826 21 ½ Road | Grand Junction, CO 81505 | TEL 970.263.7800 | FAX 970.263.7456

Spill Prevention, Control and Countermeasure Plan

Encana Oil & Gas (USA) Inc.

C19 Injection Well

OA Project No. 012-0178

SP\C Phlll - N('l'Ih Paradwll' Profll.'l'Iil's (:">IPI'IEnrana Oil & G;I ~ I l lS") jill' .

SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN

NORTH PARACHUTE PROPERTIES

Garfield County, Colorado

Prepared by:

EnvlroGroup limited Centennial, Colorado

Prepared lor:

Encana Oil & Gas (USA) Inc. Parachute, Colorado

September 13, 2010

Project No. EC · 0673

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C'I =P-auCC'CCA:-,-eCCII ,-:pO-.:O-E ----- --::O--c-ate Prepared By

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. / . ,,~ -;--~--C:::'---:~~--------;=c- ' "P _ .., " Jarnes 8. Cowart . P.E. Date

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Certified By

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spec Plan - North Parachute Properties (NPP)Encana Oil & Gas (USA) Inc.

1.0 GENERAL INFORMATION

1.1 INTRODUCTION

September 13,2010

Encana Oil & Gas (USA) Inc.'s (Encana's) North Parachute Ranch (NPR) and North Parachute

Mountain (NPM) properties, collectively known as the North Parachute Properties (NPP), are a

collection of natural gas production facilities having oil production (more specifically,

condensate) as a by-product.

The Oil Pollution Prevention Regulations (40 CFR 11 2) require preparation of a Spi ll Prevention

Control and Countermeasure Plan (SPCC) for facilities that have discharged or could reasonably

be expected to discharge oil into or on navigable waters of the United States or adjoining

shorelines. A spec plan is required to be prepared if greater than 42,000 gallons of oil are

stored in buried tanks or greater than 1,320 gallons of oil is stored in aboveground tanks.

Because each of the facilities comprising the NPP exceeds the above ground storage amounts, a

spee plan is required to be prepared and implemented. The purpose ofa spec Plan (Plan) is to

describe engineering and administrative controls employed atlby a facility to comply with

requirements set forth under 40 eFR 112 to prevent the discharge of oi l to navigable waters.

This document has been prepared in accordance with those regulations as amended by EPA's

November 13, 2009 final regulatory action. A table cross referencing all of the requirements of

those regulations is included in Section 1.2 of the Plan. The compliance date (Compliance Date)

for these requirements at the time of printing of this Plan is November 10, 2010.

EnviroGroup Limited Project No. EC·0673

SPCC Plan - North Parachute Properties (NPP)Eneana Oil & Gas (USA) Inc.

September 13 ,201 0

1. 2 CROSS REFERENCE MATRIX

(40 CFR 11 2.7)

The fo ll owing tab le is a cross reference between relevant portions of 40 CFR Part 112 and this

Plan.

Table I - Regulatory Cross Reference Matrix for Encana's North Parachute Properties spec Plan

40 CFR Pal'! Requirement SPCC Plan Section

112.3 (e) Portable fue liM facilities 2.10 112.:lidl Professional engineer certification 2.0 11 2.3 le\ Maintain a copy of plan at faci lity (locat ion of plan) 1.5 112.3 (g) I Ouali fied faci lity self certification criteria NA 112A Reoort certain discharges to EPA Aooendix C 11 2.5 (a) Amend plan when there arc significant changes made to the 3.8

faci lity 112.5 (b) Reyiew Dian at least everv five years and amend ifaoorooriale 3.8 11 2.6(a) Self cert ification of a Tier 1 qualified faci lity NA 112 .6(b) Self certification of a Tier 2 auali fied facilitv NA 112.7 ManMement annroval of DIan IA 112 .7 Provide a cross reference matrix to regulations 1.2 112 .7 Discuss needed facilities, equipment, or procedures not yet 3. 11

ooerational in senarate oara£!:raohs 112.7(a)(I) Discussion of faci litv's eonfonnance with the regulations 3.1 1 11 2.7 (a)(2) Equivalent environmental protection is allowed for deviations NA

from portions of regulations. Reasons for non confonnance must be stated.

112.7 (a)(3) Describe the physica l layout of the faci lity. Provide a faci lity 2.0 diagram includ ing tanks, underground tanks, storage areas for Appendices mobi le containers, produced water containcrs, assoc iated piping, transfer stations, connecting pipes and intra-faci lity

I gathering lines. 112.7 (a)(3)(i) Plan must include type of oi l in each container and capacity of 2.0

each con tainer 11 2.7 (a)(3)(ii) Discharge prevention measures including procedures for oi l

hand li ng at load ing/unloading areas 3.3

112.7 (a)(3)(iii) Drainage control around containers and other equipment 2.0 112.7 (a)(3)(iv) Countenneasures for discharge discovery, response and Appendix C

cleanup. 112.7 a)(3)(v) Methods of disposal of recovered materials Appendix C 11 2.7 a)(3)(v i) Contact list including phone numbers Appendix C

EnvlroGroup LImIted ProJcct No. EC-0673 2

spec I'lan - North l)arachutc Properties (NPP)Encana Oi l & Gas (USA) Inc.

September 13. 2010

40 O'R Part Requirement spec Plan Section

112.3(e) Portable fucling facilities 2. 10 112.7 (a)(4) Discharge reporting procedures, information to bc included Appendix C 11 2.7 (a)(5) Or~an ize plan to make it useful in an emergency Appendix C I 12.7 (b) Provide an equipment fa ilure analysis including sources, 2.0

quantity, direction, and rate of flow 11 2.7 (e) General secondary containment requirement (typical failure 2.0

mode and most likely quantity) for areas from which a di scharge could occur by at least one of eight speci fied measures

I 12.7 (d) If necessary provide an explanation of impracti cab ility of 2.0 secondary containment, conduct periodic integri ty testing of containers and periodic in tegrity and leak testing of va lves and DiDi,,"

112.7 (d)( I) For impracticabi lity. prov ide an oi l spill contingency plan per Appendix C pari 109

11 2.7 (d)(2) For impracticability, provide writt en commitment ofmunpower, Appendix C equjpment, and materi als

112.7 (e) Written procedures for inspecti ons and tests 3. 1 112.7(c) Records of inspections must be signed and kept with plan for 3. 1

three years 112.7 (1)( 1) Train oil handling personnel 3.2 112.7 (1)(2) Designate an indi vidual accountable for discharge prevention 2.0 112.7 (1)(3) Conduct an annual discharge prevention briefing 3.2 11 2.7(g) Security NA 11 2.7 (h)(l) Prov ide sized secondary containment (largest compartment on NA

tanker) for loading/un load ing racks 11 2.7 (h (2) Provide systems to prevent truck departure before NA

d isconnection 11 2.7 (h)(3) Inspect truck prior to filling and departure NA 112.7 (i) Eva luate field constructed containers for bri ttle fracture failure 3. 1

when containers arc altered or repaired 11 2.7 OJ Compliance with Stale requ irements 3.9 11 2.7(k) Qualilied oi l ~fi ll ed operationa l equipmenl- alternati vc to 2.0

~ genera l secondary conta inment requirements 11 2.7 (k)(2)(i) Ifno secondary containment ~r repare inspection proccdures or 2.0

monitoring program 11 2.7 (k)(2)(ii) Ifno secondary contai nment - Provide an oi l spill cont ingency 2.0

I plan pcr pari 109 112.7 (k)(2)( ii) (f no secondary eon tainmcnt provide written comm it ment of 2.0

resources 112.8 Requ irements for facilities other than production facil ities NA I 12.9 (b)( I) O il producti on facilit y drains o f d ikes must be kept closed. 2.0 EnVlroGroup L1nl ltcd I' roJ(.."(: I No. ['C~067 3 3

spec Plan - North Paraehule Properties (NPP)Eneana Oil & Gas (USA) Ine

September 13. 2010

40 C FR Part Requirement SPCC Plan Section

11 2.3 (e) Portab le fue ling faci li ties 2.10 Inspect diked areas before draining watcr and remove accumulated oiL

11 2.9 (b )(2) Inspect field drainage systems, oil traps, sumps or skimmers for 3. 1 oiL Remove accum ulated oi l

I 12.9 (e)( I ) Material and construct ion of containers must be compatible 2.0 with stored material and conditions of storage

11 2.9 (e)(2) Provide sized secondary containment (capacity of largest 2.0 container plus precipitation) fo r tan k battery, separation, and treating faci lit y installations

112.9 (e)(2) Confine drainage from undiked areas to catchment basin or 2.0 holding pond

112.9 (e)(3) Visuall y inspect containers, foundations, and supports 3. 1 periodicall y and on a regula r schedule

11 2.9 (e)(4 Engineer tank batteries to prevent di scharges with one of the 2.0 fo ll owing features:

112.9 (e)(4)( i) Provide adequate tank capacity to prevent overfi ll ing, or 2.0 112.9 (e)(4(ii)) Provide overflow equa lizing lines between containers, or 2.0 112.9 (e)(4(i ii)) Provide vacuum protection to prevent collapse, or 2.0 112.9 (c)(4)(iv) Provide high level sensors 2.0 11 2.9 (e)(5) Alternative to sized secondary containment for some flow 2.0

through process vessels 112.9(c)(5)(i) Periodicall y and regu larly inspect and/or test flow through 3. 1

process vessels and associated components 112.9(c)(5)(i i) Take corrective act ion as indicated by inspections or tests or 2.0

evidence of oi l 112.9(c)(5)(iii) Remove or stabi li ze and rcmediate any accumulation of oi l 2.0 11 2.9 (c)6 Alternative to sized secondary containment for some produced NA

water containers 11 2.9 (c)6(i) Implement a procedure to rcmove free~phasc surface oiL NA

Include written procedures, frequency, amount of oil expected insidc container, and a PE certification. Maintain records of these activitics .

112.9 (c)6(ii) On a regular schedule visua ll y inspec t and/or test produced NA water containers and associated piping

11 2.9 (c)6(iii) Take corrective action as indicated by inspections or tests or NA accumulat ion of oi l

11 2.9 (c)6(iv) Promptly rcmove or stabilize and remediatc accumulation of oil NA 112.9(d)( I) Peri odically and regularly inspect aboveground valves, piping, 3.1

drip pans, supports, and pumps associated with transfer operations

11 2.9 (d)(2) Inspect sa il water disposal faci lities NA EnvlToGroup Ln1l1led Project No. EC-0673 4

spec Plan - North Parachute Properties (N PP)Encana Oil & Gas (USA) Inc.

40 C FR Part Requirement

112.3 (e) Portable fueling facilities 112.9 (d)(3) For nowlines and intm·faeility gathering lines without

secondary containment provide: 112.9 (d)(3)(i) Oil spi ll contingency per Part 109 and 112.9 (d)(3)(ii ) Written commitment of resources 11 2.9(d)(4) Prepare and implement a flowline maintenance program

including: 11 2.9(d)(4)(i) Ensure materials arc compatible with fluids 11 2.9(d)(4)(i i) Visuall y inspect or tcst fl owlines and intra-facility gathering

lines on a regular and pcriodic schedule. For lines not having

September 13, 20 I 0

spec IJlan Section 2.10 2.0

App.C App.C 3.6

3.6 3.6

secondary containment the frequency and type of testing must allow for prompt implementation of the contingency plan.

112.9(d)(4)(ii i) Take correcti ve action as a result of inspections, tests, or 3.6 evidence of a di scharge

112.9(d)(4)(iv) Promptly remove or stabi li ze and remediatc oil di scharges 3.6 11 2. 10 Req uirements for onshore oil drilling and workover fac ilities 3. 10 112.11 Requirements for offshore oil drilling and workover facilities NA 11 2. 12 Requirements for stora 'e of an imal, fi sh, and vegetable oils NA 11 2.20 (e) Certi !ication of the applicability of substantial harm criteria \. 7 112.20(1)(1 )

EnviroGrOllp Limi1ed rroj~ 1 No. EC-0673 5

spec Plan - North Parachute Properties (NPP)Eneana Oil & Gas (USA) Inc.

1.3 LOCATION AND DEFINITION OF PLAN AREA

September 13,2010

This plan covers the Eneana North Parachute Propert ies (NPP) natural gas production operations.

Condensate is also produced and thus makes these facilities subj eclto 40 CFR 11 2 and

spcci fi ca ll y, 40 e FR 11 2.9, onshore oil production fac ili ties. The plan covers severa l facilities as

described in Section 2.0. The NPP is located northwest o f Parachute, CO and its geographic

ex tent is shown on Figurc I.

Thi s propert y is owned by Encana Oil and Gas (USA), Inc. located at 27 17 County Road 2 15,

Suite 100, Parachute, CO 81635. Equipmcnt located atlhese fac ilities includes wcl lheads,

separation eq ui pment, bulk storage containers, produced water contai ners, nowlines and

gathering li nes, and produced water d istribut ion pipelines and pits.

1.4 MANAGEMENT APPROVAL

(40 CFR 11 2.7)

Encana Oil and Gas (USA). Inc. is committed to the prevention o f discharges of oi l to navigable

waters and the envi ronment through the implementation of spill prevention measures. Th is

SPCC plan is one pa rt of that effort. The designated responsible person fo r spill prevention and

cleanup at eaeh faci lity is directl y responsible for implement ing the plan and communicating the

plan to appropriate Encana personnel. The des ignated spill prevelltion individual is responsible

to Encana management.

I approve th is plan and the commitment of resourccs to implement Ihi s plan [§ 11 2.7]. Thi s

resource commitment includes the manpower, equi pment and materials req uired to expeditiously

contro l and rcmove a quanti ty of oil di scharged that may be haml rul [40 eFR 11 2.7 (d)).

Signature: Dale: 11-;<- ;<0/0

Printed Name: -'ilAl-"'~"-''----'==~-- Tille -tJltt'2t;--/()1/If ,r:dtJ l-etJdev-

EnviroGroup Limilcd I'rojcci No. EC-0673 6

spec Plan - North I)arachute Properties (NPP)Encana Oil & Gas (USA) Inc.

1.5 LOCATION OF PLAN

(40 CFR 11 2.3 (e»

Scptcmber 13, 2010

A copy of this plan is located at the guard station at the entrance to the NPP at 10,652 County

Road 21 5, Parachute, CO 8 1635, 970-285-9496. Thi s plan is ava il able for EPA review during

normal working hours at that location .

1.6 CERTIFICATION OF THE APPLICABILITY OF THE SUBSTANTIAL HARM

CRITERIA

(40 CFR 11 2.20 (e), 40 CFR 112.20(1)( I»

A fac ility that could, because o f its location, be expected to cause substanti al hann to the

envi ronment by discharging o il into or on the navigable watcrs or adjoining shorelines is

required to prepare and submit to the EPA Regiona l admin istrator a facility response plan in

accordance wi th 40 CFR 112.20. The fonns certifying the applicabi lity of the substantial ha nn

criteria for each facil ity covered by this Plan arc included in Appendix B. As can be seen from

the completed fomls the Middle Fork Water Treatment Facil it y meets the cri teria for substant ia l

haml and thus a Faci lity Response Plan is required for th is facilit y.

1.7 COMPANY CONTACT INFORMATION

(40 CFR11 2.7 (a)(3)(v;), 11 2.7 (1)(2))

Opera ting personnel must immediately report all spills and conditions which could lead to a spill

to Encana's 24-Hour Environmental on-call number. Encana 's Environmental Compliance

Group will detenn ine the appropriate level of response, not ify the fac ility's Dischargc Prevention

Manager and Faci lity Manager, and if necessary, contact appropriate government agencies and

assist in mobili zing resources.

Environmental On-Call (24 hours) 970.319.9 173

Salcly On-Call (24 hours) 970.2 10.8755

Gas Conlrol (24 hours) 970.285 .2615

EllviroCiroup Limited ProjC(:t No. EC-0673 7

spec Plan - North Parachute Properties (N PP)Eneana Oil & Gas (USA) Inc.

Scplcmbcr 13, 2010

2 .4 F26 WELL PAD FACILITY

2 .4.1 Physical Layout, Operations, and Facility Definition

(40 CFR 12.7(a)(3))

This fac ility is a stand-a lone well pad on North Parachute Mountain (NPM). The fac ility

includes bulk storage containers and equipment on location . Water haulers and oil sales

transports omoad from the tank battery. One gas gathering line leaves the location . There may

be at least one water line coming into the location. Status of the water line is unknown, but

would be considered a part of the Middle Fork Water Treatment Faci lity ifused to transfer

produced water.

The faci lity d iagram for this fac il ity is prov ided in Appcndix A.

2.4 .2 Bulk Storage Container Data

(40 CFR 11 2.7(a)(3)(i), 112.7(d), 11 2.9(c)( I), 112.9(c)(2), 11 2.9(c)(4)(i), 11 2.9(c)(4)(i i),

112.9(c)(4)(iii ), 11 2.9(c)(4)(iv), 11 2.9(c)(6))

There arc three steel condensate tanks al this faci lit y. They each have a capac ity of500 barrels

and arc located within sized secondary containment consisting of a 29" lined metal conta inment

ring. The steel storage ta nks arc compat ible with the oil slored. Ovcrfill protecti on is provided

by a high level alarm, automatic shut down, and ca llout to the pumper.

2.4.3 General Secondary Containment and Drainage Control

(40CFR 1 12.7(c) , 112.7(d),40CFR 11 2.7(a)(3)( ii i), 112.9(b)( I), 11 2.9(c)(2»

Genera l secondary containmcnt is required, at a minimum, to contain the mosllikel y quantity of

oi l discharged by the typica l failure mode from operations at the faci lity. Operations and

equi pment whieh ha ve the potential to discharge include, storing or handling oil at bulk storage

containers, tank batteri es, treatment, and separati on install ations, portable containers, oil filled

operati onal equipment , truck loading/unloading areas, and piping. The mos t likely spill from th is

fac ility is a hose fai lure while loading a tanker truck estimated to be 50 ga llons. Bcnns, dikes,

a nd retention basins prov ide genera l secondary containment for this facili ty.

EnviroGroup Li mited Project No. EC-0673 36

spec Pl an - North Parac hutc Propcrtics (NPP)Encana Oil & Gas (USA) Inc.

Scplcmbcr 13 , 2010

Encana's poli cy is to remove an y accumulation ofprccipitation from sized secondary

containments. Upon discovery of thi s accumulation , Encana personnel will call for a water

hauler to remove accumulated prccipitation and om oad it at the Middle Fork Watcr Treatment

Facilit y, or other approved facility. Installation of drains within sized secondary containment or

slonn walcr structures is not nonnal practice. In the event that a drain is present, it wi ll remain

closed under nonnal operations.

All Encana locations have perimeter control BM Ps Ihal restri ct the fl ow of water onto the pad

from the surrounding environment, and eliminate the di scharge of sediment and other pollutants.

8MP structures ineluding berms, dikes, and sediment basins are constantl y monitored and

maintained by Encana 's Surface Management Team. If a d ischarge of accumulated precipitation

on a location is required, Envi ronmental personnel visually inspect and conduct watcr quality

analys is before approving the di scharge. In the event that an accumulation of oil or other water

quality concerns arc identified in accumulated precipitati on, liquids are removed using vacuum

trucks, and are om oaded into the Water Treatment Fac ility for treatment and disposa l. All

authorized di scharges from a location are documented in accordance with applicable regulations

and kept on file under lIsual and customary business practice.

2.4.4 Piping

(l1 2.7(c), 11 2.7(d), 11 2.9(d)(3))

There is pip ing at thi s well pad from the well head to the separators and from the separators to

the three tanks. General secondary containment is provided by the perimeter beml .

2.4.5 Flow Through Process Vessels

(40 CFR 11 2.9(c)(2), 11 2.9(c)(5 ))

There are two separators located at thi s facility. Each has a capac ity of fi ve barrels and they are

located with in secondary containment consisting of a 1.5' metal berm. It is Encana's policy to

immediately report all di scharges of oil to the Environmental On-Call phone. Any

accumulations of o il resulting from a discharge are promptly stabili zed and remcdiatcd. General

secondary containment is provided by perimeter con trols and other best management practices.

ErwiroGroup Umi1cd ['rojCC1 No. EC-0673 37

SPCC Plan - North Parachute Propcrties (NPP)Encana Oil & Gas (USA) Inc.

2.4.6 Loading/Unloading Areas and Racks

(40 CFR 11 2.7(c), 112.7(d), 112.7(h)(I),1 12.7(h)(2), 112.7(h)(3»

September 13, 2010

There are no loading racks at this facility. Thcre arc loading areas located adjacent to each of the

condensate tanks for loading tanker trucks with condensate and produced waler. General

secondary containment is provided by the perimeter benn.

2.4 .7 Oil Filled Operational Equipment

(40 CFR 11 2.7(k), 112.7(k)(i), 112.7(k)(ii), 11 2.7(k)(iii))

There is no oi l filled operational equipment located at this facilit y.

2.4.8 Analysis of Equipment Failure

(40 CFR 11 2. 7(b»

Ta ble 12 - Analysis of Equipment Failure - Well Pad F26

Potential Failure Spill Di rection Potential Volume Potential Spill Rate

Released (ga llons) (gallons/minute)

Catastrophic failure of west 21 ,000 4,000

full tank

west Partial failure of tank 5,000 500

west Tank overfill 500 200

west Pipe fitting failure 300 20

west Leaking litt ing or 100 10

valve

EnviroGroup Limited I' roject No. EC-0673 38

• ,

•

s pec Piau - North P:1rac hulc Pruperlics (NPP)Enc:11l3 Oi l & Gas (USA) Inc .

2.4.10 Professional Engineer Certification

(40 e FR 112.3 (dJ)

Scptelll r.r.:l' 1;. 1010

J hereby certify thai I am ramil inr \vith the pro\'isions 01'40 CFR 112 . I han:, examined the

information provided by EnCana Oi l <Jl1d Gas (USA) 111(' " and I ha\\: vis ited and examined the

F2() Well Pad facility in person. I attest that thi s Spil l Preve ntion (\)Jltrol and COllntenneaSllfl'S

PI<ln has been prepared in accordam:e wi lh good enginecring practice. including CLlnsi de r<lt ion o f

applicable ind ustry standards, and with the requirement s or 40 eFR 112. thai procedures 1'01'

required inspections and testing haw been established. and Illatthe plan is adequate lor the

facility r40 CFR 112.3(d)]. TIlis cenilic<llion is provided ror and on bchalrorFm'iroGroup

Limited. This cerlilic:1lion constitutes an expression or pwfessio nal opinion and does not

constitute a warranty or guarantee. e ither ..-:xrresscd or impli..::d.

9/1 J/20 1 0

Signa ture o r Registered Pro resslOna l Engineer Dall'

James B. Cowart 5!31!20 11

Prin ted Name of Registe red Engim'cr Registration Expiration f);l! e

SEA L

In~II"( il'<llIp L im iled I'I'<>.I<:!; I ,,\' ,, L( -()h73 4U

I Secondary Containment Capacity Calculation (Rectangular) I Facility Name:IF26 (NPM) Injection Facility (ESTIMATED)

25-year 24-hour precipitation event 2.20 inches

Tank Information

largest Tank (bbl) Tank Deduction (T1) Tank Diameter (ft) (bbl)

soo

Tank 112 (bbl ) (T2)

SOO

Tank #3 (bbl ) (T3)

SOO

Tank 114 (bbt) (T4) SOO

Tank #5 (Obi) (TS)·

500

13.5 0.0

Tank #2 Diameter Tank #2 Deduction (ft) (bbl)

t 3.5 76.5

Tank #3 Diameter Tank #3 Deduction (ft) (bbl)

13.5 76,5

Tank 114 Diameter Tank 114 Deduction (ft)' (bbl) 13.5 76.5

Tank 115 Diameter Tank #5 Deduction (ft) (bOI}

13.5 76.5

Tank #6 (bbl) Tank #6 Diameter Tank #6 Deduction /T6)· /ft' /bbl}

soo 13.5 76.5

Tank #7 (bbl) Tank #7 Diameter Tank #7 Deduction (T7) (ft) (bbl)

0.0

Tank #8 (bbl) Tank #8 Diameter Tank #8 Deduction ITa,· IItI /bbl

0.0

Tank #9 (bbl) Tank #9 Diameter Tank #9 Deduction (10 #1) /ft) (bbl)

Tank #10 (bbl) (10 #1 i Tank Diameter tftl

0.0

Tank #10 Deduction {bbll

0.0

Total Tank Deduction (bbl)

382.41

Is Secondary Containment Adequate for the Largest Vessel =

Containment Dimensions

length1 (ft) 72

Width 1 (ft)

36

Containment Height (ftl 3

Effective Containment Height (ft)

0-. 2!>-y< 24 .... SIotm)

2.82

Containment Capacity

Gross Containment Caoacitv Ibbll

1300.3

Net Containment Capacity /bbl}

Yes

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