RELIANCE GATHERING LLC

Incident Narrative

VALVE MANUALLY OPERATED BY LIVESTOCK. THE LIVESTOCK ENTERED THROUGH AN OPEN GATE. WE DETERMINED THE CAUSE BASED ON CATTLE FOOTPRINTS OBSERVED AROUND THE VALVE. ALL OTHER LOGICAL EXPLANATIONS WERE ELIMINATED. COMPLETING EXCAVATION AND BLENDING REMEDIATION CURRENTLY. RE-SEED AFTER COMPLETION PER UNIVERSITY LANDS REQUIREMENTS. STINGRAY ENVIRONMENTAL AND CONSTRUCTION BEGAN EXCAVATION ON SEPTEMBER 21, 2018, TO BRING ALL SOI.LS ABOVE ONE PERCENT TOTAL PETROLEUM HYDROCARBONS (TPH) TO THE SURFACE AS PER SWR RULE 91(C) 3. THE SPILL WAS EXCAVATED TO BELOW RRC REGULATIONS, WHICH YIELDED APPROXIMATELY 5,861 CUBIC YARDS OF SPILL-IMPACTED SOIL OVER 1 % TPH. CONFIRMATION SOIL SAMPLES OF THE EXCAVATION BOTTOM WERE COLLECTED FOR LABORATORY ANALYSIS OFTPH USING METHOD TX1005 IN ACCORDANCE WITH RRC GUIDELINES. APPROXIMATELY 5,861 CUBIC YARDS OF SPOIL MATERIAL WAS BLENDED WITH APPROXIMATELY 2,500 CUBIC YARDS OF CLEAN SOIL FROM THE SURROUNDING AREA TO ACHIEVE TPH LEVELS BELOW ONE PERCENT AS PER SWR 3.9L(D) (1). CONFIRMATION SOIL SAMPLES OF THE BLENDED MATERIALS WERE COLLECTED FOR LABORATORY ANALYSIS OF TPH USING METHOD TXL 005 IN ACCORDANCE WITH RRC GUIDELINES. SUBSEQUENT TO THE ANALYTICAL TESTING CONFIRMING THE TPH LEVELS OF BELOW 10,000 PPM FOR THE EXCAVATION AND BLENDED SOIL, THE BLENDED SOIL WAS UTILIZED AS BACKFILL MATERIAL AND SITE RESTORATION WAS COMPLETED APPROXIMATELY OCTOBER 21, 2018. CONFIRMATION SOIL SAMPLES WERE COLLECTED FROM THE EXCAVATED AREAS BOTTOM FOR ANALYSIS USING METHOD TXL 005 FOR TPH BY AN INDEPENDENT LABORATORY. SOIL SAMPLES COLLECTED FOR CONFIRMATION WERE PLACED IN LABORATORY PREPARED GLASSWARE, SEALED WITH CUSTODY TAPE AND PLACED ON ICE IN A SECURED COOLER. THE SAMPLES AND COMPLETED CHAIN OF CUSTODY WERE RELINQUISHED TO PBELAB, INC. IN MIDLAND, TEXAS FOR ANALYSIS. THE EXECUTED CHAIN-OF-CUSTODY FORMS, LABORATORY RESULTS SUMMARY, DATA SHEETS AND LABORATORY RESULTS ARE PROVIDED IN THE APPENDIX 1 OF THE REPORT. BASED ON THE ANALYTICAL RESULTS PURSUANT TO SWR 3.91, THE IMPACTED SOIL ABOVE 10,000 PPM TPH WAS EXCAVATED AND BROUGHT TO THE SURFACE. BASED ON RESULTS OF OUR FIELD ACTIVITIES AND LABORATORY ANALYSES, THE SWR 3.91 STANDARD FOR TPH IN SOIL HAS BEEN OBTAINED.