / 54.0 °C EXTINGUISHING MEDIA : Foam, Carbon dioxide, Dry powder, Other extinguishing agent suitable for Class B fires, For large fires, use water spray or fog, thoroughly drenching the burning material. Water mist may be used to cool closed containers. UNSUITABLE EXTINGUISHING MEDIA : Do not use water unless flooding amounts are available. FIRE AND EXPLOSION HAZARD : Combustible Liquid; may form combustible mixtures at or above the flash point. Vapors can travel to a source of ignition and flash back. Empty product containers may contain product residue. Do not pressurize, cut, heat, weld, or expose containers to flame or other sources of ignition. May evolve oxides of carbon (COx) under fire conditions. SPECIAL PROTECTIVE EQUIPMENT FOR FIRE FIGHTING : In case of fire, wear a full face positive-pressure self contained breathing apparatus and protective suit. 6. ACCIDENTAL RELEASE MEASURES PERSONAL PRECAUTIONS : Restrict access to area as appropriate until clean-up operations are complete. Use personal protective equipment recommended in Section 8 (Exposure Controls/Personal Protection). Stop or reduce any leaks if it is safe to do so. Keep people away from and upwind of spill/leak. Ventilate spill area if possible. Remove sources of ignition. Ensure clean-up is conducted by trained personnel only. Do not touch spilled material. Have emergency equipment (for fires, spills, leaks, etc.) readily available. Notify appropriate government, occupational health and safety and environmental authorities. METHODS FOR CLEANING UP : SMALL SPILLS: Soak up spill with absorbent material. Place residues in a suitable, covered, properly labeled container. Wash affected area. LARGE SPILLS: Contain liquid using absorbent material, by digging trenches or by diking. Reclaim into recovery or salvage drums or tank truck for proper disposal. Clean contaminated surfaces with water or aqueous cleaning agents. Contact an approved waste hauler for disposal of contaminated recovered material. Dispose of material in compliance with regulations indicated in Section 13 (Disposal Considerations). ENVIRONMENTAL PRECAUTIONS : Toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment., Prevent material from entering sewers or waterways., If drains, streams, soil or sewers become contaminated, notify local authority. 7. HANDLING AND STORAGE HANDLING : Do not get in eyes, on skin, on clothing. Do not take internally. Use with adequate ventilation. Do not breathe vapors/gases/dust. Keep the containers closed when not in use. Have emergency equipment (for fires, spills, leaks, etc.) readily available. Ensure all containers are labeled. Do not use, store, spill or pour near heat, sparks or open flame.



BREAXIT® EC2087B




STORAGE CONDITIONS : Store in suitable labeled containers. Store the containers tightly closed. Store away from heat and sources of ignition. Have appropriate fire extinguishers available in and near the storage area. Connections must be grounded to avoid electrical charges. Store separately from oxidizers. SUITABLE CONSTRUCTION MATERIAL : Shipping and long term storage compatibility with construction materials can vary; we therefore recommend that compatibility is tested prior to use. 8. EXPOSURE CONTROLS/PERSONAL PROTECTION OCCUPATIONAL EXPOSURE LIMITS : Exposure guidelines have not been established for this product. Available exposure limits for the substance(s) are shown below. Substance(s) Category: ppm mg/m3 Non-Standard

Unit Xylene ACGIH/TWA 100 ACGIH/STEL 150 OSHA Z1/PEL 100 435 Naphthalene ACGIH/TWA 10 ACGIH/STEL 15 ACGIH/Skin* OSHA Z1/PEL 10 50 Ethylbenzene ACGIH/TWA 100 ACGIH/STEL 125 OSHA Z1/PEL 100 435 Oil Mist (Mist) OSHA Z1/PEL 5 Oil Mist (Inhalable fraction.) ACGIH/TWA 5 Heavy Aromatic Naphtha Manufacturer's

Recommendation/TWA 100

* Can be absorbed through the skin. ENGINEERING MEASURES : General ventilation is recommended. Use local exhaust ventilation if necessary to control airborne mist and vapor. RESPIRATORY PROTECTION : Where concentrations in air may exceed the limits given in this section or when significant mists, vapors, aerosols, or dusts are generated, an approved air purifying respirator equipped with suitable filter cartridges is recommended. Consult the respirator / cartridge manufacturer data to verify the suitability of specific devices. In event of emergency or planned entry into unknown concentrations a positive pressure, full-facepiece SCBA should be used. If respiratory protection is required, institute a complete respiratory protection program including selection, fit testing, training, maintenance and inspection.



BREAXIT® EC2087B




HAND PROTECTION : When handling this product, the use of chemical gloves is recommended. The choice of work glove depends on work conditions and what chemicals are handled. Please contact the PPE manufacturer for advice on what type of glove material may be suitable. Gloves should be replaced immediately if signs of degradation are observed. SKIN PROTECTION : Wear standard protective clothing. EYE PROTECTION : Wear safety glasses with side-shields. HYGIENE RECOMMENDATIONS : Use good work and personal hygiene practices to avoid exposure. Keep an eye wash fountain available. Keep a safety shower available. If clothing is contaminated, remove clothing and thoroughly wash the affected area. Launder contaminated clothing before reuse. Always wash thoroughly after handling chemicals. When handling this product never eat, drink or smoke. HUMAN EXPOSURE CHARACTERIZATION : Based on our recommended product application and personal protective equipment, the potential human exposure is: Low 9. PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid APPEARANCE Hazy Amber ODOR Hydrocarbon SPECIFIC GRAVITY 0.96 @ 60.0 °F / 15.6 °C DENSITY 7.9 lb/gal SOLUBILITY IN WATER Dispersible VOC CONTENT 70.8 % Calculated Note: These physical properties are typical values for this product and are subject to change. 10. STABILITY AND REACTIVITY STABILITY : Stable under normal conditions. HAZARDOUS POLYMERIZATION : Hazardous polymerization will not occur. CONDITIONS TO AVOID : Avoid extremes of temperature. Heat and sources of ignition including static discharges.



BREAXIT® EC2087B




MATERIALS TO AVOID : Contact with strong oxidizers (e.g. chlorine, peroxides, chromates, nitric acid, perchlorate, concentrated oxygen, permanganate) may generate heat, fires, explosions and/or toxic vapors. Bases Contact with strong alkalies (e.g. ammonia and its solutions, carbonates, sodium hydroxide (caustic), potassium hydroxide, calcium hydroxide (lime), cyanide, sulfide, hypochlorites, chlorites) may generate heat, splattering or boiling and toxic vapors. HAZARDOUS DECOMPOSITION PRODUCTS : Under fire conditions: Oxides of carbon 11. TOXICOLOGICAL INFORMATION No toxicity studies have been conducted on this product. SENSITIZATION : This product is not expected to be a sensitizer. CARCINOGENICITY : This product contains ethylbenzene. The International Agency for Research on Cancer (IARC) has evaluated ethylbenzene and determined it to be possibly carcinogenic to humans (Group 2B, based on sufficient evidence in experimental animals and inadequate evidence in humans). This product contains naphthalene. The International Agency for Research on Cancer (IARC) has evaluated naphthalene and determined it to be possibly carcinogenic to humans (Group 2B, based on sufficient evidence in experimental animals and inadequate evidence in humans). HUMAN HAZARD CHARACTERIZATION : Based on our hazard characterization, the potential human hazard is: High 12. ECOLOGICAL INFORMATION ECOTOXICOLOGICAL EFFECTS : No toxicity studies have been conducted on this product. MOBILITY : The environmental fate was estimated using a level III fugacity model embedded in the EPI (estimation program interface) Suite TM, provided by the US EPA. The model assumes a steady state condition between the total input and output. The level III model does not require equilibrium between the defined media. The information provided is intended to give the user a general estimate of the environmental fate of this product under the defined conditions of the models. If released into the environment this material is expected to distribute to the air, water and soil/sediment in the approximate respective percentages;

Air Water Soil/Sediment 10 - 30% 30 - 50% 30 - 50%

The portion in water is expected to float on the surface. BIOACCUMULATION POTENTIAL Component substances have a potential to bioaccumulate.



BREAXIT® EC2087B




ENVIRONMENTAL HAZARD AND EXPOSURE CHARACTERIZATION Based on our hazard characterization, the potential environmental hazard is: Moderate Based on our recommended product application and the product's characteristics, the potential environmental exposure is: Low If released into the environment, see CERCLA/SUPERFUND in Section 15. 13. DISPOSAL CONSIDERATIONS If this product becomes a waste, it could meet the criteria of a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261. Before disposal, it should be determined if the waste meets the criteria of a hazardous waste. Hazardous Waste: D001,D018 Hazardous wastes must be transported by a licensed hazardous waste transporter and disposed of or treated in a properly licensed hazardous waste treatment, storage, disposal or recycling facility. Consult local, state, and federal regulations for specific requirements. 14. TRANSPORT INFORMATION The information in this section is for reference only and should not take the place of a shipping paper (bill of lading) specific to an order. Please note that the proper Shipping Name / Hazard Class may vary by packaging, properties, and mode of transportation. Typical Proper Shipping Names for this product are as follows. The presence of an RQ component (Reportable Quantity for U.S. EPA and DOT) in this product causes it to be regulated with an additional description of RQ for road, or as a class 9 for road and air, ONLY when the net weight in the package exceeds the calculated RQ for the product. LAND TRANSPORT :

Proper Shipping Name : FLAMMABLE LIQUID, N.O.S. Technical Name(s) : ETHYLBENZENE, XYLENE UN/ID No : UN 1993 Hazard Class - Primary : 3 Packing Group : III Flash Point : 54.0 °C / 129.0 °F Reportable Quantity (per package) : 3,510 lbs RQ Component : XYLENE

AIR TRANSPORT (ICAO/IATA) : The presence of an RQ component (Reportable Quantity for U.S. EPA and DOT) in this product causes it to be regulated with an additional description of RQ for road, or as a class 9 for road and air, ONLY when the net weight in the package exceeds the calculated RQ for the product.

Proper Shipping Name : FLAMMABLE LIQUID, N.O.S.



BREAXIT® EC2087B




Technical Name(s) : ETHYLBENZENE, XYLENE UN/ID No : UN 1993 Hazard Class - Primary : 3 Packing Group : III Reportable Quantity (per package) : 3,510 lbs RQ Component : XYLENE

MARINE TRANSPORT (IMDG/IMO) :

Proper Shipping Name : FLAMMABLE LIQUID, N.O.S. Technical Name(s) : ETHYLBENZENE, XYLENE UN/ID No : UN 1993 Hazard Class - Primary : 3 Packing Group : III

*Marine Pollutant : AROMATIC HYDROCARBONS

*Note: This product is regulated as a Marine Pollutant when shipped by Rail, Highway (in bulk quantities), or Air (if no other hazard class applies), and when shipped by water in all quantities. 15. REGULATORY INFORMATION This section contains additional information that may have relevance to regulatory compliance. The information in this section is for reference only. It is not exhaustive, and should not be relied upon to take the place of an individualized compliance or hazard assessment. Nalco accepts no liability for the use of this information. NATIONAL REGULATIONS, USA : OSHA HAZARD COMMUNICATION RULE, 29 CFR 1910.1200 : Based on our hazard evaluation, the following substance(s) in this product is/are hazardous and the reason(s) is/are shown below. Heavy Aromatic Naphtha : Combustible., Irritant Aliphatic hydrocarbon : Combustible., Skin irritant Xylene : Flammable, Irritant Naphthalene : Skin irritant, Combustible., Cancer suspect agent (refer to Section 3) Ethylbenzene : Flammable, Irritant, Cancer suspect agent (refer to Section 3) CERCLA/SUPERFUND, 40 CFR 302 : This product contains the following Reportable Quantity (RQ) Substance. Also listed is the RQ for the product. If a reportable quantity of product is released, it requires notification to the NATIONAL RESPONSE CENTER, WASHINGTON, D.C. (1-800-424-8802).

RQ Substance RQ Xylene 3,510 lbs

SARA/SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE III) - SECTIONS 302, 311, 312, AND 313 :



BREAXIT® EC2087B




SECTION 302 - EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355) : This product does not contain substances listed in Appendix A and B as an Extremely Hazardous Substance. SECTIONS 311 AND 312 - MATERIAL SAFETY DATA SHEET REQUIREMENTS (40 CFR 370) : Our hazard evaluation has found this product to be hazardous. The product should be reported under the following indicated EPA hazard categories:

X Immediate (Acute) Health Hazard X Delayed (Chronic) Health Hazard X Fire Hazard - Sudden Release of Pressure Hazard - Reactive Hazard

Under SARA 311 and 312, the EPA has established threshold quantities for the reporting of hazardous chemicals. The current thresholds are: 500 pounds or the threshold planning quantity (TPQ), whichever is lower, for extremely hazardous substances and 10,000 pounds for all other hazardous chemicals. SECTION 313 - LIST OF TOXIC CHEMICALS (40 CFR 372) : This product contains the following substance(s), (with CAS # and % range) which appear(s) on the List of Toxic Chemicals

Hazardous Substance(s) CAS NO % (w/w) Xylene 1330-20-7 1.0 - 5.0 Naphthalene 91-20-3 1.0 - 5.0 Ethylbenzene 100-41-4 5.0 - 10.0

TOXIC SUBSTANCES CONTROL ACT (TSCA) : The substances in this preparation are included on or exempted from the TSCA 8(b) Inventory (40 CFR 710) FEDERAL WATER POLLUTION CONTROL ACT, CLEAN WATER ACT, 40 CFR 401.15 / formerly Sec. 307, 40 CFR 116.4 / formerly Sec. 311 : This product contains the following substances listed in the regulation. Additional components may be unintentionally present at trace levels.

Substance(s) Citations • Naphthalene • Ethylbenzene • Toluene • Benzene

Sec. 307, Sec. 311

• Xylene • Potassium Hydroxide

Sec. 311

CLEAN AIR ACT, Sec. 112 (Hazardous Air Pollutants, as amended by 40 CFR 63), Sec. 602 (40 CFR 82, Class I and II Ozone Depleting Substances) : This product contains the following substances listed in the regulation. Additional components may be unintentionally present at trace levels.



BREAXIT® EC2087B




Substance(s) Citations • Naphthalene • Toluene • Xylene • Benzene • Ethylbenzene • Ethylene Glycol

Sec. 112

CALIFORNIA PROPOSITION 65 : This product contains the following substances which require warning under California Proposition 65. Additional components may be unintentionally present at trace levels.

Substance(s) Concentration EFFECTS • Naphthalene • Ethylbenzene

< 5 % < 10 %

Causes Cancer

• Toluene

< 1 %

Causes Birth Defects, Causes Reproductive Harm

• Benzene

< .1 %

Causes Cancer, Causes Birth Defects, Causes Reproductive Harm

MICHIGAN CRITICAL MATERIALS : This product contains the following substances listed in the regulation. Additional components may be unintentionally present at trace levels.

Xylene Naphthalene

STATE RIGHT TO KNOW LAWS : The following substances are disclosed for compliance with State Right to Know Laws:

Xylene 1330-20-7 Naphthalene 91-20-3 Ethylbenzene 100-41-4

INTERNATIONAL CHEMICAL CONTROL LAWS : 16. OTHER INFORMATION Due to our commitment to Product Stewardship, we have evaluated the human and environmental hazards and exposures of this product. Based on our recommended use of this product, we have characterized the product's general risk. This information should provide assistance for your own risk management practices. We have evaluated our product's risk as follows:



BREAXIT® EC2087B




* The human risk is: Low * The environmental risk is: Low Any use inconsistent with our recommendations may affect the risk characterization. Our sales representative will assist you to determine if your product application is consistent with our recommendations. Together we can implement an appropriate risk management process. This product material safety data sheet provides health and safety information. The product is to be used in applications consistent with our product literature. Individuals handling this product should be informed of the recommended safety precautions and should have access to this information. For any other uses, exposures should be evaluated so that appropriate handling practices and training programs can be established to insure safe workplace operations. Please consult your local sales representative for any further information.

REFERENCES Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, American Conference of Governmental Industrial Hygienists, OH., (Ariel Insight™ CD-ROM Version), Ariel Research Corp., Bethesda, MD. Hazardous Substances Data Bank, National Library of Medicine, Bethesda, Maryland (TOMES CPS™ CD-ROM Version), Micromedex, Inc., Englewood, CO. IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Man, Geneva: World Health Organization, International Agency for Research on Cancer. Integrated Risk Information System, U.S. Environmental Protection Agency, Washington, D.C. (TOMES CPS™ CD-ROM Version), Micromedex, Inc., Englewood, CO. Annual Report on Carcinogens, National Toxicology Program, U.S. Department of Health and Human Services, Public Health Service. Title 29 Code of Federal Regulations, Part 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration (OSHA), (Ariel Insight™ CD-ROM Version), Ariel Research Corp., Bethesda, MD. Registry of Toxic Effects of Chemical Substances, National Institute for Occupational Safety and Health, Cincinnati, OH, (TOMES CPS™ CD-ROM Version), Micromedex, Inc., Englewood, CO. Ariel Insight™ (An integrated guide to industrial chemicals covered under major regulatory and advisory programs), North American Module, Western European Module, Chemical Inventories Module and the Generics Module (Ariel Insight™ CD-ROM Version), Ariel Research Corp., Bethesda, MD. The Teratogen Information System, University of Washington, Seattle, WA (TOMES CPS™ CD-ROM Version), Micromedex, Inc., Englewood, CO.



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Prepared By : Product Safety Department Date issued : 03/03/2011 Version Number : 2.1


ANALYTICAL SUMMARY REPORTANALYTICAL SUMMARY REPORTANALYTICAL SUMMARY REPORTANALYTICAL SUMMARY REPORT

This is a partial report. All requested analyses are not complete at this time. The analyses that are reported are considered final and not subject to change.

The analyses presented in this report were performed by Energy Laboratories, Inc., 400 W. Boxelder Rd., Gillette,

WY 82718, unless otherwise noted.

As appropriate, any exceptions or problems with the analyses are noted in the Laboratory Analytical Report, the

QA/QC Summary Report, or the Case Narrative.

The results as reported relate only to the item(s) submitted for testing.

If you have any questions regarding these tests results, please call.

Sample ID Client Sample ID Collect Date Receive Dat Matrix Test

Report Approved By:

G11100774-001 Fowler 23-8 10/27/11 12:00 10/27/11 Aqueous Metals by ICP/ICPMS, Dissolved

Metals, Total Recoverable

Conductivity, fieldMercury, Dissolved

Oil & Grease, Gravimetric, Sulfur Corrected

Hydrocarbons, Total Petroleum, Sulfur Corrected

Hardness

Anions by Ion ChromatographypH, field

Metals Digestion by EPA 200.2Digestion, Mercury by CVAA

Radium 226, TotalRadium 226 + Radium 228

Radium 228, Total

Sodium Absorption RatioSolids, Total Dissolved

Sulfide, Iodine TitrimetricTemperature °C, field

G11100774-002 Fowler 22-8 10/27/11 13:00 10/27/11 Aqueous Same As Above

Ballard Petroleum

Project Name: Fowler

Workorder No.: G11100774

PO Box 608

Gillette, WY 82717-0608

November 10, 2011

Energy Laboratories Inc. Gillette WY received the following 2 samples for Ballard Petroleum on 10/27/11 for analysis.

Page 1 of 3Ballard Petroleum Holdings LLC: 2011/11/18/NEW/10110201/East Jewel Fowler Discharge of 27

Analyses Result Units Analysis Date / ByMethod

LABORATORY ANALYTICAL REPORT

Client Sample ID Fowler 22-8 Collection Date: 10/27/11 13:00

Matrix: Aqueous

Client: Ballard Petroleum

Lab ID: G11100774-002

Report Date: 11/10/11

Date Received: 10/27/11Location:

Sampled By: Allen Jones

Qualifier

Samp FRQ/Type

Project: Fowler

RL

Prepared by Gillette, WY Branch

FIELD PARAMETERS

10/27/11 13:00 / ***umhos/cm3210Conductivity, field FIELD

10/27/11 13:00 / ***s.u.6.70pH, field FIELD

10/27/11 13:00 / ***°C29.8Temperature °C, field FIELD

*** Performed by Sampler

MAJOR IONS, DISSOLVED

D 10/31/11 13:22 / japmg/L19Chloride E300.04

D 10/31/11 13:22 / japug/L2340Fluoride E300.0400

D 10/31/11 13:22 / japmg/L2100Sulfate E300.04

10/31/11 19:42 / eli-bmg/L611Calcium E200.81

10/31/11 16:18 / eli-bmg/L161Magnesium E200.71

10/31/11 16:18 / eli-bmg/L28Sodium E200.71

METALS, DISSOLVED

10/31/11 19:42 / eli-bug/LNDAluminum E200.850

10/31/11 16:18 / eli-bug/LNDBoron E200.7100

10/31/11 19:42 / eli-bug/LNDCadmium E200.80.1

10/31/11 19:42 / eli-bug/LNDChromium E200.81

11/01/11 12:48 / eli-bug/LNDCopper E200.81

10/31/11 19:42 / eli-bug/L113Iron E200.830

10/31/11 19:42 / eli-bug/LNDLead E200.82

10/31/11 19:42 / eli-bug/L57Manganese E200.810

11/08/11 12:09 / eli-bug/LNDMercury E245.10.06

10/31/11 19:42 / eli-bug/LNDMolybdenum E200.85

10/31/11 16:18 / eli-bug/LNDNickel E200.710

D 10/31/11 16:18 / eli-bug/LNDSilver E200.720

11/01/11 12:48 / eli-bug/L19Zinc E200.810

METALS, TOTAL RECOVERABLE

11/01/11 03:16 / eli-bug/LNDArsenic E200.80.5

11/01/11 03:16 / eli-bug/LNDBarium E200.8100

11/01/11 03:16 / eli-bug/LNDSelenium E200.85

NON-METALS

11/09/11 16:46 / cafmg/L2200Hardness as CaCO3 A2340 B

11/09/11 16:46 / cafunitless0.3Sodium Adsorption Ratio (SAR) Calculation

D 11/02/11 14:50 / hmhmg/L3370Solids, Total Dissolved TDS @ 180 C A2540 C20

10/31/11 13:22 / mavmg/L6Oil & Grease (HEM), Sulfur Corrected E1664A5

10/31/11 14:46 / mavmg/LNDTotal Petroleum Hydrocarbons, S Corrected E1664A5

10/31/11 14:15 / eli-bmg/L76Sulfide A4500-S F1

10/31/11 14:15 / eli-bmg/L81Sulfide as Hydrogen Sulfide (H2S) A4500-S F1

Report

Definitions:

RL - Analyte reporting limit. MCL - Maximum contaminant level.

QCL - Quality control limit. ND - Not detected at the reporting limit.

D - RL increased due to sample matrix.

Page 3 of 3Ballard Petroleum Holdings LLC: 2011/11/18/NEW/10110201/East Jewel Fowler Discharge of 27

allen.jones

Text Box

SENW Section 8, T54N, R67W

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