February 17, George Sheffer Southwestern Energy Company 1000 Southwestern Energy Drive P.O. Box 789 Conway, AR 72033

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1 February 17, 2012 George Sheffer Southwestern Energy Company 1000 Southwestern Energy Drive P.O. Box 789 Conway, AR RE: Complaint Investigation of Thomas Holland Family Trust 10-9, #1, 2-22H27 production pad & lease road (Cleburne Co); excessive turbidity observed in the Little Red River Mr. Sheffer: On January 24, 2012 I performed an investigation of the Thomas Holland Family Trust 10-9, #1, 2-22H27 drilling pad & associated lease road (Cleburne Co.; General Permit# WG-P; ADEQ Reference# W-RB) in response to a complaint in regards to turbid water being observed in a tributary that flows by the drilling pad & lease road into the Little Red River. At the time of the investigation, you are not in violation of the Arkansas Water and Air Pollution Control Act and the regulations promulgated thereunder. Please refer to the comments section of the complaint form for notes regarding any areas of concern that may have been observed at the above referenced site. Furthermore, I have contacted Zac Watson by phone & in regards to any potential issues concerning this site. If you should have any questions, feel free to contact me at or via mccabe@adeq.state.ar.us Thank you for your time, Kerri McCabe Oil & Gas Field Inspector Water Division cc: Water Division Permits Branch Water Division Enforcement Branch Zac Watson, SWN EH&S Coordinator, Zachary_Watson@SWN.com

2 FOR OFFICE USE ONLY: AIR HW RST SW WATER MINING ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 Northshore Drive, North Little Rock, AR COMPLAINT REPORT GPS: Lat: ; Long: DATE RECEIVED: January 23, 2012 AFIN#: W-RB COUNTY: Cleburne Co. PERMIT#: WG-P; COMPLAINANT NAME: Frank Barton ADDRESS: N/A COMPLAINT AGAINST: Southwestern Energy (SWN) ADDRESS: 1000 Southwestern Energy Drive P.O. Box 789 Conway, Arkansas PHONE: FAX: N/A PHONE: (Zac Watson) FAX: N/A PERSON RECEIVING REPORT: Eric Fleming Jan. 23, 2012 SUPERVISOR REFERRAL: INSPECTOR REFERRED: Kerri McCabe & David Young Jan. 23, 2012 MEDIA SUPERVISOR REFERRAL: PHONE REFERRAL CONTACT: RECEIVING INSPECTOR: Kerri McCabe DESCRIPTION (IN DETAIL) Mr. Barton contacted ADEQ Water Division by phone with concerns about the turbidity & sedimentation coming from the Thomas Holland Family Trust 10-9, #1, 2-22H27 drilling site entering the Little Red River. Also, he had concerns about the noise coming from the location. LOCATION (IN DETAIL) From Little Rock, take Hwy 67/167 toward Cabot, AR. At the second Cabot exit, take Hwy 5 toward Heber Springs, AR. Hwy 5 merges with Hwy 25 and continues towards Heber Springs, AR. At the Hwy 5/110 junction, turn right onto Hwy 110 (Wilburn Rd) toward Wilburn. The lease road for Thomas Holland Family Trust 10-9, #1, 2-22H27 is on the left before Hays Rd. PREVIOUS COMPLAINT? YES NO DATES: Dec. 12, 2011 (Little Red River Action Team local Trout Unlimited group concerned with turbidity coming from site DISCHARGE TO WATERS OF THE STATE? YES NO NAME OF WATERBODY: HOW COMPLAINT WAS RECEIVED: PHONE LETTER VERBAL FAX FOLLOW- UP ON COMPLAINT Page 2

3 COMPLAINT #: WG-P_comp_ PDS # AFIN #: INSPECTOR: Kerri McCabe Jan. 24, 2011 ACTION TAKEN: PHOTOS TAKEN: YES I spoke with Mr. Barton on the phone about his regards, and I informed him I had received a similar complaint in Dec My results from Dec 2011 confirmed that there are numerous industries within close proximity to the tributary that could potentially lead to turbidity issues. Also, Mr. Barton was concerned about the noise coming from the location during hydro-fracturing of the two wells. I told him I would re-investigate the drilling pad & lease road. When I arrived, the fracking company had just finished & remediation of the drilling pad was underway. I walked the perimeter of the drilling pad and noted that the landowner has a private road that runs between the drilling pad & a slough. The slough was considerably turbid. There are numerous ephemeral drainages leading into the slough from the road; however, the drilling pad was built within an extensive earthen berm & vegetation is establishing. I noted no turbidity or sedimentation leading from the drilling site into the slough. The lease road crosses the unnamed tributary in question & another unnamed tributary that meets the tributary in question. Flow from both tributaries was intermittent. One of the privately-owned ponds had been emptied during the fracking of the two wells. I continued towards Hays Rd where the tributaries are upstream. I noted that the slough has a spillway that flows under Hays Rd, and that three intermittent tributaries flow into drains located on the sloughside of Hays Rd. The adjacent property is the E&W Wildlife Refuge, and the property owner raises cattle & hogs for food production. The cattle are freely allowed to utilize the tributaries. I noted turbid water flowing from the E&W Wildlife Refuge drains. The property owner has clear-cut sections of the property for cattle/hog production as well as lease land to BHP Billiton for production pads (production pads located off Hwy 110). I spoke with Mr. Barton & informed him of my findings. I told him the noise issues should be over due to them finishing the fracking of the wells. Also, I informed him that cattle were freely allowed to roam the property as well as the adjacent property (E&W Wildlife Refuge), and this roaming included crossing & wading into the tributaries. He told me he would try to speak to his neighbors about the turbidity issues associated with their livestock. FURTHER ACTION TAKEN/TO BE TAKEN: The Thomas Holland Family Trust 10-9, #1,2-22H27 drilling pad, lease road & pipeline ROW are newly constructed with disturbed soil present; however, SWN & DGC have placed numerous BMPs (both temporary & permanent) at the location. Reasonable measures to prevent turbidity & sedimentation are being practiced. There are too many industries in the area to solely place blame on one natural gas drilling pad. I did not feel the need to refer the noise complaint to another Division because the fracking of the wells had ended. INSPECTOR SIGNATURE: February 6, 2012 Page 3

4 Water Division Photographic Evidence Sheet Location: Thomas Holland Family Trust 10-9, #1,2-22H27 from Hwy 110 about 5.2 miles E of Heber Springs, AR Photographer: Kerri McCabe Witness: none Photo # 1 Of 3 Date: Time: 0749 Description: Overview of drilling pad & surrounding watershed Photographer: Kerri McCabe Witness: none Photo # 2 Of 3 Date: Time: 1132 Description: Private road between earthen berm of drilling pad & slough Page 4

5 Water Division Photographic Evidence Sheet Location: Thomas Holland Family Trust 10-9, #1,2-22H27 from Hwy 110 about 5.2 miles E of Heber Springs, AR Photographer: Kerri McCabe Witness: none Photo # 3 Of 3 Date: Time: 1146 Description: Unnamed tributary flowing pass Thomas Holland FT 10-9, #1,2-22H27 Page 5

6 Oil & Gas Violation Summary Sheet No Violations Noted Placing Waste Permitting Issues Spills & Leaks Turbidity (Regulation #2 Violations) Stormwater/Erosion Issues Notification/Reporting Violations Unpermitted Discharges Record Keeping/Paperwork Violations Trash/Unauthorized Fluids in Pits Improper Closure of Pit Insufficient Freeboard Poor Pit Construction Other (Describe): Page 6