RE: AFIN: PERMIT NO.: 0751-WG-SW-1 WELL NAME: Squires SWD (Jessica #1-4 SWD) COUNTY: Conway Co.

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1 June 7, 2011 Mike Cook Terra Renewal, LLC 201 South Denver, Suite B Russellville, AR RE: AFIN: PERMIT NO.: 0751-WG-SW-1 WELL NAME: Squires SWD (Jessica #1-4 SWD) COUNTY: Conway Co. Mr. Cook: On June 3, 2011 I performed a routine compliance inspection of the surface facilities associated with a disposal system for injection of saltwater & other oil/gas wastes in accordance with the provisions of the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. At the time of the inspection, no violations were observed. Please be advised that Part III, Section B.7. of the permit, the Operator shall at all times properly maintain all portions of the pit and its systems of treatment & control, which are installed or used by the Operator to achieve compliance with the conditions of the permit. Proper operation & maintenance also include adequate staffing to ensure that the facilities comply with all conditions of this permit. Silt fencing was installed during construction and it has not been maintained. There is a freshwater pond adjacent to the facility that was noticeably turbid. Per Part III, Section B.1; all applicable provisions of APC&EC Regulation #2 (Water Quality Standards) are incorporated herein by reference. Please refer to the comments section of the inspection form for any notes regarding any areas of concern that may have been observed at the above referenced site. Furthermore, I have met with Bobby Dacus onsite in regards to any potential issues concerning this site. If I can be of any further assistance, please contact me at ext. 24 or via at mccabe@adeq.state.ar.us Thank you for your time, Kerri McCabe Oil & Gas Field Inspector Water Division ext. 24 mccabe@adeq.state.ar.us cc: Water Division Enforcement Branch Water Division Permits Branch Mike Cook, Terra Renewal, LLC, mikec@terrarenewal.com

2 ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY NO DISCHARGE INDUSTRIAL PERMIT INSPECTION FORM AFIN: Log No.: N/A Permit No.: 0751-WG-SW-1 Inspection Date: June 3, 2011 Media: WATER Inspector: Kerri McCabe Compliance Status: IN / OUT 1A. Name of Facility: Terra Renewal Squires SWD (Jessica #1-4 SWD) Address: Lat: ; Long: (location of well; 3 miles from facility) County: Conway Co. 2A. Name of On-Site Representative: Bobby Dacus 3A. Name of Responsible Official: Terra Renewal, LLC (Mike Cook) Address: 201 South Denver, Suite B Russellville, AR Telephone: A. Parent Company: N/A Address: Telephone: 5A. Description of Process (including type of industry, materials produced, and major by- Facility stores/filters produced water & gas field disposal fluids from wells within the production area & the filtered fluids are then injected products): into the well (commercial). 6A. Any complaints registered against this permitted facility? Yes No If yes, give date and description of complaint: 7A. Are there any additions, modifications, or corrections to the facility since the last inspection? Yes No There have been some improvements to the layout of the facility, and recent construction of a new containment berm & transfer pit. The layout does not match the original NOI; however, there has not been an increase in above-ground storage. An updated If yes, explain: schematic should be submitted. No Discharge Industrial Report Page 2

3 ADEQ Water Industrial No Discharge AFIN: Permit #: 0751-WG-SW-1 1B. Furnish a simplified flow diagram of the treatment system and include main components, flow sequence through plant, and calculated or estimated flows. 2B. Nearest Stream: Facility is near an unnamed, intermittent tributary of Cedar Branch & the well is near an unnamed, intermittent tributary of West Fork Point Remove Creek 3B. Does wastewater from this facility cause adverse effect on the waters of the State: Yes No Discharge of any saltwater or other oil/gass field wastes, including contaminated precipitation runoff, to the land or waters of the State is prohibited at all times. NO wastewater is discharged from If yes, describe: the site. 4B. Are operating records kept as required by permit? If no, explain: Yes No N/ /A 5B. Are maintenancee records kept as required by permit? If no, explain: Yes No N/ /A No Discharge Industrial Report Page 3

4 6B. Are Samples routinely taken? Yes No N/A 7B. Does the sampling program meet the requirements of the permit? Yes No N/A Operator samples each tanker truck received per AOGC rules (not If no, explain: required by ADEQ) 8B. What laboratory does the facility use? N/A; handheld ph/conductivity meter Address: Telephone: 1C. Do laboratory procedures and records meet the requirements of the permit? Yes No N/A If no, explain: 2C. Is contaminated runoff a problem? Yes No N/A Containment berm is emptied periodically of accumulated If yes, explain: precipitation 3C. Is sludge disposal required? Yes No N/A If yes, describe (including final destination): 4C. Is the treatment system being properly operated and maintained as required by permit? Yes No N/A If no, explain SUMMARY OF FINDINGS/COMMENTS There have been recent modifications to the site s layout. The Operator has improved the containment berm & transfer pit areas of the facility. The modifications have not resulted in an increase in produced water/oil & gas field waste storage capacity. However, an updated schematic should be sent to ADEQ. The containment berm is permanent & lined, and the individual storage tanks (connected by manifolds, all with individual shut-off valves & supervised 24/7) are placed on top of tank rings with a pea gravel liner. The transfer pit & concrete pit are completely finished, but a small area (walk-way) still needs concrete laid. The old office is still onsite, and the septic system is still being used (the septic system has not been installed in the new office). The actual injection well is 3 miles from the disposal facility (with 2 miles of transmission lines). The Operator has implemented BMPs during construction; however, they are not being maintained. A freshwater pond is in close proximity to the facility, and turbidity was observed. I informed Mr. Dacus that the silt fencing would need to be maintained to keep potential violations (Regulation #2) from occurring. The site is in transition, but appears to be operating properly. AOGC & ADEQ permits were visible onsite, and paperwork was being kept in an appropriate, up-to-date manner. Inspector Signature: Date of Report: June 7, 2011 Signature of Reviewer: Date of Review: July 6, 2011 No Discharge Industrial Report Page 4

5 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Squires SWD Facility (Jessica #1-4H) from Hwy 124 about 2 miles SW of Jerusalem, AR Photo # 1 Of 7 Date: Time: 1127 Description: Site identification Photo # 2 Of 7 Date: Time: 1129 Description: Truck transfer area & unfinished walk-way to transfer pit No Discharge Industrial Report Page 5

6 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Squires SWD Facility (Jessica #1-4H) from Hwy 124 about 2 miles SW of Jerusalem, AR Photo # 3 Of 7 Date: Time: 1129 Description: Transfer pit Photo # 4 Of 7 Date: Time: 1131 Description: Storage tanks within permanent, lined berm (note transmission line) No Discharge Industrial Report Page 6

7 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Squires SWD Facility (Jessica #1-4H) from Hwy 124 about 2 miles SW of Jerusalem, AR Photo # 5 Of 7 Date: Time: 1131 Description: Pump & filter station Photo # 6 Of 7 Date: Time: 1134 Description: Manifolds with individual shut-off valves No Discharge Industrial Report Page 7

8 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Squires SWD Facility (Jessica #1-4H) from Hwy 124 about 2 miles SW of Jerusalem, AR Photo # 7 Of 7 Date: Time: 1145 Description: Silt fencing full of sediment; freshwater pond in close proximity No Discharge Industrial Report Page 8

9 Oil and Gas Violation Summary Sheet No Violations Noted Placing Waste Permitting Issues Spills and Leaks Turbidity (Reg 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) No Discharge Industrial Report Page 9