Technical Review of Subpart RR MRV Plan for
30-30 Gas Plant

November 2022


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For assistance in accessing this document, please contact ghgreporting@epa.gov.


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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF
AIR AND RADIATION

November 4, 2022

Mr. Joshua Roberts
Stakeholder Midstream, LLC
401 E Sonterra Boulevard
Suite 215

San Antonio, Texas 78258

Re: Monitoring, Reporting and Verification (MRV) Plan for 30-30 Gas Plant

Dear Mr. Roberts:

The United States Environmental Protection Agency (EPA) has reviewed the
Monitoring, Reporting and Verification (MRV) Plan submitted for 30-30 Gas Plant, as required
by 40 CFR Part 98, Subpart RR of the Greenhouse Gas Reporting Program. The EPA is
approving the MRV Plan submitted by 30-30 Gas Plant on September 13, 2022, as the final
MRV plan. The MRV Plan Approval Number is 1013701-1. This decision is effective
November 9, 2022 and is appealable to the EPA's Environmental Appeals Board under 40 CFR
Part 78.

If you have any questions regarding this determination, please contact me or Melinda
Miller of the Greenhouse Gas Reporting Branch at miller.melinda@epa.gov.

Sincerely,

Julius Banks, Chief
Greenhouse Gas Reporting Branch


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Contents

1	Overview of Project	1

2	Evaluation of the Delineation of the Maximum Monitoring Area (MMA) and Active
Monitoring Area (AMA)	2

3	Identification of Potential Surface Leakage Pathways	3

4	Strategy for Detection and Quantifying Surface Leakage of C02 and for Establishing Expected
Baselines for Monitoring	7

5	Considerations Used to Calculate Site-Specific Variables for the Mass Balance Equation	12

6	Summary of Findings	15

Appendices

Appendix A: Final MRV Plan

Appendix B: Submissions and Responses to Requests for Additional Information


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This document summarizes the U.S. Environmental Protection Agency's (EPA's) technical evaluation of
the Greenhouse Gas Reporting Program (GHGRP) Subpart RR Monitoring, Reporting, and Verification
(MRV) plan submitted by the Stakeholder Gas Services, LLC (Stakeholder) 30-30 Gas Plant (30-30) for its
treated acid gas (TAG) injection project into the Wristen Group in Yoakum County, Texas approximately
seven miles northwest of the town of Plains. Note that this evaluation pertains only to the Subpart RR
MRV plan, and does not in any way replace, remove, or affect Underground Injection Control (UIC)
permitting obligations.

1 Overview of Project

30-30 states in the introduction of the MRV plan that it currently has a Class II permit for acid gas
injection (AGI), issued by the Texas Railroad Commission (TRRC) in November 2018 under the state's
Underground Injection Control (UIC) program for the Rattlesnake AGI #1 well, API No. 42- 501-36998,
UIC #000117143. This permit was originally issued to Santa Fe Midstream Permian, LLC in 2018, but the
asset was subsequently acquired by Stakeholder in December of 2020. This permit currently authorizes
30-30 to inject up to 4,500 barrels per day (or around 25,266 standard cubic feet per day (scf/d)) of TAG
into the Devonian formation at a depth of 11,000 to 12,000 feet with a maximum allowable surface
pressure of 2,200 pounds per square inch (psi). 30-30 claims that since being permitted, injection has
proceeded without incident. The Rattlesnake AGI #1 well is located in a rural, sparsely populated area of
Yoakum County, Texas, approximately seven miles northwest of the town of Plains.

In addition to submitting this MRV plan to the EPA, 30-30 is also applying to the TRRC for an amendment
to the Rattlesnake AGI #1 well's Class II permit to increase its authorized injection volume and maximum
allowable surface injection pressure (MASIP). The MRV plan states that approval of the permit
amendment will allow 30-30 to increase its capacity, which removes H2S and C02 from natural gas
production using amine treating. Approval will also increase the injection well capacity for a future gas
processing facility which is currently under development by Stakeholder. Additionally, expanded
capacity allows 30-30 to potentially provide future disposal in its AGI well for TAG from similar third-
party gas processing facilities. The MRV plan states that increased disposal capacity will allow for greater
gas processing capacity in the region, ultimately helping to reduce flaring and its associated emissions.
Throughout the MRV plan, both in written reference and in modeling inputs, 30-30 has used the
applied-for expanded permit capacity of 16 million standard cubic feet per day (MMSCF/d). 30-30 plans
to inject C02 for approximately 14 more years (17 years in total from the start of injection in 2019).

30-30 states in the MRV plan that the Rattlesnake AGI #1 well is designed in such a way to protect
against migration of C02 out of the injection interval and to prevent surface releases. The injection
interval for Rattlesnake AGI #1 is located over 4,720 feet below the primary producing formation, the San
Andres, and 8,593 feet below the base of the lowest useable quality water table, as shown in Figure 2 of
the MRV plan. As stated in section 2 of the MRV plan, this well will inject a C02 stream that contains
9.20% H2S, 89.68% C02, and 1.12% other gases. For these reasons, the MRV plan states that the well and
the facility are designed to minimize any leakage to the surface.

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In Section 2 of the MRV plan, 30-30 describes the geologic setting, planned injection volumes and
process, and the reservoir modeling performed for the Rattlesnake AGI #1. The target injection
formation is the Wristen Group. This formation was deposited in a basin platform setting across the
northern half of the Permian Basin. The MRV plan refers to this sequence as Devonian, Silurian-
Devonian, or Siluro-Devonian in age. The Silurian-age lithology on the inner platform is dominated by
grain-rich skeletal carbonates. The MRV plan states that the thickness of the Silurian-age rock is
approximately 1,000 feet thick at the Rattlesnake AGI #1 well location. Carbonate buildups are common
within the shallow inner platform, mainly skeletal wackestone, indicating a lower-energy deposition on
the inner platform. The Wristen Group is composed of three formations: Fasken, Frame, and Wink. The
Frame and Wink Formations are found near the ramp boundary to the south, while the Fasken
formation is found predominantly in the inner platform, where the Rattlesnake AGI #1 well is located.
The Fasken Formation is predominately dolomite grading to limestone, occurring as cycles, down
section. Figure 4 in the MRV plan shows a generalized stratigraphic column of the area underlying the
Rattlesnake AGI #1 well.

The MRV plan states that the upper confining interval is the Woodford Shale. The Woodford Shale is a
late Devonian-age organic-rich shale deposited as a result of a widespread marine transgression. The
flooding event occurred over most of the Permian basin, which produced a low relief, blanket-like shale
deposit of the Woodford. Two major lithofacies found within the Woodford are black shale and
siltstone. Nutrient-rich surface waters promoted the decay of abundant organic matter within the
Woodford, resulting in a high total organic carbon (TOC) percentage.

The MRV plan states that the low-permeability Montoya Formation is a tight limestone/dolomite that
will act as the lower confining unit for the injection interval. The MRV plan states that the porosity in the
lower section can range from 2-3% with permeabilities below 1 millidarcy (md). The Rattlesnake AGI #1
well drilled six feet into the Montoya formation, but the section was not logged. The MRV plan states
that the Montoya Formation is anticipated to be roughly 250 feet thick. The MRV plan states that these
petrophysical characteristics represent ideal sealing properties to prohibit any migration of injected fluid
outside of the injection interval.

The description of the project is determined to be acceptable and provides the necessary information
for 40 CFR 98.448(a)(6).

2 Evaluation of the Delineation of the Maximum Monitoring Area
(MMA) and Active Monitoring Area (AMA)

As part of the MRV plan, the reporter must identify and delineate both the maximum monitoring area
(MMA) and active monitoring area (AMA), pursuant to 40 CFR 98.448(a)(1). Subpart RR defines the
maximum monitoring area as "the area that must be monitored under this regulation and is defined as
equal to or greater than the area expected to contain the free phase C02 plume until the C02 plume has
stabilized plus an all-around buffer zone of at least one-half mile." Subpart RR defines the active
monitoring area as "the area that will be monitored over a specific time interval from the first year of

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the period (n) to the last year in the period (t). The boundary of the active monitoring area is established
by superimposing two areas: (1) the area projected to contain the free phase C02 plume at the end of
year t, plus an all-around buffer zone of one-half mile or greater if known leakage pathways extend
laterally more than one-half mile; (2) the area projected to contain the free phase C02 plume at the end
of year t + 5." See 40 CFR 98.449.

30-30 has indicated in the MRV plan that the initial AMA will cover a 14-year monitoring period, which is
equal to the expected time of future injection. The MRV plan states that the AMA itself will be
established based on the half-mile buffer around the anticipated plume location at the end of injection
in 2036. The area of projected free-phase C02 plume after five additional years (t + 5) was also reviewed,
but the boundaries of the plume at t + 5 were inside the plume boundary in 2016 plus the Vz mile buffer.
Therefore, the MRV plan delineates the AMA as the plume at the end of injection plus the Vz mile buffer.
The AMA is shown in Figure 27. 30-30 states that it may submit a revised MRV plan on or before 2036 to
amend the AMA if necessary.

The plume boundary was defined by the weighted average gas saturation in the aquifer. A value of 3%
gas saturation of C02 was used to determine the boundary of the plume. When injection ceases in year
2036, the MRV plan states that the areal expanse of the plume will be 1,052 acres. The maximum
distance between the wellbore and the edge of the plume is expected to be approximately 0.87 miles to
the southeast. After 743 additional years of density drift, the areal extent of the plume is predicted by
30-30 to be 2,177 acres with a maximum distance to the edge of the plume of approximately 1.35 miles
to the southeast. A map of the plume boundary can be seen in Figure 26 of the MRV plan.

The MMA is defined in the MRV plan as equal to or greater than the area expected to contain the free-
phase C02 plume until the C02 plume has stabilized plus an all-around buffer zone of at least one-half
mile, and is delineated in Figure 26. The MMA is consistent with Subpart RR requirements because the
defined MMA accounts for the expected free phase C02 plume, based on modeling results, and
incorporates the additional 0.5-mile or greater buffer area. The rationale used to delineate the MMA, as
described in 30-30's MRV plan, accounts for the existing operational and subsurface conditions at the
site, along with any potential changes in future operations. Therefore, the designation of the MMA is an
acceptable approach.

The delineations of the MMA and AMA were determined to be acceptable per the requirements in 40
CFR 98.448(a)(1). The MMA and AMA described in the MRV plan are clearly and explicitly delineated in
the plan and are consistent with the definitions in 40 CFR 98.449.

3 Identification of Potential Surface Leakage Pathways

As part of the MRV plan, the reporter must identify potential surface leakage pathways for C02 in the
MMA and the likelihood, magnitude, and timing of potential surface leakage of C02 through these
pathways pursuant to 40 CFR 98.448(a)(2). 30-30 identified the following as potential leakage pathways
in their MRV plan that required consideration:

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•	Leakage from surface equipment

•	Leakage through existing wells within MMA

•	Leakage through faults and fractures

•	Leakage through the confining layer

•	Leakage from Natural or Induced Seismicity

3.1	Leakage through Surface Equipment

The MRV plan states that 30-30 is designed for injecting acid gas containing H2S, and is therefore
designed and operated to minimize leakage points such as valves and flanges following industry
standards and best practices. The MRV plan states that H2S gas detectors are located around the facility
and the well site. These gas detectors trigger alarms at 10 parts per million (ppm) of H2S. Additionally, all
30-30 field personnel are required to wear H2S monitors which are triggered at 5 ppm of H2S. A shut-in
valve is located at the wellhead and is locally controlled by pressure, with a high pressure and low
pressure shut-off.

Additional safety features noted in this section of the MRV plan include Emergency Shutdown (ESD)
valves to isolate portions of the plant and pipeline; pressure relief valves along the pipeline to prevent
over pressurization; and flares to allow piping and equipment to be de-pressured rapidly.

The MRV plan states that with the level of monitoring at the 30-30 Facility and the Rattlesnake AGI #1
well, any release of H2S and C02 would be quickly identified, and the safety systems would quickly
minimize the volume of the release. It further states that the C02 injected into the Rattlesnake AGI #1 is
injected with H2S at a concentration of 10% (100,000 ppm). At this high level of H2S concentration,
even a small leakage would trigger personal and facility H2S monitors set to alarm at 5 ppm and 10 ppm
respectively.

Thus, the MRV plan provides an acceptable characterization of the C02 leakage that could be expected
through surface equipment.

3.2	Leakage from Existing Wells within MMA
Oil and Gas Operations within Monitoring Area

The MRV plan states that significant number of wells have historically been drilled within the area of the
Rattlesnake AGI #1 well. However, production has primarily been from the shallower San Andres
Formation in the Wasson Field. The San Andres Formation is separated from the Silurian-Devonian
interval by 4,720 feet in this area. The MRV plan states that a few wells have also been producing from
the Wolfcamp Formation. The Wolfcamp Formation is separated from the Siluro-Devonian interval by
1,800 feet. The MRV plan concludes that there are no penetrations of the injection interval within the
projected plume area of the Rattlesnake AGI #1 well.

The MRV plan also states that a review of the TRRC records for all the wells which penetrate the
injection interval within the MMA show that the wells were properly cased and cemented to prevent

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annular leakage of CChto the surface. The plugged wells are also adequately protected against migration
from the Devonian by the placement of the plugs within the wellbores. Additionally, the MRV plan states
that the Rattlesnake AGI #1 well was designed to prevent migration from the injection interval to the
surface through the casing and cement placed in the well, as shown in Figure 29 of the MRV plan. The
plan further states that Mechanical integrity tests ("MIT") required under TRRC rules are run annually to
verify the well and wellhead can hold the appropriate amount of pressure. If the MIT were to indicate a
leak, the well would be isolated and the leak mitigated quickly to prevent leakage to the atmosphere.

The MRV plan provides a map of all wells within the MMA in Figure 30. Figure 31 shows only those wells
which penetrate the injection interval within the MMA. The MMA review maps, a summary of all the
wells in the MMA and detailed wellbore schematics for those wells which penetrate the injection
interval are provided in Appendix F.

Future Drilling

The MRV plan states that potential leakage pathways caused by future drilling in the area are not
expected to occur, in particular noting that the deeper formations, such as the Devonian, have proven
to-date to be less productive or non-productive in this area, which is why the location was selected for
injection. Furthermore, the MRV plan states that any drilling permits issued by the TRRC in the area of
the Rattlesnake AGI #1 well include a list of formations for which oil and gas operators are required to
comply with TRRC Rule 13 (entitled "Casing, Cementing, Drilling, Well Control, and Completion
Requirements"), 16 TAC § 3.13. As stated in the MRV plan, TRRC Rule 13 requires oil and gas operators
to set steel casing and cement across and above all formations permitted for injection under TRRC Rule
9 or immediately above all formations permitted for injection under Rule 46 for any well proposed
within a one-quarter mile radius of an injection well. Additionally, Rule 13 requires operators to case
and cement across and above all potential flow zones and/or zones with corrosive formation fluids. The
MRV plan states that if any leakage were to be detected, the volume of C02 released will be quantified
based on the operating conditions at the time of release.

Groundwater Wells

The MRV plan states that there are seven groundwater wells located within the MMA, as identified by
the Texas Water Development Board. All the identified groundwater wells in the area have total depths
less than or equal to 265 feet, as shown in Figure 32 and Table 9 of the MRV plan. One of the wells is
located on the 30-30 facility property with a total depth of 119 feet and is operated by Stakeholder.

The surface and intermediate casings of the Rattlesnake AGI #1 well, as shown in Figure 29 of the MRV
plan, are designed to protect the shallow freshwater aquifers consistent with applicable TRRC
regulations and the GAU letter issued for this location. See GAU letter included within Appendix B of the
MRV plan. The wellbore casings and cements also serve to prevent C02 leakage to the surface along the
borehole.

Thus, the MRV plan provides an acceptable characterization of the C02 leakage that could be expected
through existing and future oil, gas, and groundwater wells.

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3.3 Leakage Through Faults and Fractures

The MRV plan states that faults were interpreted from roughly 9 square miles of 3D seismic indicated by
the purple outline in Figure 12 of the MRV plan. This interpreting revealed that faulting in this region
terminates vertically below the Pennsylvanian-age rock. Secondary confining shales within the
Wolfcampian and younger strata provide additional, redundant confining layers that would prevent C02
from migrating into freshwater aquifers. None of the mapped faults project above the Wolfcamp
formation; rather, they appear to terminate between the Strawn and the base of the Wolfcamp. The
MRV plan states that in the unlikely event the faults' sealing properties are compromised post-injection,
secondary confinement is provided by the tight limestones found within the overlying Mississippian
Lime formation and the shale layers found in the Atoka and Wolfcamp formations.

As seen in Figure 14 of the MRV plan, the largest fault found southeast (SE) of the Rattlesnake AGI #1
well terminates within the Atoka formation. Though it crosses the Silurian section, this fault thrusts the
Mississippian Lime upward against the Atoka shales. The tight reservoir characteristics of the
Mississippian Lime and shaley section of the Atoka create a confining environment vertically and
laterally to contain potential upward migration of buoyant fluids. Shales within the Wolfcamp formation
provide additional confining beds between overlying USDWs and the fault plane.

The MRV plan states that pressures will be kept significantly below the fracture gradient of the injection
and confining intervals. Therefore, 30-30 states that upward migration of injected gas through confining
bed fractures is unlikely.

Thus, the MRV plan provides an acceptable characterization of C02 leakage that could be expected
through faults or fractures.

3.4 Leakage through the Confining Layer

The MRV plan states that the Silurian-Devonian injection zones have competent sealing rocks above and
below the porous sub-aerially exposed carbonate. The MRV plan states that the properties of the
overlying transgressive Woodford shale (widespread deposition, high illite clay and organic matter
composition, and low porosity and permeability) make an excellent sealing rock to the underlying
Silurian formation. Furthermore, tight Mississippian Lime of roughly 660 feet lay between Atoka and
Woodford shale formations, forming an impermeable upper seal to the injection interval. Above this
confining unit, correlative shales of the Wolfcamp, Abo and Tubb formations will prevent any upper fluid
migration. The MRV plan states that these impermeable shales are capped by hundreds of feet of the
regionally present Salado formation evaporites. The USDW lies above the sealing properties of the
formations outlined above, making stratigraphic migration of fluids into the USDW highly unlikely. The
MRV plan states that the low porosity and permeability of the underlying Montoya carbonate minimizes
the likelihood of downward migration of injected fluids. It also states that the relative buoyancy of
injected gas to the in-situ reservoir fluid makes migration below the lower confining layer unlikely.

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Thus, the MRV plan provides an acceptable characterization of C02 leakage that could be expected
through confining layers.

3.5 Leakage From Natural or Induced Seismicity

The MRV plan states that the location of Rattlesnake AGI #1 is in an area of the Permian Basin that is
inactive from a seismicity perspective, whether induced or natural. A review of historical seismic events
on the USGS's Advanced National Seismic System site (from 1971 to present) and the Bureau of
Economic Geology's TexNet catalog (from 2017 to present), as shown in Figure 33 of the MRV plan,
indicates the nearest seismic event occurred more than 60 miles away.

The MRV plan states that a regional analysis of the probabilistic fault slip potential across the Permian
Basin (Snee & Zoback 2016) further demonstrates that the Rattlesnake AGI #1 well is located in a
seismically inactive area and confirms that this area has little to no potential for an induced seismicity
event. Therefore, 30-30 states that there is no indication that seismic activity poses a risk for loss of C02
to the surface within the MMA.

Furthermore, the MRV plan states that pressures will be kept significantly below the fracture gradient of
the injection and confining intervals. This lowers the risk of induced seismicity. Additionally, continuous
well monitoring combined with seismic monitoring will identify any operational anomalies associated
with a seismicity event.

Thus, the MRV plan provides an acceptable characterization of C02 leakage that could be expected
through natural or induced seismicity.

4 Strategy for Detection and Quantifying Surface Leakage of CO2
and for Establishing Expected Baselines for Monitoring

40 CFR 98.448(a)(3) requires that an MRV plan contain a strategy for detecting and quantifying any
surface leakage of C02, and 40 CFR 98.448(a)(4) requires that an MRV plan include a strategy for
establishing the expected baselines for monitoring C02 surface leakage. Section 5 of the MRV plan
details 30-30's strategy for monitoring and quantifying potential C02 leakage, and section 6 of the MRV
plan details strategies for establishing baselines for evaluating potential C02 leakage. The MRV plan
explains that as the C02 stream injected at the 30-30 facility contains both H2S and C02, fixed and
personal H2S monitors will be 30-30's primary method for monitoring C02 leakage. The H2S will serve as
a proxy for C02. Additional approaches for detecting and quantifying surface leakage of C02 primarily
include visual inspections, well mechanical integrity tests (MITs), groundwater sampling, continuous
monitoring, and seismic monitoring. Monitoring will occur during the planned 17-year injection period,
or until cessation of injection operations, plus a proposed 5-year post-injection period. Table 10 of the
MRV plan, which has been reproduced below, provides a summary of potential leakage pathway(s) and

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their respective monitoring methods.

Leakage Pathway

Monitoring Method

Leakage from surface equipment

Fixed H2S monitors throughout the AGI facility

Daily visual inspections

Personal H2S monitors

Distributed Control System Monitoring (Volumes and Pressures)

Leakage through existing wells

Fixed H2S monitor at the AGI well

SCADA Continuous Monitoring at the AGI Well

Annual Mechanical Integrity Tests ("MIT") of the AGI Well

Visual Inspections

Quarterly C02 Measurements within AMA

Leakage through groundwater wells

Annual Groundwater Samples on Property

Leakage from future wells

H2S Monitoring during offset drilling operations

Leakage through faults and fractures

SCADA Continuous Monitoring at the AGI Well (volumes and pressures)

Fixed In-field H2S monitors

Leakage through confining layer

SCADA Continuous Monitoring at the AGI Well (volumes and pressures)

Fixed In-field H2S monitors

Leakage from natural or induced
seismicity

Seismic monitoring station to be installed

SCADA - Supervisory control and data acquisition

4.1 Detection of Leakage through Surface Equipment

As described in section 5 of the MRV plan, the M2S in the injectate serves as a proxy for the release of
C02. The MRV plan states that the 30-30 Facility and the Rattlesnake AGI #1 well are designed to handle
H2S through a facility design that minimizes leak points and corrosion points. Therefore, the MRV plan
states that C02 leakage from surface equipment is unlikely to occur and would be quickly detected and
addressed if it does occur. 30-30 and the Rattlesnake AGI #1 well site contain numerous H2S alarms, set
with a high alarm setpoint of 10 ppm of H2S. Additionally, all 30-30 field personnel are required to wear
H2S monitors, which trigger the alarm at 5 ppm H2S.

The MRV plan also states that 30-30 is continuously monitored through automated systems. Field
personnel also conduct daily visual field inspections of gauges, monitors and leak indicators such as
vapor plumes. The plan explains that the effectiveness of the internal and external corrosion control
program is monitored through the periodic inspection of the system, analysis of liquids collected from
the system, and inspection of the cathodic protection system. The MRV plan states that these
inspections, in addition to the automated systems, will allow 30-30 to quickly respond to any leakage
situation. Monitoring will occur for the duration of injection and the post-injection period. Should
leakage be detected, 30-30 will calculate the volume of C02 released based on operating conditions at
the time of the event, per 40 CFR §98.448(a)(5). The MRV plan states that the mass of any C02 released
through surface leakage would be calculated for the operating conditions at the time, including
pressure, flow rate, size of the leak point opening, and duration of the leak.

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Thus, the MRV plan provides adequate characterization of 30-30's approach to detect potential leakage
through surface equipment as required by 40 CFR 98.448(a)(3).

4.2 Detection of Leakage from Wells within the Monitoring Area

As described in section 5 of the MRV plan, 30-30 continuously monitors and collects injection volumes,
pressures, temperatures and gas composition data, through their SCADA systems, for the Rattlesnake
AGI #1 well. Rattlesnake AGI #1 has a pressure and temperature gauge placed in the injection stream at
its wellhead, and a pressure gauge on the casing annulus. The MRV plan states that a change to the
pressure on the annulus would indicate the presence of a possible leak. The MRV plan states that these
data are reviewed by qualified personnel and will follow response and reporting procedures when data
are outside acceptable performance limits. Furthermore, MITs performed annually would also indicate
the presence of a leak. Upon a negative MIT, the well would immediately be isolated and the leak
mitigated.

The MRV plan states that the ten offset penetrating wells within the MMA are adequately cased and
cemented to prevent potential leakage of CChfrom the Rattlesnake AGI #1 well plume. Additionally, the
plan states that the plugging of these wells was executed in a way to prevent migration. Details on these
procedures are provided in Appendix E of the MRV plan. As discussed in the MRV plan, TRRC Rule 13
would ensure that new wells in the field would be constructed in a manner to prevent migration from
the injection interval.

In addition to the fixed and personal monitors described previously, 30-30 will also establish and
operate an in-field monitoring program to detect any CO2 leakage within the AMA. This will include H2S
and CO2 monitoring at the AGI well site as well at a minimum, quarterly atmospheric monitoring near
identified penetrations within the AMA. Upon approval of the MRV and through the post-injection
monitoring period, 30-30 will have these monitoring systems in place. Additional monitoring will be
added as the AMA is updated over time.

The MRV plan states that, at the well site, H2S and CO2 concentrations will be monitored continuously
with fixed monitors that detect atmospheric concentrations of H2S and CO2. At penetrating well sites,
30-30 will similarly measure atmospheric concentrations of CO2 and H2S using mobile gas monitors. This
data will be recorded at least quarterly.

According to the MRV plan, 30-30 will also monitor the groundwater quality in fluids above the confining
interval by sampling the well on the facility property and analyzing the sample with a third-party
laboratory on an annual basis. Any significant changes to the water analysis would be investigated to
determine if such change was a result of leakage from the Rattlesnake AGI #1 well. The parameters to
be measured will include pH, total dissolved solids, total inorganic and organic carbons, density,
temperature and other standard laboratory measurements. Any significant differences in these
parameters from the baseline sample will be evaluated to determine if leakage of CChto the USDW may
have occurred.

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Thus, the MRV plan provides adequate characterization of 30-30's approach to detect potential leakage
through existing and future wells as required by 40 CFR 98.448(a)(3).

4.3	Detection of Leakage Through Faults or Fractures

As described in section 5 of the MRV plan, 30-30 continuously monitors the operations of the
Rattlesnake AGI #1 well through automated systems. The MRV plan states that any deviation from
normal operating conditions indicating movement into a potential pathway such as a fault or
breakthrough of the confining seal would trigger an alert. Any such alert would be reviewed by field
personnel and action taken to shut in the well, if necessary. Field H2S monitoring systems would alert
field personnel for any release of H2S/CO2 caused by such leakage.

Thus, the MRV plan provides adequate characterization of 30-30's approach to detect potential leakage
through faults and fractures as required by 40 CFR 98.448(a)(3).

4.4	Detection of Leakage through Confining Layers

As described in section 5 of the MRV plan, 30-30 plans to use SCADA continuous monitoring at the
Rattlesnake AGI #1 well in order to keep track of gas volumes and pressures that might be lost due to
leakage through the confining seal. Furthermore, the MRV plan states that fixed H2S monitors will be
used to detect and monitor potential leakage through the confining seal. Any deviation from normal
operating conditions indicating a breakthrough of the confining seal would trigger an alert. Any such
alert would be reviewed by field personnel and action taken to shut in the well, if necessary. Field H2S
monitoring systems would alert field personnel for any release of H2S/CO2 caused by such leakage.

Thus, the MRV plan provides adequate characterization of 30-30's approach to detect potential leakage
through the confining layers as required by 40 CFR 98.448(a)(3).

4.5	Detection of Leakage from Natural or Induced Seismicity

As described in section 5 of the MRV plan, 30-30 plans to install a seismic monitoring station in the
general area of the Rattlesnake AGI #1 well. The installation of this station would start upon approval of
the MRV plan, with an expected in-service date within six months after the commencement of the
installation project. This monitoring station will be tied into the Bureau of Economic Geology's TexNet
Seismic Monitoring Dystem. If a seismic event of 3.0 magnitude or greater is detected, 30-30 will review
the injection volumes and pressures at the Rattlesnake AGI #1 well to determine if any significant
changes occurred that would indicate potential leakage. Additionally, continuous well monitoring
combined with seismic monitoring will identify any operational anomalies associated with a seismicity
event.

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Thus, the MRV plan provides adequate characterization of 30-30's approach to detect potential leakage
through natural or induced seismicity as required by 40 CFR 98.448(a)(3).

4.6 Determination of Baselines and Quantification of Potential CO2 Leakage

Section 6 of the MRV plan outlines 30-30's methodology for determining expected baselines for
monitoring C02 surface leakage. 30-30 will use the existing SCADA monitoring systems to identify
changes from expected performance that may indicate leakage of CO2. The MRV plan states that the
mass of any C02 released would be calculated for the operating conditions at the time, including
pressure, flow rate, size of the leak point opening, and duration of the leak.

Visual Inspections

The MRV plan states that daily inspections will be conducted by field personnel at the 30-30 facility and
the Rattlesnake AGI #1 well. These inspections will aid with identifying and addressing issues timely to
minimize the possibility of leakage. If any issues are identified, such as vapor clouds or ice formations,
corrective actions would be taken to address such issues.

H2S Detection

The MRV plan implies that known H2S concentrations of the injectate will be used to determine
expected leakage relative to established baselines. As stated in the MRV plan, H2S will be initially
injected into the AGI well at a concentration of approximately ten (10) percent or 100,000 ppm. The
concentration will drop to approximately seven percent as additional volumes are added. H2S gas
detectors are located throughout the AGI facility and well site and are set to trigger the alarm at 10
ppm. Additionally, all field personnel are required to wear personal H2S monitors, which are set to
trigger the alarm at 5 ppm. Any alarm would trigger an immediate response to protect personnel and
verify that the monitors are working properly.

C02 Detection

The MRV plan states that any CO2 release would be accompanied by H2S, therefore, the H2S monitors at
the facility would also serve as a CO2 release warning system. In addition to the fixed and personal
monitors described previously, 30-30 states that it will also establish and operate an in-field monitoring
program to detect any CO2 leakage within the AMA and MMA. This will include H2S and CO2 monitoring
at the AGI well site as well as atmospheric monitoring near identified penetrations within the AMA.

Operational Data

The MRV plan explains that upon starting injection operations, baseline measurements of injection
volumes and pressures will be taken. Any significant deviations over time will be analyzed for indication
of potential leakage of CO2.

Continuous Monitoring

11


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The MRV plan states that the mass of C02 emitted by surface leakage and equipment leaks will not be
measured directly as the injection stream for this well contains H2S which would be extremely
dangerous for personnel to perform a direct leak survey. Any leakage would be detected and managed
as per Texas regulations and 30-30's TRRC approved H2S Contingency Plan. Gas detectors and
continuous monitoring systems would trigger an alarm upon a release. The mass of the CO2 released
would be calculated for the operating conditions at the time, including pressure, flow rate, size of the
leak point opening, and duration of the leak. 30-30 notes that this method is consistent with 40 CFR
§98.448(a)(5), allowing the operator to calculate site-specific variables used in the mass balance
equation. The MRV plan states that no C02 emissions should occur from venting because of the high H2S
concentrations. Blowdown emissions are sent to flares and would be reported as part of the required
reporting for the gas plant.

Groundwater Monitoring

The MRV plan states that an initial groundwater sample will be taken from the groundwater well on SO-
SO property and analyzed by a third-party laboratory upon the MRV plan's approval to establish the
baseline properties of the groundwater.

Given the methodologies listed above, 30-30 provides an acceptable approach for establishing C02
leakage monitoring baselines in accordance with 40 CFR 98.448(a)(4).

5 Considerations Used to Calculate Site-Specific Variables for the
Mass Balance Equation

5.1	Calculation of Mass of CO2 Received

According to the MRV plan, the C02 received for this injection well will be wholly injected and not mixed
with any other supplies of C02, thus the annual mass of C02 injected will equal the quantity of C02
received at the receiving flow meter. Therefore, in accordance with 40 CFR §98.444(a)(4), 30-30 will use
the mass of C02 injected as the mass of C02 received instead of using Equation RR-1 or RR-2.

30-30's approach to calculating the mass of C02 received is acceptable for the Subpart RR requirements.

5.2	Calculation of Mass of CO2 Injected

Section 7 of the MRV plan states that the mass of C02 injected will be calculated using Equation RR-5 in
accordance with 40 CFR §98.444(b). The flow rate of C02 injected will be measured with a volumetric
flow meter, the total annual mass of C02, in metric tons, will be calculated by multiplying the volumetric
flow at standard conditions by the C02 concentration in the flow and the density of C02 at standard
conditions, as follows:

12


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4

C02,u = ^ Qp,u *D * cco2pM

P = 1

Where:

C02,u = Annual C02 mass injected (metric tons) as measured by flow meter u.

QP,u = Quarterly mass flow rate measurement for flow meter u in quarter p (metric tons per
quarter).

D = Density of C02 at standard conditions (metric tons per standard cubic meter): 0.0018682

Cco2,P,u = Quarterly C02 concentration measurement in flow for flow meter u in quarter p (wt.
percent C02, expressed as a decimal fraction).

p = Quarter of the year

u = Flow meter.

30-30 provides an acceptable approach to calculating the mass of C02 injected in accordance Subpart RR
requirements.

5.3	Mass of CO2 Produced

The MRV plan states that the Rattlesnake AGI #1 well is not part of an enhanced oil recovery project,
thus no C02 will be produced.

5.4	Calculation of Mass of CO2 Emitted by Surface Leakage

The MRV plan states that the mass of C02 emitted by surface leakage and equipment leaks will not be
measured directly as the injection stream for this well contains H2S which would be extremely
dangerous for personnel to perform a direct leak survey. Any leakage would be detected and managed
as a major upset event. Gas detectors and continuous monitoring systems would trigger an alarm upon
a release. The mass of the C02 released would be calculated for the operating conditions at the time,
including pressure, flow rate, size of the leak point opening, and duration of the leak. This method is
consistent with 40 CFR §98.448(a)(5), allowing the operator to calculate site-specific variables used in
the mass balance equation.

13


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In the unlikely event that C02 was released as a result of surface leakage, the MRV plan states that the
mass emitted would be calculated for each surface pathway according to methods outlined in the plan
and totaled using Equation RR-10 as follows:

X

C02e — ^ C02,x

X—l

Where:

C02 = Total annual C02 mass emitted by surface leakage (metric tons) in the reporting year
C02,x = Annual C02 mass emitted (metric tons) at leakage pathway x in the reporting year
X = Leakage pathway

The MRV plan states that calculation methods from Subpart W will be used to calculate C02 emissions
from equipment located on the surface between the flow meter used to measure injection quantity and
the injection wellhead.

30-30 provides an acceptable approach for calculating the mass of C02 emitted by surface leakage under
the Subpart RR requirements.

5.5 Calculation of Mass of CO2 Sequestered

The MRV plan states that the mass of C02 sequestered in subsurface geologic formations will be
calculated based off Equation RR-12, as this well will not actively produce oil or natural gas or any other
fluids, as follows:

C02 — C02i — C02e ~ C02fi

Where:

C02 = Total annual C02 mass sequestered in subsurface geologic formations (metric tons) at the
facility in the reporting year

C02| = Total annual C02 mass injected (metric tons) in the well or group of wells covered by this
source category in the reporting year

C02E = Total annual C02 mass emitted (metric tons) by surface leakage in the reporting year

14


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C02F| = Total annual C02 mass emitted (metric tons) from equipment leaks and vented emissions of
C02 from equipment located on the surface between the flow meter used to measure injection
quantity and the injection wellhead

The plan further states that C02Fi will be calculated in accordance with Subpart W reporting of GHGs.
Because no venting would occur due to the high H2S concentrations of the injectate stream, the
calculations would be based on the blowdown emissions that would be sent to flares and would be
reported as part of the required GHG reporting for the gas plant.

The plan also states that calculation methods from Subpart W will be used to calculate C02 emissions
from equipment located on the surface between the flow meter used to measure injection quantity and
the injection wellhead.

30-30 provides an acceptable approach for calculating the mass of C02 sequestered under Subpart RR.

Overall, 30-30 provides an acceptable approach for the considerations used to calculate site-specific
variables for the mass balance equation as required by 98.448(a)(5).

6 Summary of Findings

The Subpart RR MRV plan for the 30-30 Facility meets the requirements of 40 CFR 98.448. The
regulatory provisions of 40 CFR 98.448, which specifies the requirements for MRV plans, are
summarized below along with a summary of relevant provisions in the MRV plan.

Subpart RR MRV Plan Requirement

30-30 MRV Plan

40 CFR 98.448(a)(1): Delineation of the
maximum monitoring area (MMA) and the
active monitoring areas (AMA).

Section 3 of the MRV plan describes the MMA and
AMA. 30-30 used CMG's GEM numerical simulation
software to determine the areal extent and density
drift of the C02 plume. Numerical simulation was also
used by 30-30 to predict the size and drift of the C02
plume. The MMA is defined as equal to or greater than
the area expected to contain the free-phase C02 plume
until the C02 plume has stabilized plus an all-around
buffer zone of at least one-half mile. The AMA is based
on the superimposition of a one-half mile buffer
around the anticipated plume location at the end of
injection in 2036 and the area of projected free-phase
C02 plume after 5 additional years.

15


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40 CFR 98.448(a)(2): Identification of
potential surface leakage pathways for C02
in the MMA and the likelihood, magnitude,
and timing, of surface leakage of C02
through these pathways.

Section 4 of the MRV plan identifies and evaluates
potential surface leakage pathways. The MRV plan
identifies the following potential pathways: leakage
from surface equipment, leakage through existing wells
within the MMA, leakage through faults and fractures,
leakage through natural or induced seismicity, leakage
from drilling through the MMA, and leakage through
the confining layer. The MRV plan analyzes the
likelihood, magnitude, and timing of potential surface
leakage through these pathways.

40 CFR 98.448(a)(3): A strategy for
detecting and quantifying any surface
leakage of C02.

Section 5 of the MRV plan describes strategies for how
the facility would detect C02 leakage to the surface,
such as H2S monitors, visual inspections, and SCADA
continuous monitoring of the Rattlesnake AGI #1 well.
Section 4 of the MRV plan describes a strategy for how
potential surface leakage would be quantified.

40 CFR 98.448(a)(4): A strategy for
establishing the expected baselines for
monitoring C02 surface leakage.

Section 6 of the MRV plan describes the strategy for
establishing baselines against which monitoring results
will be compared to assess potential surface leakage.
30-30 will use visual inspections, H2S detection, C02
detection, operational data, continuous monitoring,
and groundwater monitoring to establish baselines for
monitoring potential C02 surface leakage.

40 CFR 98.448(a)(5): A summary of the
considerations you intend to use to
calculate site-specific variables for the mass
balance equation.

Section 7 of the MRV plan describes 30-30's approach
to determining the amount of C02 sequestered using
the Subpart RR mass balance equation, including as
related to calculation of total annual mass emitted
from equipment leakage.

40 CFR 98.448(a)(6): For each injection
well, report the well identification number
used for the UIC permit (or the permit
application) and the UIC permit class.

Section 1 of the MRV plan provides well identification
number for the Rattlesnake AGI #1 well. The MRV plan
specifies that the Rattlesnake AGI #1 well has been
issued a UIC Class II permit under TRRC Rule 9 and Rule
36.

40 CFR 98.448(a)(7): Proposed date to
begin collecting data for calculating total
amount sequestered according to equation
RR-11 or RR-12 of this subpart.

Section 8 of the MRV plan states that the 30-30 facility
baseline measurements of injection volumes and
pressures will be taken upon implementation of this
MRV plan. 30-30 will implement the MRV plan upon
receiving EPA approval.

16


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Appendix A: Final MRV Plan


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STAKEHOLDER

I!MIDSTREAM

Subpart RR Monitoring, Reporting, and
Verification (MRV) Plan
Rattlesnake AGI #1

Yoakum County, Texas

Prepared for Stakeholder Gas Services, LLC
San Antonio, TX

By

Lonquist Sequestration, LLC
Austin, TX

Version 3
September 2022



LONQUIST

SEQUESTRATION LLC


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INTRODUCTION

Stakeholder Gas Services, LLC ("Stakeholder") currently has a Class II acid gas injection ("AGI") permit, issued
by the Texas Railroad Commission ("TRRC") in November 2018, for the Rattlesnake AGI #1 well, API No. 42-
501-36998. This permit was originally issued to Santa Fe Midstream Permian, LLC, in 2018 and the asset was
subsequently acquired by Stakeholder in December of 2020. This permit currently authorizes Stakeholder to
inject up to 4,500 barrels per day ("bbls/d") of treated acid gas ("TAG") into the Devonian formation at a
depth of 11,000' to 12,000' with a maximum allowable surface pressure of 2,200 psi. Since being permitted,
injection has proceeded without incident. This AGI well is associated with Stakeholder's 30-30 gas treating
and processing plant ("30-30") located in a rural, sparsely populated area of Yoakum County, Texas,
approximately seven miles northwest of the town of Plains, as shown in Figure 1.

I t

H-



Ula

homa















STAKEHOLDER
MIDSTREAM



Mexlip

TT
:

1

t

L

Y



I











H

iti































l^vas

J L















riV





r\ fV















WES

T OIL F

IELD

















































Yoakum

ink Bas.n



















Rattlesnake
AGI(RS#1)



























¦





























WASSON OIL

FIELD



° *





9
"S













W























i
|















Four Mi



	 | 1

Ji|—k s ¦/- 1 i
§



YbAKUM





GAINrS

^ Gaines







0 0.5 1 2 Miles

GEOROi

ALLEN

OIL

FIELD

# Stakeholder AGI Well

Figure 1 - Location of Rattlesnake AGI #3 Well

1


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Stakeholder is submitting this Monitoring, Reporting, and Verification ("MRV") plan to the EPA for approval
under 40 CFR §98.440(a), Subpart RR, of the Greenhouse Gas Reporting Program ("GHGRP"). In addition to
submitting this MRV plan to the EPA, Stakeholder is also applying to the TRRC for an amendment to the
Rattlesnake AGI #1 well's Class II permit to increase its authorized injection volume and maximum allowable
surface injection pressure ("MASIP"). Approval of the permit amendment will allow Stakeholder to increase
the capacity of its existing 30-30 Facility, which removes H2S and C02 from natural gas production using amine
treating, as well as increase the injection well capacity for a future gas processing facility which is currently
under development by Stakeholder. Additionally, expanded capacity allows Stakeholder to potentially
provide future disposal in its AGI well for oil and gas waste derived TAG from similar third-party gas processing
facilities. Increased disposal capacity will allow for greater gas processing capacity in the region, ultimately
helping to reduce flaring and its associated emissions. Throughout this document, both in written reference
and in modeling inputs, Stakeholder has used the applied-for expanded permit capacity of 16 million standard
cubic feet per day ("MMSCF/d"). Stakeholder plans to inject C02 for approximately 14 more years.

2


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ACRONYMS AND ABBREVIATIONS

%

°c

°F

AMA

BCF

CH4

CMG

C02

E

EOS

EPA

ESD

FG

ft

GAU

GEM

GHGs

GHGRP

H2S

md

mi

MIT

MM

MMA

MCF

MMCF

MMSCF

Feet

Percent(Percentage)

Degrees Celsius
Degrees Fahrenheit
Active Monitoring Area
Billion Cubic Feet
Methane

Computer Modelling Group

Carbon Dioxide (may also refer to other Carbon Oxides)
East

Equation of State

U.S. Environmental Protection Agency
Emergency Shutdown
Fracture Gradient
Foot (Feet)

Groundwater Advisory Unit

Computer Modelling Group's GEM 2020.11

Greenhouse Gases

Greenhouse Gas Reporting Program

Hydrogen Sulfide

Millidarcy(ies)

Mile(s)

Mechanical Integrity Test
Million

Maximum Monitoring Area
Thousand Cubic Feet
Million Cubic Feet
Million Standard Cubic Feet


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MSCF/D	Thousand Cubic Feet per Day

MMSCF/d	Million Standard Cubic Feet per Day

MRV	Monitoring, Reporting and Verification

v	Poisson's Ratio

N	North

NW	Northwest

OBG	Overburden Gradient

PG	Pore Gradient

pH	Scale of Acidity

ppm	Parts per Million

psi	Pounds per Square Inch

psig	Pounds per Square Inch Gauge

S	South

SE	Southeast

SF	Safety Factor

SWD	Saltwater Disposal

TAC	Texas Administrative Code

TAG	Treated Acid Gas

TOC	Total Organic Carbon

TRRC	Texas Railroad Commission

UIC	Underground Injection Control

USDW	Underground Source of Drinking Water

W	West

4


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TABLE OF CONTENTS

INTRODUCTION	1

ACRONYMS AND ABBREVIATIONS	3

SECTION 1 - FACILITY INFORMATION	8

Reporter number	8

Underground Injection Control (UIC) Class II Permit	8

UIC Well Identification Number	8

SECTION 2- PROJECT DESCRIPTION	9

Regional Geology	10

Regional Faulting	15

Site Characterization	15

Stratigraphy and Lithologic Characteristics	15

Upper Confining Interval - Woodford Shale	16

Injection Interval - Fasken Formation	17

Lower Confining Zone - Fusselman Formation	21

Local Structure	21

Injection and Confinement Summary	26

Groundwater Hydrology	26

Description of the Injection Process	31

Current Operations	31

Planned Operations	32

Reservoir Characterization Modeling	32

Simulation Modeling	35

SECTION 3 - DELI NATION OF MONITORING AREA	39

Maximum Monitoring Area	39

Active Monitoring Area	40

SECTION 4- POTENTIAL PATHWAYS FOR LEAKAGE	42

Leakage from Surface Equipment	42

Leakage from Wells in the Monitoring Area	44

Oil and Gas Operations within Monitoring Area	44

Groundwater wells	48

Leakage Through Faults or Fractures	50

Leakage Through Confining Layers	51

Leakage from Natural or Induced Seismicity	51

SECTION 5 - MONITORING FOR LEAKAGE	54

Leakage from Surface Equipment	54

Leakage from Existing and Future Wells within Monitoring Area	55

Leakage through Faults, Fractures or Confining Seals	56

Leakage through Natural or Induced Seismicity	56

SECTION 6 - BASELINE DETERMINATIONS	57

Visual Inspections	57

H2S Detection	57

C02 Detection	57

Operational Data	57

Continuous Monitoring	57

Groundwater Monitoring	58

SECTION 7 - SITE SPECIFIC CONSIDERATIONS FOR MASS BALANCE EQUATION	59

5


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Mass of C02 Received	59

Mass of C02 Injected	59

Mass of C02 Produced	60

Mass of C02 Emitted by Surface Leakage	60

Mass of C02 Sequestered	60

SECTION 8- IMPLEMENTATION SCHEDULE FOR MRV PLAN	62

SECTION 9 - QUALITY ASSURANCE	63

Monitoring QA/QC	63

Missing Data	63

MRV Plan Revisions	64

SECTION 10- RECORDS RETENTION	65

References	66

APPENDICES	67

LIST OF FIGURES

Figure 1 - Location of Rattlesnake AGI #1 well	1

Figure 2 - Illustrative overview of Rattlesnake AGI #1 and 30-30 Facility	9

Figure 3 - Regional Map of the Permian Basin	10

Figure 4 - Stratigraphic column of the Northwest Shelf	11

Figure 5 - Stratigraphic column depicting the composition of the Silurian group	12

Figure 6 - Thickness map of the Silurian system which composes the Fusselman and Wristen group	14

Figure 7 - Type Log (42-501-10238) with tops, confining and injection zones depicted	15

Figure 8 - Core description of the Woodford Shale and Upper Silurian (Ruppel and Holtz, 1994)	16

Figure 9 - Table of reservoir properties found within the Wristen buildups and platform plays	18

Figure 10 - Rattlesnake AGI #1 open hole log (42-501-36998)	19

Figure 11 - Offset wells used for Formation Fluid Characterization	20

Figure 12 - Silurian Structure Map (subsea depths)	23

Figure 13 - Structural Northeast-Southwest Cross Section	24

Figure 14- Structural Northwest-Southeast Cross Section	25

Figure 15 - Northwest-Southeast Cross Section of aquifers in the Rattlesnake AGI #1 well area 	27

Figure 16 - Potentiometric surfaces from wells completed in A Ogallala aquifer, B the Edwards-Trinity aquifer

and Cthe Dockum aquifer	28

Figure 17 - Regional extent of the Dockum freshwater aquifer (TWDB)	29

Figure 18 - Total dissolved solids in groundwater from the Dockum Aquifer	29

Figure 19 - Regional extent of the Edwards-Trinity freshwater aquifer	30

Figure 20 - Regional extent of the Ogallala freshwater aquifer 	31

Figure 21 - 30-30 Facility Process Flow Diagram	32

Figure 22 - Permeability Distribution of Karst Limestone	34

Figure 23 - Areal View Gas Saturation Plume, 2036 (End of Injection)	37

Figure 24 - Areal View Gas Saturation Plume, 2779 (End of Density Drift)	38

Figure 25 - Well Injection Rate and Bottomhole Pressure over Time	38

Figure 26 - Plume Boundary at End of Injection, Stabilized Plume, and Maximum Monitoring Area	40

Figure 27 - Active Monitoring Area	41

Figure 28 - Site Plan, 30-30 Facility	43

Figure 29 - Rattlesnake AGI #1 Wellbore Schematic	45

Figure 30 - Oil and Gas Wells within the MMA	46

6


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Figure 31 - Penetrating Oil and Gas Wells within the MMA	47

Figure 32 - Groundwater Wells within MMA	49

Figure 33 - Seismicity Review (TexNet - 06/01/2022)	52

Figure 34 - Probabilistic Fault Slip Potential Analysis with Rattlesnake AGI #1 location	53

LIST OF TABLES

Table 1 - Analysis of Silurian-Devonian age formation fluids from nearby oil-field brine samples	20

Table 2 - Fracture Gradient Assumptions	21

Table 3 - Geologic and hydrogeologic units with accompanying lithologic descriptions near Gaines, Terry and

Yoakum Counties, Texas	26

Table 4 - Gas Composition of 30-30 Facility outlet	31

Table 5 - Modeled Initial Gas Composition	33

Table 6 - CMG Model Layer Properties	34

Table 7 - All Offset SWDs included in the model	36

Table 8 - All Offset Producers included in the model	36

Table 9 - Groundwater Well Summary	50

Table 10 - Summary of Leakage Monitoring Methods	54

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SECTION 1 - FACILITY INFORMATION

This section contains key information regarding the Acid Gas and C02 injection facility.

Reporter number:

•	Gas Plant Facility Name: 30-30 Gas Plant

•	Greenhouse Gas Reporting Program ID: 574501

o Currently reporting under Subpart UU

•	Operator: Stakeholder Gas Services, LLC

Underground Injection Control (UIC) Permit Class: Class II

The TRRC regulates oil and gas activities in Texas and has primacy to implement the Underground Injection
Control ("UIC") Class II program. TRRC classifies the Rattlesnake AGI #1 well as a UIC Class II well. A Class II
permit was issued to Stakeholder under TRRC Rule 9 (entitled "Disposal into Non-Productive Formations")
and Rule 36 (entitled "Oil, Gas, or Geothermal Resource Operation in Hydrogen Sulfide Areas").

UIC Well Identification Number:

Rattlesnake AGI #1, API No. 42-501-36998, UIC #000117143.

8


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SECTION 2 - PROJECT DESCRIPTION

This Project Description discusses the geologic setting, planned injection volumes and process, and the
reservoir modeling performed for the Rattlesnake AGI #1 well. The Class II UIC permit was initially applied
for and received by Santa Fe Midstream Permian, LLC. The asset was acquired in 2020 by Stakeholder and
has been in operation since that time. Since the original application, Lonquist has revised and updated the
geology and the plume modeling within the reservoir in preparing this MRV Plan.

The Rattlesnake AGI #1 well is located and designed to protect against migration of C02 out of the injection
interval and to prevent surface releases. The injection interval for Rattlesnake AGI #1 is located over 4,720'
below the primary producing formation, the San Andres, in the area and 8,593' below the base of the lowest
useable quality water table, as shown in Figure 2. This well injects both H2S and C02, therefore the well and
the facility are designed to minimize any leakage to the surface.

STAKEHOLDER
TREATING & PROCESSING
PLANT

2,450'

LOWEST
WATER TABLE
DEPTH

5,500'

CASING DEPTH

Casing consists of
reinforced steel
and concrete

11,000'

INJECTION WELL
DEPTH

>8,500'

BELOW THE
WATER TABLE

Figure 2 - Illustrative overview of Rattlesnake AGI tt1 and 30-30 Facility

9


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Regional Geology

The Rattlesnake AGI #1 well is located on the southern portion of the Northwestern Shelf within the larger
Permian Basin as seen in Figure 3. The Northwestern Shelf is a broad marine shelf located in the northern
portion of the Permian Basin,

Basin

Matador Arch

Eastern
Shelf

f..	NEW MEXICO

Jtexas |
Delaware'^
Basin \

Ozona
, Arch

>Val Verde
' Basin

.Ouach/h
NJ

NEW
MEXICO

		WO ml

100 Km

I I Permian Basin

Figure 3 - Regional Map of the Permian Basin. Red Star is approximate location of Rattlesnake AGI #1 well

Figure 4 depicts the stratigraphic column found at the Rattlesnake AGI #1 well location with red stars
referencing the injection formation and green stars indicating the productive intervals in the area. The
primary injection interval is found within the Wristen group, of Silurian-age, as seen in Figure 5. The TRRC
refers to this sequence under the general terms "Devonian", "Silurian-Devonian" or "Siluro-Devonian".

10


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Period

Epoch

Formation

General Lithology

Permian

Ochoan

Dewey Lake

Redbeds/Anhydrite

Rustler

Halite

Salado

Halite/Anhydrite

Guadalupian

Tansil

Anhydrite/Dolomite

Yates

Anhydrite/Dolomite

Seven Rivers

Dolomite/Anhydrite

Queen

Sandy Dolomite/Anhydrite/Sandstone

Grayburg

Dolomite/Anhydrite/Shale/Sandstone

Leonardian

~ San Andres

Dolomite/Anhydrite

Glorieta

Sandy Dolomite

Yeso

Paddock

Dolomite/Anhydrite/Sandstone

Blinebry

Tubb

Drinkard

Abo

Dolomite/Anhydrite/Shale

Wolfcampian

^ Wolfcamp

Limestone/Dolomite

Pennsylvanian

Virgilian

Cisco

Limestone/Dolomite

Missourian

Canyon

Limestone/Shale

Des Moinesian

Strawn

Limestone/Sandstone

Atokan

Bend

Limestone/Sandstone/Shale

Morrowan

Morrow

Mississippian



Mississippian Lime

Limestone

Devonian



Woodford

Shale

Silurian



-^Wristen Group

Dolomite/Limestone



^ Fusselman

Dolomite/Chert

Ordovician

Upper

Montoya

Dolomite/Chert

Middle

Simspson Gp

Limestone/Sandstone/Shale

Lower

Ellenburger

Dolomite

Figure 4 - Stratigraphic column of the North west Shelf. Red stars indicate injection interval. Green stars indicate productive

intervals.


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Mississippian

Chesterian

undivided

Meramecian

Osagian



Kinderhookian

Devonian

Upper

Woodford Shale



Middle

Lower

Thirtyone Fm.

Silurian

Pridolian

Wristen Gp.

~

Fasken
Fm.

Frame Fm.

Ludlovian

Wink Fm.

Wenlockian

Llandoverian



Fusselman Fm.

Ordovician

Upper

Montoya Fm.

Simpson Gp.

Middle

Lower

Ellenburger Fm.

Figure 5 - Stratigraphic column depicting the composition of the Silurian group. Red star indicates injection interval (Broadhead,

2005)

The Wristeri group was deposited in a basin platform setting across the northern half of the Permian Basin.
The depositional environment over Yoakum County during the Silurian period was a shallow inner platform,
the margin of which exists to the south, in southern Andrews County, Texas. The Silurian-age lithology on
the inner platform is dominated by grain-rich skeletal carbonates. Carbonate buildups are common within
the shallow inner platform, mainly skeletal wackestone, indicating a lower-energy deposition on the inner
platform. The carbonate shelf margin to the south acted as a barrier from basin-ward wave energy (Ruppel
and Holtz, 1994).

Depositional cycles within the inner platform indicate it was controlled by episodic sea level rise and fail,
resulting in sub-areal exposure and diagenesis. The diagenesis of the Silurian-age carbonate rocks initiated

12


-------
secondary porosity development and increased permeability. Dolomite and solution-related features are the
most prominent diagenetic characteristics found within the Silurian. The Wristen Group is composed of three
formations: Fasken, Frame, and Wink formations. The Frame and Wink formations are found near the ramp
boundary to the south, while the Fasken formation is found predominantly in the inner platform, where the
Rattlesnake AGI #1 well is located. The Fasken formation is predominately dolomite grading to limestone,
occurring as cycles, down section. This dolomitization is due in part to sub-areal exposure, during which
karsts and secondary porosity developed. Additional dolomitization was possible during successive sea level
fluctuations via movement of magnesium-rich solution through karsts and vugs, which acted as channels for
fluid flow (Ruppel and Holtz, 1994).

Figure 6 shows a regional isopach map of the Silurian (combined Fasken and Fusselman formations) with a
red star depicting the Rattlesnake AGI #1 well location. Thickness of the Silurian-age rock is approximately
1,000' at the Rattlesnake AGI #1 well location.

North of Andrews County there is little differentiation between the Fasken and Fusselman formations which
are both carbonate deposits with the potential for sub-areal exposure and porosity development. For
purposes of this MRV Plan, the combined Fasken and Fusselman formations are defined as the injection
interval, and the underlying Montoya formation serves as the lower confining unit.

13


-------


ThjChMSJ (ft)

W'Uin plait ttf iM'tm

M«l$COC« |4?t«U«IS

wiOtAI

4.0*1*4

Ttm

S kM>M

c«o«rTT

Figure 6- Thickness map of the Silurian system which composes the Fusselman and Wristen group

14


-------
Regional Faulting

A major uplift that began during the Pennsylvanian Period to the south, the Central Basin Platform, ceased
in the Early Permian (Wolfcampian), which caused a regional unconformity of the underlying formations
(Hoak, Sundberg, and Ortoleva). Faulting on the Northwest Shelf can be seen through high angle basement
faults that tend to die within the Pennsylvanian strata. These faults predominately represent contractional
(thrust) faults that were initiated during the Pennsylvanian as a result of regional tectonics. Hydrocarbon
traps within the Wristen group are primarily anticlinal structures dependent upon reservoir development
(Broadhead, 2005).

Site Characterization

The Rattlesnake AGI #1 well is located in Section 733, Block D, John H. Gibson Survey, in Yoakum County,
Texas. Stakeholder owns the 82.42-acre surface tract where the plant and Rattlesnake AGI #1 well are
located. The following discusses the geological character of this site.

Stratigraphy and Lithologic Characteristics

Figure 7 depicts an open hole log from an offset well (API No. 42-501-10238) to the Rattlesnake AGI #1 well
indicating the injection and primary upper confining zone. This well is approximately 1.8 miles to the
northwest of the Rattlesnake AGI #1 well, An offset well log was used to depict the upper confining intervals
as electric logs were only run in the Rattlesnake AGI #1 well across the injection zone.

15


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Upper Confining Interval - Woodford Shale

The Woodford is a late Devonian-age organic-rich shale deposited as a result of a widespread marine
transgression. The flooding event occurred over the majority of the Permian basin, which produced a low-
relief blanket-like shale deposit of the Woodford. Two major lithofacies found within the Woodford are black
shale and siltstone. Nutrient-rich surface waters promoted the decay of abundant organic matter within the
Woodford, resulting in a high total organic carbon ("TOC") percentage. The Woodford shale acts as the
primary source and sealant rock for the Wristen Group (Comer, 1991).

Figure 8 is a description of a core sample taken in Lea County, New Mexico just southwest of the Rattlesnake
AGI #1 well location. This sample is referenced as C9 in the reference map with the blue star representing
the Rattlesnake AGI #1 well. In the core description, black shale with abundant illitic clays is observed in the
upper section, and medium gray dolomitic siltstone found in the basal section. The mineralogic and lithologic
properties recorded in this description serve as excellent sealant characteristics to prohibit any injected fluids
from migrating above the injection interval.

The Woodford at the Rattlesnake AGI #1 well location is encountered at 10,973 ft and is approximately 63 ft
thick.

C9

Shell No. 5 Pacific Royalty
Lea County, New Mexico
Section 10.T15S-R37E
		Elevation 3814 ft

X

Q

TOC

Weight
percent

1 2 3 4 5
—I	I	I	I	L_

GR i

C9 5

cs s

C9 7

Description

(ft)

35+
-12.200

Medium* to dark-gray limestone Lime mudstone with a few thin beds of brachiopod
wackestone and skeletal and pellet grainstone Some intervals highly fractured; all
fractures are filled, some with calcite, some with silica. Lowor contact not
preserved, probably conformable.	

Green limestone. Clay rich. Lower contact not preserved, probably disconformablo.

Black shale. Parallel laminae Abundant fllitic clay; pyritic. Scattered grains of sift*
sized quartz, dolomite, and mica. Spores scattered or concentrated in thin laminae,
some spores replaced by pyrite, some by carbonate; sparse laminao of Radiolana;
rare burrows filled by chert, carbonate, and anhydrite Scarce veinlets filled with
calcite. Lower contact not preserved, probably conformable and abruptly gradatiorial.

I

| Boii»y	

•Cochron

JRqCtMT

Medium-gray dolomitic siltstone. Abundant silt-sized anhedral and subnedral dolomite;
s»lt-sized quartz common Interbedded and interlaminated dark-gray shate and
medium-gray line-grained catcite grainstone, packs tone, and lime mudstone Wavy to
discontinuous bods near top; becomes more discontinuous, contorted, and mottled
downward; shales have parallel to wavy laminae. Pyritjc; micacoous. Sparse burrows;
rare Lmgula and wood fragments. Grades downward into lighter gray dolomitic
siltstone with fewer shale inter bods Lower contact not preserved, probably
disconfonrtablo.

Pale brownish pink crystalline dolostone. Vuggy.

^Medium-gray shale. Dolomitic; silty.

69+

Pale brownish-pink crystalline dolostone Vuggy.

»-12,400

l£	

| Y00hum

I

I

I ~

' Coirct

Figure 8- Core description of the Woodford Shale and Upper Silurian (Ruppel and Holtz, 1994)

16


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Injection Interval - Fasken Formation

The Rattlesnake AGI #1 well reaches total depth in the Fasken/Fusselman formation (Silurian in age), directly
below the Woodford formation. Dolomites at the top of the Fasken formation underwent multiple leaching
and diagenetic episodes which developed secondary porosity. This is evidenced in offset wells by the practice
of only drilling through the top 30' of the Fasken, in anticipation of encountering the best reservoir quality.
In Figure 8, the uppermost Silurian section is described as 'vuggy dolostone' in the core description. Beds
below the top of the Fasken section may also have similar petrophysical attributes if exposed to multiple
diagenetic events. Solution-collapse and karst breccia horizons can be found within inner platform deposits,
some occurring as much as 100 ft below the Fasken top (Ruppel and Holtz, 1994).

Porositv/Permeabilitv Development

Porosity in the Fasken formation at the Rattlesnake AGI #1 well location is typically moldic and intercrystalline
associated with leaching of allochem-rich intervals. Porosity is directly related to these leaching events which
occurred during and post-deposition, resulting in vugs and karst-like features. Figure 9 provides reservoir
information from core data within fields in the Wristen buildup and platform carbonate play. The average
porosity of these cores is 7.1% with an average permeability of 45.28 millidarcies (Ruppel and Holtz, 1994).
The porosity and permeability described in the offset core data indicate the Fasken formation provides
sufficient accessible pore space for the amount of fluid injection proposed.

Using the above values as reference points, the Rattlesnake AGI #1 porosity log (API No. 42-501-36998) was
evaluated. Figure 10 is the product of the petrophysical analysis performed on the open hole logs run within
the injection interval at the Rattlesnake AGI #1 well. A permeability curve was generated from the effective
porosity curve using the table in Figure 9 to establish the porosity-permeability relationship. In Figure 10,
the majority of the injection interval's porosity and permeability is found at the top of the Fasken formation,
which correlates with the diagenetic processes described above. These curves are extrapolated to the
injection site and used to establish reservoir characteristics in the plume model.

17


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Wristen







Fusselman

Buildups and

Thirtyone

Thirtyone



Shallow Platform

Platform

Ramp

Deep-Water



Carbonate play

Carbonate play

Carbonate play

Chert play



Porosity (%>





Numbe/ o' data points

33

30

16

35

Mean

7,93

7. to

e.4i

14,85

Mnimum

1.00

2.70

3.50

2.00

Maximum

17,70

14.00

0.50

30.00

Standard devation

4.01

2.67

1.75

6.76



Permeability (md)





dumber ot (Jala points

21

24

12

33

Mean

11.61

45.28

1.51

9.56

Minimum

0.60

2.90

0.40

1.00

Maximum

84.80

400.00

30.00

100.00

Standard deviation

22.48

99.17

8.36

22.23



Initial water saturation {%)





Number oi data points

24

28

10

31

Mean

26.96

31.55

24.70

31.46

Mmmnum

10.00

20.00

16.00

10.00

Maximum

50.00

55.00

40.00

45.00

Standard deviation

9.31

10.4b

7.39

8.33



Residua) oil saturation {%)





Number a', data points

8

13

5

22

Mean

34.06

30.54

21.30

29.17

Minimum

30.00

20.00

9.00

14.00

Maximum

50.00

35.00

35.00

48.20

Standard devation

6.99

4.61

11.66

9.76



Oil viscosity (op)





Number oi data points

11

12

5

21

Mean

0.69

1.10

0.33

0.68

Mrnmum

0.13

0.32

0.04

0.07

Maximum

1.08

2.00

1.00

1.03

Standard devation

0.81

0.75

0.40

0.42



Oil formation volume factor





Number oi data points

21

22

6

32

Mean

1.57

1.22

1.65

1.50

Mnirnum

1.05

1.05

1.31

1.30

Maximum

1.91

1.55

1.66

1.73

Standard deviation

0.28

0.14

0.48

0.16



Bubble-point pressure (psi)





Number of data points

9

9

5

19

Mean

2.272

1,055

3.750

2.752

Minimum

798

450

2.660

1.755

Maximum

4.C50

2,600

4,440

4.655

Standard devation

1.300

689

756

667











Figure 9 - Table of reservoir properties found within the Wristen buildups and platform plays (Ruppel and Holtz, 1994)


-------
Low Perm

42501369980000
RATTLESNAKE AG I
1

STAKEHOLDER GAS SERVICES

0

[PLJ]=11036.9

Figure 10- Rattlesnake AG I #1 open hole log (42-501-36998) with effective porosity (green) and permeability (black)

Formation Fluid

Four wells were identified through a review of chemical analyses of oil-field brines from the U.S. Geological
Survey National Produced Waters Geochemical Database v2.1 within the Devonian, Silurian-Devonian, or
Fusselman formations within 20 miles of the Rattlesnake AGI #1 well. The location of these wells is shown in
Figure 11. Water chemistry analyses conducted on oil-field brines in Gaines County, as reported to the Texas

19


-------
Water Development Board, provided additional data on Devonian and Silurian reservoir fluids. Results from
the synthesis of these two sources are provided in Table 1. The fluids have greater than 20,000 parts per
million ("ppm") total dissolved solids, therefore these aquifers are considered saline. These analyses indicate
the in-situ reservoir fluid of the Devonian, Silurian, and Fusselman formations are compatible with the
proposed injection fluids.

Figure 11 - Offset wells used for Formation Fluid Characterization

Table 1 - Analysis of Silurian-Devonian age formation fluids from nearby oil-field brine samples



Average

Low

High

Total Dissolved Solids (ppm)

41,428

23,100

55,953

pH

7,2

7.0

7.3

Sodium (ppm)

12,458

7,426

15,948

Calcium (ppm)

1,759

1,010

2,320

Chlorides (ppm)

23,423

12,810

31,930

Fracture Pressure Gradient

Fracture pressure gradient was estimated using Eaton's equation. Eaton's equation is commonly accepted
as the standard practice for the determination of fracture gradients. Poisson's ratio ("v"), overburden
gradient ("OBG"), and pore gradient ("PG") are all variables that can be changed to match the site-specific
injection zone. Through literature review and industry standards, we are able to determine the expected

20


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fracture gradient. First, 1.05 psi/ft and 0.465 psi/ft were assumed for both the overburden and pore
gradients, respectively. These values are considered best practice values when there are no site-specific
numbers available. For limestone/dolomite rock, the Poisson's ratio to be assumed to be 0.3 through
literature review (Molina, Vilarras, Zeidouni 2016). Using these values in the equation below, a fracture
gradient of 0.72 psi/ft was calculated. A 10% safety factor was then applied to this number resulting in
maximum allowed bottom hole pressure of 0.64 psi/ft. This was done to ensure that the injection pressure
would never exceed the fracture pressure of the injection zone.

For the upper confining interval, a similar fracture gradient as the limestone was calculated. Shale has an
increased chance to vertically fracture if the injection interval is fractured (Molina, Vilarras, Zeidouni 2016),
so assuming a Poisson's ratio equal to the injection interval was used as a conservative estimate. The lower
confining zone was assumed to be of a similar matrix to that of the injection interval, with the key difference
being that the formation is much tighter (lower porosity/permeability). The Poisson's ratio was assumed to
be slightly higher in this rock. As seen in Table 2, the fracture gradient is slightly higher than the upper zones.

Table 2 - Fracture Gradient Assumptions



Injection Interval

Upper Confining

Lower Confining

Overburden Gradient (psi/ft)

1.05

1.05

1.05

Pore Gradient (psi/ft)

0.465

0.465

0.465

Poisson's Ratio

0.30

0.30

0.31

Fracture Gradient psi/ft

0.72

0.72

0.73

FG +10% Safety Factor (psi/ft)

0.64

0.64

0.66

The following steps were taken to calculate fracture gradient:

FG = —-—(OBG - PG) + PG
1 — v

0.3

FG = 1_Q3(1-05 - °-465) + °-465 = °-72
FG with SF = 0.72 x (1 - 0.1) = 0.64

Lower Confining Zone - Montoya Formation

The low-permeability Montoya Formation is a tight limestone/dolomite that will act as the lower confining
unit for the injection interval. Figure 10 shows the decreasing trend in porosity of the limestone rock in the
lower section that was not exposed to leaching diagenesis. Porosity in the lower section can range from 2-
3% with permeabilities below 1 millidarcy. The Rattlesnake AGI #1 well drilled 6' into the Montoya formation,
but the section was not logged. The Montoya is anticipated to be roughly 250' thick. These petrophysical
characteristics represent ideal sealing properties to prohibit any migration of injected fluid outside of the
injection interval.

Local Structure

Regional structure in the area of the Rattlesnake AGI #1 well is dictated by carbonate buildups and structural
events causing anticlinal to synclinal features throughout the area. The Rattlesnake AGI #1 well is specifically
located at the base of a syncline with anticlinal features to the northeast, south, and east. Figure 12 is a

21


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structure map of the Silurian formation of subsea depths with the star representing the location of the
Rattlesnake AGI #1 well. The red and blue lines represent the cross-section reference lines.

Faulting can be seen to the south and east of the Rattlesnake AGI #1 well location. These faults were
interpreted from roughly 9 square miles of 3D seismic indicated by the purple outline in Figure 12. Many of
these faults are minor, with offsets less than 50'. The nearest large fault is found southeast of the Rattlesnake
AGI #1 well and has an offset of roughly 120'. None of these faults project above the Wolfcamp formation,
rather, they appear to terminate between the Strawn and base of the Wolfcamp formation. Production is
associated with a hydrocarbon trap set up by the larger fault to the southeast, indicating the fault is vertically
sealing in nature. If, in the unlikely event the faults' sealing properties are compromised post-injection,
secondary confinement is provided by the tight limestones found within the overlying Mississippian Lime
formation along with shale layers found in the Atoka and Wolfcamp formations. As seen in Figure 14, the
largest fault found southeast of the Rattlesnake AGI #1 well, terminates within the Atoka formation. Though
it crosses the Silurian section, this fault thrusts the Mississippian Lime upward against the Atoka shales. The
tight reservoir characteristics of the Mississippian Lime and shaley section of the Atoka create a confining
environment vertically and laterally to contain potential upward migration of buoyant fluids. Shales within
the Wolfcamp formation provide additional confining beds between overlying USDWs and the fault plane.
Figures 13 and 14 are north-south and west-east structural cross sections showing the structural dips. As
seen in these figures, the Woodford formation is laterally present above the injection interval, alleviating risk
of erosion of the upper sealant formation.

Larger versions of Figures 11, 12, 13 and 14 are provided in Appendix A.

22


-------

-------

-------
NW

3T?w'

42501105700000
1-667

TEXAS CRUDE OIL CO
+

<14,201 FT>

42501369980000
RATTLESNAKE AG I
1

STAKEHOLDER GAS SERVICES



42501358340000
ROBERTS UNIT
2

APACHE



42501335110000
CORNELL UNIT

3019D
EXXON MOBIL

SE

asr

MONTOYA [PUJ

25


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Injection and Confinement Summary

The lithologic and petrophysical characteristics of the Faskeri and Fusseiman formations at the Rattlesnake
AGI #1 well location indicate the formations have sufficient thickness, porosity, permeability, and lateral
continuity to accept the proposed injection fluids. The Woodford formation shale at the Rattlesnake AGI #1
well has low permeability and is of sufficient thickness and lateral continuity to serve as the upper confining
zone. Beneath the injection interval, the low permeability, low porosity Montoya formation is unsuitable for
fluid migration and serves as the lower confining zone. Deeper, laterally continuous formations, including the
Simpson Group, provide additional confinement.

Groundwater Hydrology

Yoakum County falls within the boundary of the Sandy Land Underground Water Conservation District. Three
aquifers are identified by the Texas Water Development Board's Aquifers of Texas report in the vicinity of the
proposed Rattlesnake AGI #1 well: the Dockum Aquifer, Edwards-Trinity Aquifer, and Ogallala Aquifer
(George, Mace and Petrossian, 2011). Table 3 references the aquifers' positions in geologic time and the
associated geologic formations. A schematic cross section in Figure 15, near the proposed Rattlesnake AGI
#1 well, illustrates the structure and stratigraphy of these water-bearing formations. Groundwater flow
direction is the same for the three aquifers, generally from northwest to southeast, Figure 16 (Teeple, et al.,
2021).

Table 3 - Geologic and hydrogeologic units with accompanying lithologic descriptions near Gaines, Terry and Yoakum Counties, Texas
(Teeple, et al. 2021)

Era

Period

Epoch or series

Geologic unit group
or formation

Lithologic descriptions

Hydrogeologic unit

Cenozoic

Tertiary

Pliocene

Ogallala Formation

Gravel, sand, silt,
and clay

High Plains
aquifer system
(Ogallala aquifer)

Miocene

Mesozoic

Cretaceous'

Comanchean
Series

Washita Group2

Shale and limestone

Edwards-T rinity
(High Plains)
aquifer system

Fredericksburg Group

Clay, shale, and
limestone

Trinity Group

Sand and gravel

Triassic

Upper

Dockum Group

Sillstone, mudstone,
shale, and sandstone

Dockum aquifer

26


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Figure 15- NW-SE Cross Section of aquifers in the Rattlesnake AG! #1 well area (George, Mac and Petrossian, 2011)

27


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IOCKLEV COI NTY 8 103°0'
/ •

HOC KLEV COl.Vn

"J	\^J! In* • •• •Hv4. •

V , " •. A " *

r I J ' *1 nnvaJ^Sil'

/ • • t / • 'I** *	i» 1

K.-.'- l\i^\\s>* I

lY\ 3| ~7	. 1

/ ' <8 jX • /• *> / ~**. i' >!

[ <. OTvKsl ,. • ,

icuiNfu" fr;—7

i	if _ \ »V*^r"

C 1Q3°D'	,K

rrir

33°20' I

I ~
L-'

Y0AKUM
»v \ | x COUNTY

©#xr /

/ fMiu \ ~'

y .<

l«s

f Mjch

\ / n*L"IMkt jif

v^'	(

ftpy ' ' v x liruu^lfcUi x

~ ' j

artr'

32"4G'

-HOCKLEY COUNTY

0	5 10 (SMILES

1	. 1 r i1	1

0 5 tO T5 KILOMETERS

Base modified tram U S Geological Survey 1 250 000-scale to 1 2,000.000-scale digital data.
Universal Transverse Mercator projection, ione 13
North American Datum of 15&3

Groundwater-level altitude, in
leal above North American
Vertical Oatum of 1988

|^m" >3,750

Hj- 3,500

3,250

3,000

<2,750

EXPLANATION

Study area boundary

Edwards-Trinity I High Plains} nquilor downdip enfant
Underground water conservation district boundary

Llano Estacado Underground Water Conservation District
Sandy Land Underground Water Conservation District
South Plains Underground Water Conservation District

Potenriometric contour Shows altitude at
which water level would have stood in
tightly cased wells. Contour interval is
100 feel Datum it North American
Vertical Datum of 1988 Dashed where
mlerred.

Groundwater How pallia Dashed where
interred

• Groundwater tevol measurement (Payne
and others. 2020)

Figure 16 - Potentiometric surfaces from wells completed in A, Ogallala aquifer, B, the Edwards-Trinity aquifer and C, the Dockum
aquifer (George, Mace and Petrossian, 2011).

The Dockum Aquifer is the oldest of the three aquifers, formed from Triassic-age Dockum Group sediments,
and underlies the Cretaceous Trinity and Fredericksburg Groups (Teeple, et al., 2021). Figure 17 shows the
subsurface and outcrop extent of the Dockum Aquifer. As shown in Figure 18, the total dissolved solids in
western Yoakum County exceed 5,000 milligrams per liter ("mg/L"), therefore the aquifer is considered
brackish.

28


-------
Dockum

Aquifer

Figure 17 - Regional extent of the Dockum freshwater aquifer (TWDBj

Figure 18 - Total dissolved solids in groundwater from the Dockum Aquifer (Ewing et at, 2008)

The Edwards-Trinity Aquifer is a collection of Cretaceous age sediments - primarily the Trinity Group Antlers
formation sandstone and limestones of the Fredericksburg Group, specifically the Comanche Peak and
Edwards formations. Figure 19 shows the subsurface and outcrop extent of the Edwards-Trinity Aquifer.
Freshwater infiltration to this aquifer is primarily from the overlying Ogallala Aquifer (George, Mace and
Petrossian, 2011).

29


-------
The Ogallala aquifer consists of sand, gravel, clay and silt sediments (George, Mace and Petrossian, 2011) and
produces the majority of the freshwater for Yoakum County. Figure 20 shows the subsurface and outcrop
extent of the Ogallala Aquifer.

The base of the deepest aquifer is separated from the injection interval by approximately 8,600' of rock,
including 576' of Salado salt. Though unlikely for reasons outlined in the confinement and potential leaks
sections, if migration of injected fluid did occur above the Woodford Shale, thousands of feet of tight
sandstone, limestone, shale, salt and anhydrite beds occur between the injection interval and the lowest
water-bearing aquifer.

30


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The TRRC's Groundwater Advisory Unit ("GAU") identified the base of Underground Sources of Drinking
Water ("USDW") at 375' at the location of the Rattlesnake AGI #1 well. Therefore, there is approximately
10,661' separating the base of the USDW and the injection interval. A copy of the GAU's Groundwater
Protection Determination letter issued by the TRRC as part of the Class II permitting process for the
Rattlesnake AGI #1 well is provided in Appendix B.

Description of the Injection Process
Current Operations

The 30-30 Facility and its associated Rattlesnake AGI #1 well began operating in March of 2019. Since
operations began, 258 million cubic feet ("MMCF") of treated acid gas ("TAG") has been injected, which
equates to 12,316 metric tons of C02. Over the life of the injection period, the average daily injection rate
has been 223 MSCF/d. The approximate current composition of the TAG stream is as follows;

Table 4 - Gas Composition of 30-30 Facility outlet

Component

Mol %

C02

89.68%

H2S

9.20%

Other

1.12%

31


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The 30-30 Facility is designed to compress, treat, and process natural gas produced from the surrounding
counties in Texas and New Mexico. The gas is dehydrated to remove the water content, then processed to
separate natural gas liquids which are then sold, along with the pipeline quality natural gas, to various
customers. TAG is then directly routed from the plant amine regen system to the Rattlesnake AGI #1 well.
The facility is manned 24 hours per day, 7 days per week.

Planned Operations

Stakeholder anticipates increasing the amount of CO2 injected into Rattlesnake AGI #1 well from the current
rate up to 16 MMSCF/d. Additional growth is expected both at Stakeholder facilities and regionally as rising
sour gas production and flaring reduction mandates create the need for additional CO2 and H2S disposal
capacity. Stakeholder plans to inject into this AGI well for another 14 years for a total of 17 years from the
start of injection in 2019.

Figure 21 shows a high-level view of the current process flow plus the prospective additional operations over
time.

Amine Regen
System

>96% C02
1,090-1,150 psig

CO, Offta ke

13% H2S, 87% COj
1,400-2,200 psig

AGI
Compression

Prospective Facilities

Meter

er XV

Meter

&

XV

A

l_
"l
I

-L

596-13% HjS, 87%-

95% C02
1,400-2,500 psig

Injection
Pumps

XV

Current Operation

AGI
Well

Figure 21 - 30-30 Facility Process Flow Diagram

Reservoir Characterization Modeling

The modeling software used to evaluate this project was Computer Modelling Group's GEM 2020.11 ("GEM")
simulator. Computer Modelling Group ("CMG") has put together one of the most accurate and technically
sound reservoir simulation software packages for conventional, unconventional, and secondary recovery.
GEM utilizes equation-of-state ("EOS") algorithms along with some of the most advanced computational
methods to evaluate compositional, chemical, and geochemical processes and characteristics to produce
highly accurate and reliable simulation models for carbon injection and storage. The GEM model is
recognized by the EPA for use in area of review delineation modeling as listed in the Class VI Well Area of
Review Evaluation and Corrective Action Guidance document.

The Silurian (Fasken/Fusselman) formation is the target formation for Rattlesnake AGI #1 well. The Petra
software package was used to create the geologic model of the target formation. The faulting and geologic
structure was then imported into GEM and used to create contours for the model grid.

Porosity and permeability estimates were determined using the porosity log from the Rattlesnake AGI #1
well and a petrophysical analysis was performed to correlate porosity values by depth with core porosities

32


-------
as shown in the Holtz paper. The Coates permeability equation was then used to calculate permeability with
depth. Both porosity and permeability are assumed to be laterally homogeneous in the reservoir.

The reservoir is assumed to be at hydrostatic equilibrium and initially saturated with 100% brine. An infinite
acting reservoir was created to simulate boundary conditions. The gas injectate is composed of H2S, CO2,
CH4, and other components as shown in Table 5. Core data from literature review was used to determine
residual gas saturation (Ruppel and Holtz, 1994). The modeled composition only takes into consideration the
carbon dioxide and hydrogen sulfide as they comprise nearly 99% of total stream. For the initial injection
period, these compositions are normalized up to 100%. For the proposed additional injection period, it is
expected that a larger portion of the gas added is carbon dioxide, changing the composition to ~93% CO2 and
~7% H2S.

Table 5 - Modeled Initial Gas Composition



Measured Current

2019-2024 Model

2024-2036 Model

Component

Composition (mol%)

Composition (mol%)

Composition (mol%)

Carbon Dioxide (C02)

89.678

90.696

92.921

Hydrogen Sulfide (H2S)

9.200

9.304

7.079

Methane (CI)

0.303

0

0

Ethane (C2)

0.058

0

0

Propane (C3)

0.108

0

0

N-Butane (NC4)

0.025

0

0

Hexane Plus (C6+)

0.628

0

0

Core data from literature review was used to determine relative permeability curves between carbon dioxide
and the connate brine within the Silurian-Devonian carbonates (Ruppel and Holtz, 1994). The key inputs
used in the model include an irreducible water saturation of 25% and a maximum residual gas saturation of
21%.

The grid contains 141 blocks in the x-direction (E-W) and 201 blocks in the y-direction (N-S), totaling 28,341
grid blocks per layer. The grid blocks are each 150' by 150' by layer thickness as specified in Table 6. This
results in the grid being 21,150' by 30,150' totaling just over a 23-square mile area (14,640 acres). Each layer
in the model was determined by identifying higher permeability zones as targets for injection from the logs
and assigning each high permeability and intermediary low permeability zone its own layer. One zone was
identified as being a karst limestone (layers 2-7). Due to the "karsted" nature of this rock, it was determined
that most of the injectate would flow into this zone. Therefore, the karst limestone was further split into
layers by permeability to provide higher resolution and more accurately simulate which layer will have more
gas flow into it. Figure 22 provides a detailed breakdown of the "karsted" rock.

33


-------
Permeability Distribution of Karst Zone

2

3

4

l—

(D
_l

5

6

7

1	10	100	1000

Permeability (mD)

Figure 22 - Permeability Distribution of Karst Limestone

In total, there are sixteen (16) layers in the model, representing ten (10) layers of pay and six (6) layers of
intermediary low permeability zones. The properties of each of these layers are summarized in Table 6
below.

Table 6 - CMG Model Layer Properties

Layer #

Top (ft)

Thickness (ft)

Permeability (mD)

Porosity

1

11,037

71

1

2.8%

2

11,108

57

47

8.0%

3

11,165

19

223

11.9%

4

11,184

16

15

6.3%

5

11,200

39

70

9.2%

6

11,238

11

228

12.3%

7

11,249

21

49

8.3%

8

11,270

251

2

3.7%

9

11,520

46

9

5.6%

10

11,566

13

3

4.3%

11

11,579

19

17

6.5%

12

11,597

14

2

3.9%

13

11,611

103

13

6.0%

14

11,714

46

2

3.7%

15

11,759

67

23

6.1%

16

11,826

125

2

3.6%

34


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Simulation Modeling

The primary objectives of the model simulation were to:

1)	Estimate the maximum areal extent and density drift of the acid gas plume after injection

2)	Assess the impact of offset saltwater disposal ("SWD") well injection on density drift of the plume

3)	Assess the impact of offset producing wells on the density drift of the plume

4)	Determine the ability of the target formation to handle the required injection rate without
fracturing the injection zone

5)	Assess the likelihood of the acid gas plume migrating into potential leak pathways

The reservoir is assumed to be an aquifer filled with 100% brine. The salinity of the formation is estimated
to be 53,000 ppm (Texas Water Development Board, 1972). The acid gas stream is primarily composed of
C02 and H2S as stated previously. Core data was used to help generate relative permeability curves. Cores,
from the literature reviews previously discussed, that most closely represent the vuggy carbonate seen in
this region were identified and the Corey-Brooks equations were used to develop the curves. The lowest
residual gas saturation found in the cores was then used for a conservative estimate of plume size. From
offset injection well analysis, the initial reservoir pressure was determined to be 5,132 psi which is equivalent
to a 0.465 psi/ft pressure gradient. The fracture gradient of the injection zone was estimated to be 0.72
psi/ft, which was determined using Eaton's equation. A 10% safety factor was then applied to this number,
putting the maximum bottom-hole pressure allowed in the model at 0.64 psi/ft which is equivalent to 7,064
psi.

The model also takes into account offset saltwater disposal ("SWD") injection volumes within five (5) miles
of the Rattlesnake AGI #1 well. These SWDs create a pressure front that push the plume further up-dip of
the formation. A total of twenty (20) offset wells currently injecting into the target formation were identified.
Eleven (11) of these offset SWDs were out of the confines of the grid, but were still accounted for in the
model. Nine (9) salt-water disposals were modeled within the boundaries of the 23-square-mile grid. Two
(2) of these offset injectors are currently only permitted (not drilled) but were assumed to start active
injection within the first year of the model. Both permits were simulated at the forecasted injection rate
schedule for 30 years. These forecasts were provided by the operators of these wells. Historical injection
rates of each of the other existing wells were analyzed and projected into the model. This simulation includes
the effect of water injection on the density drift of the plume and bottom hole pressure.

Further review of the area revealed production wells in the Silurian-Devonian formation that could impact
the density drift of the plume by creating a "pressure sink". A "pressure sink" is an area of lower pressure
caused by the production of formation fluids. To simulate this effect, nine (9) production wells were grouped
together and their respective production rates combined into a single well to add more conservatism into
the model. These producers were forecasted an additional 15 years to simulate their potential economic
lifespan. This simulation includes the effect of fluid production on the density drift of the plume and bottom
hole pressure. Overall, the "pressure sink" has little effect on the density drift and, as discussed below, the
plume never reaches the producing wells.

The model runs for a total of 814 years, starting in 1965 with the beginning of offset production until the
calculated stabilization of the plume in 2779. The injection of TAG from Rattlesnake AGI #1 is modeled from
the beginning of injection in 2019 through the planned 14 years of future injection. The model also includes
the 57 years of historical plus 15 years of forecasted future oil and gas production.

Additionally, historical monthly injection rates of all nearby SWDs were incorporated into the model to
simulate any additional near-wellbore pressure increase that may occur due to offset injection. The

35


-------
modelling of the saltwater injection begins in 1984 when the first offset SWD well became operational. The
SWDs to the North were grouped into four (4) separate groups to simulate their combined effect on the
density drift of the plume. All offset injection wells and their groupings are included in Table 7. All offset
production wells are listed in Table 8.

Table 7 - All Offset SI/l/Ds included in the model

Grouping

API

Well Name

Well#



42-501-32511

SAWYER, DESSIE

1



42-501-02068

WEST, M. M.

2

Group 1

42-501-02053

NORTH CENTRAL OIL CO. "A"

1



42-501-01453

SMITH, EDS. HEIRS "B"

1



42-501-02059

SMITH, ED "C"

1W

Group 2

42-501-30051

JOHNSON

2

42-501-30001

JOHNSON

ID

Group 3

42-501-37066

MISS KITTY SWD 669

1W

42-501-36650

RUSTY CRANE 604

1W

Group 4

42-501-36745

SUNDANCE 642

1

42-501-33887

WINFREY 602

3WD



42-501-37252

Miller SWD

7



42-501-37367

BLONDIE 704

1W



42-501-37206

BRUSHY BILL 707

1WD



42-501-36622

WISHBONE FARMS 710

1W

Standalone

42-501-35834

ROBERTS UNIT

2



42-501-33297

STATE ELMORE

1



42-501-10238

SHEPHERD SWD

1



42-501-33511

CORNELL UNIT

3019D



42-501-32868

WILLARD UNIT

1WD

Table 8 - All Offset Producers included in the model

API

Well Name

Well #

42-501-10046

ELLIOTT, C.A.

2

42-501-10079

RANDALL, E

32

42-501-337932

RANDALL, E

40

42-501-33885

RANDALL, E

41L

42-501-34016

RANDALL, E

43 L

42-501-34017

RANDALL, E.

45 L

42-501-34023

RANDALL, E

42L

42-501-34024

RANDALL, E

44

42-501-35418

RANDALL, E

46

Rattlesnake AGI #1 came online in 2019 and the model simulated its historical monthly injection rates until
2024. After this initial period, it is conservatively assumed that the injection rate increases to the maximum
permitted rate of 16 MMSCF/d for the remainder of the active injection period in 2036. At this point, the

36


-------
Rattlesnake AGI #1 well stops injection while the offset SWD injectors continue operations for thirty more
years. Density drift then occurs until plume stabilizes, which was determined to be 814 years from the start
of the model in 1965. Stabilization of the plume is determined to occur when the model shows no further
lateral movement horizontally or vertically. The plume boundary is then defined by a weighted average gas
saturation in the aquifer of 3%.

The maximum plume extent during the 17-year Rattlesnake injection period is shown in Figure 23. The final
extent after 743 years of density drift after injection ceases is shown in Figure 24. The extensive time of the
modeled density drift of the plume is driven by the buoyant forces of the gas, the permeability/porosity of
the rock, and the residual gas saturation. Initially, the karsted region takes on most of the injection, but due
to the buoyant forces, it is slowly pushed up higher into the less permeable layers of the injection interval.
These lower permeable layers, increase the amount of time it takes for the plume to reach its maximum areal
extent. As all the inputs to the model were based on the most conservative approach, the maximum extent
of the plume will likely be smaller and the effective impact on reaching potential leakage pathways will be
minimal as the amount of CO2 at those far extents will be small.

State Elmore

Brushy Bills 707

Shepherd SWD

Rattlesnake AGI Plume
Global Mote froction(CQ2) 2036-Jqn-Ol K Plone: 2 of 16

-0.70
¦ -060

1050
o.
-
0.20

Group 2 Group 4 Group 3 Group 1

Blondie 704

Mi ter SWD

Rattlesnake AGI

Willard Unit

Roberts Unit

Production Wells

Cornell Unit

Figure 23 - AreaI View Gas Saturation Plume, 2036 (End of Injection)

37


-------
Brushy Bills 707

19,215'

Miller SWD

6,900'

Blondie 704

Production Wells

Rattlesnake AGI

Willard Unit

Roberts Unit

Cornell Unit

Group 2 Group 4 Group 3 Group 1

State Elmore

Shepherd SWD

1.00-—
!¦

090
080
-070
-060

-

t

-030
020

Rattlesnake AGI Plume
Global Mole Fractlon{C02) 2779-Doc-OI K Plane: 2 of 16

Figure 24- Area! View Gas Saturation Plume, 2779 (End of Density Drift)

Figure 25 shows the surface injection rate and bottom hole pressure over the injection period and the period
of density drift after injection ceases. The bottomhole pressure increases the most as the injection rate
reaches its peak, reaching a maximum pressure of 5,413 psi. This buildup of 280 psi keeps the bottomhole
pressure well below the fracture pressure of 7,064 psi. The maximum surface pressure associated with the
maximum bottomhole pressure reached is 2,494 psi.

16.000,000

I" 14.000,000

£ 12,000,000

= 10,000,000
o

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6370 J
S340 |
5310 b

O

5280 ®
T3

5250 ®
w

5220 c
at

5190 9*

v>

5160 —

—	Rattlesnake AGI, Gas Rate SC - Daily

—	Rattlesnake AGI, Well Bottom-hole Pressure

Figure 25 - Well Injection Rate and Bottomhole Pressure over Time

38


-------
SECTION 3 - DELINATION OF MONITORING AREA

This section discusses the delineation of Maximum Monitoring Area ("MMA") and Active Monitoring Area
("AMA") as described in EPA 40 CFR §98.448(a)(l).

Maximum Monitoring Area

The MMA is defined as equal to or greater than the area expected to contain the free-phase C02 plume until
the C02 plume has stabilized plus an all-around buffer zone of at least one-half mile. Numerical simulation
was used to predict the size and drift of the plume. With CMG's GEM software package, reservoir modeling
was used to determine the areal extent and density drift of the plume. The model takes into account the
following considerations:

•	Offset well logs to estimate geologic properties

•	Petrophysical analysis to calculate the heterogeneity of the rock

•	Geological interpretations to determine faulting and geologic structure

•	Offset injection history to adequately predict the density drift of the plume

Acid gas injectate was analyzed by a third-party vendor to determine the initial composition used in the
model. The report is provided in Appendix C. The molar composition of the gas is primarily C02 with some
H2S and CH4. The change in molar composition was also incorporated into the model as future predominantly
C02 streams are added for injection. As discussed in Section 2, the gas was injected into the Silurian
formation, specifically, the Fasken/Fusselman formation. The geomodel was created based off the rock
properties seen in the Fasken/Fusselman.

The plume boundary was defined by the weighted average gas saturation in the aquifer. A value of 3% gas
saturation was used to determine the boundary of the plume. When injection ceases in 2036, the areal
expanse of the plume will be 1,052 acres. The maximum distance between the wellbore and the edge of the
plume is approximately 0.87 miles to the southeast. After 743 additional years of density drift, the areal
extent of the plume is 2,177 acres with a maximum distance to the edge of the plume of approximately 1.35
miles to the southeast.

Figure 26 shows the plume boundary at the end of injection, the stabilized plume boundary and the MMA.

39


-------
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Rattlesnake ACI No. 1
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6 Stabilized Plune

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Active Monitoring Area

The initial AMA will cover a 14-year monitoring period. This period equates to the time of expected future
injection. The AMA will be established by superimposing the area based on a half-mile buffer around the
anticipated plume location at the end of injection (2036) with the area of the projected free-phase C02 plume
at five additional years (2041). In this case, the plume boundary in 2041 is within the plume at 2036 plus a
half-mile buffer. By 2036 at the latest, a revised MRV plan will be submitted to define a new AMA. Figure 27
shows the area covered by the AMA.

Larger size versions of Figures 26 and 27 are provided in Appendix D.

40


-------
ID

1 Inch = 0.51 Mile
1:32,000 m



&

Rattlesnake ACI No. 1
PI use Boundary at End of Injection
& 19-Year Plume
wi th

1/Z-Hile Active Monitoring Area (AHA)
Stakeholder Midstream

	Yoakum Co.. TX	

PCS: NADB3 TX-NC FIPS 4202 
-------
SECTION 4 - POTENTIAL PATHWAYS FOR LEAKAGE

This section identifies the potential pathways for C02 to leak to the surface within the MMA and the
likelihood, magnitude and timing of such leakage. The potential leakage pathways are:

•	Leakage from surface equipment

•	Leakage through existing wells within MMA

•	Leakage through faults and fractures

•	Leakage through the confining layer

•	Leakage from Natural or Induced Seismicity

Leakage from Surface Equipment

The surface facilities at the 30-30 Facility are designed for injecting acid gas containing H2S, and therefore
minimize leakage points such as valves and flanges following industry standards and best practices. H2S gas
detectors are located around the facility and the well site. These gas detectors trigger alarms at 10 parts per
million ("ppm"). Additionally, all Stakeholder field personnel are required to wear H2S monitors which are
triggered at 5 ppm of H2S. A shut-in valve is located at the wellhead and is locally controlled by pressure,
with a high pressure and low pressure shut-off.

The facilities have been designed and constructed with additional safety systems to provide for safe
operations. These systems include Emergency Shutdown ("ESD") valves to isolate portions of the plant and
pipeline, pressure relief valves along the pipeline to prevent over pressurization, and flares to allow piping
and equipment to be de-pressured rapidly under safe and controlled operating conditions in the event of a
leak. Figures 28 and 29 display the facility safety plot plan, taken from the 30-30 H2S Contingency Plan, and
show the location of the H2S monitors in the vicinity of the plant and the Rattlesnake AGI #1 well. Should
Stakeholder construct additional C02 facilities, as indicated in Figure 21, a separate meter will be installed for
the additional stream in order to comply with the 40 CFR §98.448(a)(5) measurement. As this meter will be
in close proximity to the existing facilities, it will utilize the existing monitoring programs discussed previously.
Additionally, C02 monitors will be installed near the new meter and tied into the facility monitoring systems.

42


-------
Figure 28 - Site Plan, 30-30 Facility

43


-------
With the level of monitoring at the 30-30 Facility and the Rattlesnake AGI #1 well, any release of H2S and C02
would be quickly identified, and the safety systems would quickly minimize the volume of the release. The
C02 injected into the Rattlesnake AGI #1 is injected with H2S at a concentration of 10% (100,000 ppm). At
this high level of H2S concentration, even a small leakage would trigger personal and facility H2S monitors set
to alarm at 5 ppm and 10 ppm respectively. If any leakage were to be detected, the volume of C02 released
will be quantified based on the operating conditions at the time of release, as stated in Section 7 in
accordance with 40 CFR §98.448(a)(5).

A larger scale version of Figure 28 is provided in Appendix E.

Leakage from Existing Wells within MMA
Oil and Gas Operations within Monitoring Area

A significant number of wells have historically been drilled within the area of the Rattlesnake AGI #1 well,
however production has primarily been from the shallower San Andres formation in the Wasson Field. The
San Andres is separated from the Silurian-Devonian interval by 4,720' in this area. In addition to the primary
San Andres production, a few wells have produced from the Wolfcamp. The Wolfcamp is separated from the
Siluro-Devonian interval by is 1,800'. Within the projected plume area of the Rattlesnake AGI #1 well, there
are no penetrations of the injection interval. There are ten wells within the MMA that penetrate the
injection interval.

A review of the TRRC records for all of the wells which penetrate the injection interval within the MMA,
shows the wells were properly cased and cemented to prevent annular leakage of C02 to the surface. The
plugged wells are also adequately protected against migration from the Devonian by the placement of the
plugs within the wellbores. Additionally, the Rattlesnake AGI #1 well was designed to prevent migration from
the injection interval to the surface through the casing and cement placed in the well, as shown in Figure 29.
Mechanical integrity tests ("MIT") required under TRRC rules are run annually to verify the well and wellhead
can hold the appropriate amount of pressure. If the MIT were to indicate a leak, the well would be isolated
and the leak mitigated quickly to prevent leakage to the atmosphere.

A map of all wells within the MMA is shown in Figure 30. Figure 31 shows only those wells which penetrate
the injection interval within the MMA. The MMA review maps, a summary of all the wells in the MMA and
detailed wellbore schematics for those wells which penetrate the injection interval are provided in Appendix
F.

44


-------
Base of USDW@375'

Rustler @ 2,345'

Salado @ 2,443'

Yates @ 3,019'

Seven Rivers @ 3,440'

dH

Grayburg @ 4; 190'
San Andres @ 4,465'

DV Tool @ 4,275'

DV Tool @5,591'

Glorieta @ 6,316'
Clearfork @ 6,492'

Wichita @ 8,628'

12,500' -
13,000' -
15,500' -

GK

Upper Wolfcamp @ 9,239'

Strawn @ 10,030'

Atoka @ 10,230'

Woodford @ 10,973'
Devonian @ 11,036'
Wristen@ 11,268'
Fusselman@ 11,538' Ci)
Montoya @ 11,974'

¦

ir

DV Tool @9,575'
Packer @ 10,966'

TD@ 11,980'

KB:

N/A

BHF:

NA

GL:

3,627'

Spud:

5/27/2018

Casing/Tubing Information

Label

1

2

3

4

Type

Surface

Intermediate

Production

Tubing

OD

13-3/8"

9-5/8"

7"

3-1/2"

Weight

48

40

29

9,2

WT

.330

.395

.408

NA

Grade

H40/J55 STC

L- 80 BTC

L80 LTC
2535 Vam Top

L80 Vam Top:
G3 Vam Top'

Hole Size

17-1/2"

12-1/4"

8 3/4

6"

Depth Set

504'

5.498'

11,014'

10,966'

TOC

Surface

Surface

Surface

NA

Volume

510 sks

2,135 sks

760 sks

NA

LONQUIST & CO. LLC

PETROLEUM

ENER6Y

ENGINEERS

ADVISORS

HOUSTON'CALGARY
AUSTIN I WICHITA I DENVER

Stakeholder Midstream

Country: USA

Location: 33.07884, -103.904514

API No: 42-501-36998

Rattlesnake No. 1

State/Province: Texas

Site:

County/Parish: Yoakum

Survey:

Well Type/Status: AG I

Texas License F-9147

RRC District No:

Project No: LS 128

Date: 5/27/2022

12912 Hill Country Blvd Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Reviewed: SLP

Approved: SLP

Figure 29 - Rattlesnake AG! #1 Well bore Schematic

45


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Drawn by: ER Date: 5/31/2022 Approved by: RH

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Figure 30 - Oil arid Gas Wells within the MMA

46


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Figure 31 - Penetrating Oil and Gas Wells within the MMA

47


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Future Drilling

Potential leak pathways caused by future drilling in the area are not expected to occur. The deeper
formations, such as the Devonian, have proven to-date to be less productive or non-productive in this area,
which is why the location was selected for injection. Furthermore, any drilling permits issued by the TRRC in
the area of the Rattlesnake AGI #1 well include a list of formations for which oil and gas operators are
required to comply with TRRC Rule 13 (entitled "Casing, Cementing, Drilling, Well Control, and Completion
Requirements"). 16 TAC § 3.13. By way of example, see the Rattlesnake AGI #1 well drilling permit provided
in Appendix B. The Devonian is among the formations listed for which operators in Yoakum County (where
the Rattlesnake #1 is located) are required to comply with TRCC Rule 13 (Appendix B, pg. 5). TRRC Rule 13
requires oil and gas operators to set steel casing and cement across and above all formations permitted for
injection under TRRC Rule 9 or immediately above all formations permitted for injection under Rule 46 for
any well proposed within a one-quarter mile radius of an injection well. In this instance, any new well
permitted and drilled to the Rattlesnake AGI #1 well's injection zone, and located within a one-quarter mile
radius of the Rattlesnake AGI #1 well, will be required under TRRC Rule 13 to set steel casing and cement
above the Rattlesnake AGI #1 well injection zone. Additionally, Rule 13 requires operators to case and
cement across and above all potential flow zones and/or zones with corrosive formation fluids. The TRRC
maintains a list of such known zones by TRRC district and county and provides that list with each drilling
permit issued, which is also shown in the above-mentioned permit in Appendix B.

If any leakage were to be detected, the volume of C02 released will be quantified based on the operating
conditions at the time of release.

Groundwater wells

There are seven groundwater wells located within the MMA, as identified by the Texas Water Development
Board. All of the identified groundwater wells in the area have total depths less than or equal to 265', as
shown in Figure 32 and Table 9. One of the wells is located on the 30-30 facility property with a total depth
of 119'and is operated by Stakeholder.

The surface and intermediate casings of the Rattlesnake AGI #1 well, as shown in Figure 29, are designed to
protect the shallow freshwater aquifers consistent with applicable TRRC regulations and the GAU letter
issued for this location. See GAU letter included within Appendix B. The wellbore casings and cements also
serve to prevent C02 leakage to the surface along the borehole.

A larger scale version of Figure 32 is provided in Appendix F.

48


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PCS: NAD 83 TX-NC FIPS 4202 
-------
Table 9 - Groundwater Well Summary

State Well ID

Owner Name

Primary Use Well Depth Data Source

370449

Frances Barbini

Irrigation

237

SDRDB

443840

Frances Jean Barbini

Irrigation

250

SDRDB

482963

Santa Fe Midstream Permian

Industrial

119

SDRDB

510854

FRANCIS BARNINI

Irrigation

255

SDRDB

520249

Thomas Durham

Irrigation

264

SDRDB

543433

FRANCIS BARBIDI

Irrigation

240

SDRDB

84760

TEXACO PRODUCING INC





TWDB BW

Leakage Through Faults and Fractures

Faults were interpreted from roughly 9 square miles of 3D seismic indicated by the purple outline in Figure
12. Faulting in this region terminates vertically below the Pennsylvanian-age rock. Secondary confining
shales within the Wolfcampian and younger strata provide additional, redundant confining layers that would
prevent C02from migrating into freshwater aquifers. None of the mapped faults project above the Wolfcamp
formation; rather, they appear to terminate between the Strawn and base of the Wolfcamp formation. If, in
the unlikely event the faults' sealing properties are compromised post-injection, secondary confinement is
provided by the tight limestones found within the overlying Mississippianan Lime formation and the shale
layers found in the Atoka and Wolfcamp formations. As seen in Figure 14, the largest fault found SE of the
Rattlesnake AGI #1 well, terminates within the Atoka formation. Though it crosses the Silurian section, this
fault thrusts the Mississippian Lime upward against the Atoka shales. The tight reservoir characteristics of
the Mississippian Lime and shaley section of the Atoka create a confining environment vertically and laterally
to contain potential upward migration of buoyant fluids. Shales within the Wolfcamp formation provide
additional confining beds between overlying USDWs and the fault plane.

Should an unmapped fault exist within the plume boundary, the offset would be below 3D seismic resolution.
The offset would be less than the thickness of the Woodford shale, juxtaposing the Woodford against itself,
preventing vertical migration.

Fractures and subsequent subaerial exposure are responsible for porosity development within the injection
intervals. Open hole logs show little to no porosity development indicating the Woodford or Mississippian
Lime were not exposed at this location. Upward migration of injected gas through confining bed fractures is
unlikely.

50


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Leakage Through the Confining Layer

The Silurian-Devonian injection zones have competent sealing rocks above and below the porous sub-aerially
exposed carbonate. The properties of the overlying transgressive Woodford shale (widespread deposition,
high illite clay and organic matter composition, and low porosity and permeability) make an excellent sealing
rock to the underlying Silurian formation. Tight Mississippian Lime of roughly 660 ft, lay between Atoka and
Woodford shale formations, forming an impermeable upper seal to the injection interval. Above this
confining unit, correlative shales of the Wolfcamp, Abo and Tubb formations will prevent any upper fluid
migration. These impermeable shales are capped by hundreds of feet of the regionally present Salado
formation evaporites. The USDW lies above the sealing properties of the formations outlined above, making
stratigraphic migration of fluids into the USDW highly unlikely. The underlying low porosity and permeability
Montoya carbonate minimizes the likelihood of downward migration of injected fluids. The relative
buoyancy of injected gas to the in-situ reservoir fluid makes migration below the lower confining layer
unlikely.

Leakage from Natural or Induced Seismicitv

The location of Rattlesnake AGI #1 is in an area of the Permian Basin that is inactive from a seismicity
perspective, whether induced or natural. A review of historical seismic events on the USGS's Advanced
National Seismic System site (from 1971 to present) and the Bureau of Economic Geology's TexNet catalog
(from 2017 to present), as shown in Figure 33, indicates the nearest seismic event occurred more than 60
miles away.

A regional analysis of the probabilistic fault slip potential across the Permian Basin (Snee & Zoback 2016), as
seen in Figure 34, further demonstrates that the Rattlesnake AGI #1 well is located in a seismically inactive
area and confirms that this area has little to no potential for an induced seismicity event.

Therefore, there is no indication that seismic activity poses a risk for loss of C02 to the surface within the
MMA.

Pressures will be kept significantly below the fracture gradient of the injection and confining intervals.
Additionally, continuous well monitoring combined with seismic monitoring will identify any operational
anomalies associated with a seismicity event.

51


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52


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Figure 34 - Probabilistic Fault Slip Potential Analysis with Rattlesnake AGI ft1 location (Snee & Zobak 2016)

53


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SECTION 5 - MONITORING FOR LEAKAGE

This section discusses the strategy that Stakeholder will employ for detecting and quantifying surface leakage
of C02 through the pathways identified in Section 4 to meet the requirements of 40 CFR §98.448(a)(3). As
the injectate stream contains both H2S and C02, the H2S will be a proxy for C02 leakage and therefore the
monitoring systems in place to detect H2S will also indicate a release of C02. Table 10 summarizes the
monitoring of potential leakage pathways to the surface. Monitoring will occur during the planned 17-year
injection period, or cessation of injection operations, plus a proposed 5-year post-injection period.

•	Leakage from surface equipment

•	Leakage through existing and future wells within MMA

•	Leakage through faults , fractures or confining seals

•	Leakage through natural or induced seismicity

Because the acid gas injection stream also contains H2S, any leakage would be detected by the H2S alarms
located around the facility and would be quickly addressed which would minimize the release of C02 into the
atmosphere.

Table 10- Summary of Leakage Monitoring Methods

Leakage Pathway

Monitoring Method

Leakage from surface equipment

Fixed H2S monitors throughout the AGI facility

Daily visual inspections

Personal H2S monitors

Distributed Control System Monitoring (Volumes and Pressures)

Leakage through existing wells

Fixed H2S monitor at the AGI well

SCADA Continuous Monitoring at the AGI Well

Annual Mechanical Integrity Tests ("MIT") of the AGI Well

Visual Inspections

Quarterly C02 Measurements within AMA

Leakage through groundwater wells

Annual GroundwaterSamples on Property

Leakage from future wells

H2S Monitoring during offset drilling operations

Leakage through faults and fractures

SCADA Continuous Monitoring at the AGI Well (volumes and pressures)

Fixed In-field H2S monitors

Leakage through confining layer

SCADA Continuous Monitoring at the AGI Well (volumes and pressures)

Fixed In-field H2S monitors

Leakage from natural or induced
seismicity

Seismic monitoring station to be installed

54


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Leakage from Surface Equipment

As the 30-30 Facility and the Rattlesnake AGI #1 well are designed to handle H2S, leakage from surface
equipment is unlikely to occur and would be quickly detected and addressed. The facility design minimizes
leak points through the equipment used and the type of connections are designed to minimize corrosion
points. The H2S in the injectate serves as a proxy for the release of C02. The facility and well site contain a
number of H2S alarms, set with a high alarm setpoint of 10 ppm of H2S, which are shown in Figure 28 above.
Additionally, all Stakeholder field personnel are required to wear H2S monitors, which trigger the alarm at 5
ppm H2S.

The AGI facility is continuously monitored through automated systems. In addition, field personnel conduct
daily visual field inspections of gauges, monitors and leak indicators such as vapor plumes. The effectiveness
of the internal and external corrosion control program is monitored through the periodic inspection of the
system, analysis of liquids collected from the line, and inspection of the cathodic protection system. These
inspections, in addition to the automated systems, allow Stakeholder to quickly respond to any leakage
situation. Monitoring will occur for the duration of injection and the post-injection period. Should leakage
be detected during active injection operations, the volume of C02 released will be calculated based on
operating conditions at the time of the event, per 40 CFR §98.448(a)(5).

Pressures and flowrates through the surface equipment are continuously monitored during operations. If a
release occurred from surface equipment, the amount of C02 released would be quantified based on the
operating conditions at the time, including pressure, flow rate, size of the leak point opening, and duration
of the leak.

Leakage from Existing and Future Wells within MMA

Stakeholder continuously monitors and collects injection volumes, pressures, temperatures and gas
composition data, through their SCADA systems, for the Rattlesnake AGI #1 well. This data is reviewed by
qualified personnel and will follow response and reporting procedures when data is outside acceptable
performance limits. Rattlesnake AGI #1 has a pressure and temperature gauge placed in the injection stream
at its wellhead, and a pressure gauge on the casing annulus. A change of pressure on the annulus would
indicate the presence of a possible leak. Mechanical integrity tests ("MITs") performed annually would also
indicate the presence of a leak. Upon a negative MIT, the well would immediately be isolated and the leak
mitigated.

The ten offset penetrating wells within the MMA are adequately cased and cemented to prevent potential
leakage of C02 from the Rattlesnake AGI #1 well plume. Additionally, the plugged wells were done so in a
way to prevent migration of C02 as provided in Appendix E. As discussed previously, Rule 13 would ensure
that new wells in the field would be constructed in a manner to prevent migration from the injection interval.

In addition to the fixed and personal monitors described previously, Stakeholder will also establish and
operate an in-field monitoring program to detect any C02 leakage within the AMA. The scope of work will
include H2S and C02 monitoring at the AGI well site as well as minimum, quarterly atmospheric monitoring
near identified penetrations within the AMA. Upon approval of the MRV and through the post-injection
monitoring period, Stakeholder will have these monitoring systems in place. Additional monitoring will be
added as the AMA is updated over time.

At the well site, H2S and C02 concentrations will be monitored continuously with fixed monitors that detect

55


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atmospheric concentrations of H2S and C02. At penetrating well sites, Stakeholder will similarly measure
atmospheric concentrations of C02 and H2S using mobile gas monitors. This data will be recorded at least
quarterly.

Groundwater Quality Monitoring

Stakeholder will monitor the groundwater quality in fluids above the confining interval by sampling the well
on the facility property and analyzing the sample with a third-party laboratory on an annual basis. Any
significant changes to the water analysis would be investigated to determine if such change was a result of
leakage from the Rattlesnake AGI #1 well. The parameters to be measured will include pH, total dissolved
solids, total inorganic and organic carbons, density, temperature and other standard laboratory
measurements. Any significant differences in these parameters from the baseline sample will be evaluated
to determine if leakage of C02 to the USDW may have occurred.

Leakage through Faults, Fractures or Confining Seals

Stakeholder continuously monitors the operations of the Rattlesnake AGI #1 well through automated
systems. Any deviation from normal operating conditions indicating movement into a potential pathway
such as a fault or breakthrough of the confining seal would trigger an alert. Any such alert would be reviewed
by field personnel and action taken to shut in the well, if necessary. Field H2S monitoring systems would alert
field personnel for any release of H2S/C02 caused by such leakage.

Leakage through Natural or Induced Seismicitv

While the likelihood of a natural or induced seismicity event is extremely low, Stakeholder plans to install a
seismic monitoring station in the general area of the Rattlesnake AGI #1 well. The installation of this station
would start upon approval of the MRV plan, with an expected in-service data within six months after the
commencement of the installation project. This monitoring station will be tied in to the Bureau of Economic
Geology's TexNet Seismic Monitoring system. If a seismic event of 3.0 magnitude or greater is detected,
Stakeholder will review the injection volumes and pressures at the Rattlesnake AGI #1 well to determine if
any significant changes occur that would indicate potential leakage.

56


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SECTION 6 - BASELINE DETERMINATIONS

This section identifies the strategies Stakeholder will undertake to establish the expected baselines for
monitoring C02 surface leakage per 40 CFR §98.448(a)(4). Stakeholder will use the existing SCADA monitoring
systems to identify changes from expected performance that may indicate leakage of C02.

Visual Inspections

Daily inspections will be conducted by field personnel at the 30-30 Facility and the Rattlesnake AGI #1 well.
These inspections will aid with identifying and addressing issues timely to minimize the possibility of leakage.
If any issues are identified, such as vapor clouds or ice formations, corrective actions would be taken to
address such issues.

H2S Detection

H2S will be initially injected into the AGI well at a concentration of approximately ten (10) percent or 100,000
ppm. The concentration will drop to approximately seven (7) percent as additional volumes are added. H2S
gas detectors are located throughout the AGI facility and well site and are set to trigger the alarm at 10 ppm.
Additionally, all field personnel are required to wear personal H2S monitors, which are set to trigger the alarm
at 5 ppm. Any alarm would trigger an immediate response to protect personnel and verify that the monitors
are working properly. If monitors are working correctly, immediate actions would be taken to secure the
facility and mitigate potential leaks.

CO2 Detection

Any C02 release would be accompanied by H2S and therefore the H2S monitors at the facility would also serve
as a C02 release warning system. In addition to the fixed and personal monitors described previously,
Stakeholder will also establish and operate an in-field monitoring program to detect any C02 leakage within
the AMA. The scope of work will include H2S and C02 monitoring at the AGI well site as well as atmospheric
monitoring near identified penetrations within the AMA.

Operational Data

Upon starting injection operations, baseline measurements of injection volumes and pressures will be taken.
Any significant deviations over time will be analyzed for indication of leakage of C02.

Continuous Monitoring

Mass of C02 emitted by surface leakage and equipment leaks will not be measured directly as the injection
stream for this well contains H2S which would be extremely dangerous for personnel to perform a direct leak
survey. Any leakage would be detected and managed as per Texas regulations and Stakeholder's TRRC-
approved H2S Contingency Plan. Gas detectors and continuous monitoring systems would trigger an alarm
upon a release. The mass of the C02 released would be calculated for the operating conditions at the time,
including pressure, flow rate, size of the leak point opening, and duration of the leak. This method is
consistent with 40 CFR §98.448(a)(5), allowing the operator to calculate site-specific variables used in the
mass balance equation.

57


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No C02 emissions will occur from venting because of the high H2S concentrations. Blowdown emissions are
sent to flares and would be reported as part of the required reporting for the gas plant.

Groundwater Monitoring

An initial sample will be taken from the groundwater well on Stakeholder's property, identified as Well #
482963 in Table 9 above, upon approval of Stakeholder's MRV and prior to increasing injection. The sample
will be analyzed by a third-party laboratory to establish the baseline properties of the groundwater.

58


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SECTION 7 - SITE SPECIFIC CONSIDERATIONS FOR MASS BALANCE

EQUATION

This section identifies how Stakeholder will calculate the mass of C02 injected, emitted, and sequestered.
This also includes site-specific variables for calculating the C02 emissions from equipment leaks and vented
emissions of C02 between the injection flow meter and the injection well, per 40 CFR §98.448(a)(5).

Mass of CO2 Received

Per 40 CFR §98.443, the mass of C02 received must be calculated using the specified C02 received equations
"unless you follow the procedures in 40 CFR §98.444(a)(4)." 40 CFR §98.444(a)(4) states that "if the C02 you
receive is wholly injected and is not mixed with any other supply of C02, you may report the annual mass of
C02 injected that you determined following the requirements under paragraph (b) of this section as the total
annual mass of C02 received instead of using Equation RR-1 or RR-2 of this subpart to calculate C02 received."
The C02 received for this injection well is wholly injected and not mixed with any other supply and the annual
mass of C02 injected will equal the amount received. Any future streams would be metered separately before
being combined into the calculated stream.

Mass of CO2 Injected

Per 40 CFR §98.444(b), since the flow rate of C02 injected will be measured with a volumetric flow meter, the
total annual mass of C02, in metric tons, will be calculated by multiplying the mass flow by the C02
concentration in the flow according to Equation RR-5:

C02,u = Annual C02 mass injected (metric tons) as measured by flow meter u

QP,u = Quarterly volumetric flow rate measurement for flow meter u in quarter p (metric tons per

D = Density of C02 at standard conditions (metric tons per standard cubic meter): 0.0018682

Cco2,P,u = Quarterly C02 concentration measurement in flow for flow meter u in quarter p (wt. percent
C02, expressed as a decimal fraction)

p = Quarter of the year

u = Flow meter

4

p = 1

where:

quarter)

59


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Mass of CO2 Produced

The Rattlesnake AGI #1 well is not part of an enhanced oil recovery project; therefore, no C02 will be
produced.

Mass of CO2 Emitted by Surface Leakage

Mass of C02 emitted by surface leakage and equipment leaks will not be measured directly as the injection
stream for this well contains H2S which would be extremely dangerous for personnel to perform a direct leak
survey. Any leakage would be detected and managed as a major upset event. Gas detectors and continuous
monitoring systems would trigger an alarm upon a release. The mass of the C02 released would be calculated
for the operating conditions at the time, including pressure, flow rate, size of the leak point opening, and
duration of the leak. This method is consistent with 40 CFR §98.448(a)(5), allowing the operator to calculate
site-specific variables used in the mass balance equation.

In the unlikely event that C02 was released as a result of surface leakage, the mass emitted would be
calculated for each surface pathway according to methods outlined in the plan and totaled using Equation
RR-10 as follows:

C02 = Total annual C02 mass emitted by surface leakage (metric tons) in the reporting year
C02,x= Annual C02 mass emitted (metric tons) at leakage pathway x in the reporting year
X = Leakage pathway

Calculation methods from subpart W will be used to calculate C02 emissions from equipment located on
the surface between the flow meter used to measure injection quantity and the injection wellhead

Mass of CO2 Sequestered

The mass of C02 sequestered in subsurface geologic formations will be calculated based off Equation RR-12,
as this well will not actively produce oil or natural gas or any other fluids, as follows:

X

X=1

Where:

CO 2 — C02i C02e C02fi

Where:

60


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C02 = Total annual C02 mass sequestered in subsurface geologic formations (metric tons) at the
facility in the reporting year

CO21 = Total annual C02 mass injected (metric tons) in the well or group of wells covered by this source
category in the reporting year

C02E = Total annual C02 mass emitted (metric tons) by surface leakage in the reporting year

CO 2fi - Total annual C02 mass emitted (metric tons) from equipment leaks and vented emissions of
C02 from equipment located on the surface between the flow meter used to measure injection
quantity and the injection wellhead

CO 2fi will be calculated in accordance with Subpart W reporting of GHGs. Because no venting would occur
due to the high H2S concentrations of the injectate stream, the calculations would be based on the blowdown
emissions that would be sent to flares and would be reported as part of the required GHG reporting for the
gas plant.

• Calculation methods from subpart W will be used to calculate C02 emissions from equipment located
on the surface between the flow meter used to measure injection quantity and the injection
wellhead.

61


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SECTION 8 - IMPLEMENTATION SCHEDULE FOR MRV PLAN

The Rattlesnake AGI #1 well currently reports GHGs under Subpart UU, but Stakeholder has elected to submit
an MRV plan under, and otherwise comply with, Subpart RR. The MRV plan will be implemented upon
receiving EPA approval. The Annual Subpart RR Report will be filed on March 31st of the year following the
reporting year.

62


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SECTION 9 - QUALITY ASSURANCE

This section identifies how Stakeholder plans to manage quality assurance and control, to meet the

requirements of 40 CFR §98.444.

Monitoring QA/QC

C02 Injected

•	The flow rate of the C02 being injected will be measured with a volumetric flow meter, consistent
with industry best practices. These flow rates will be compiled quarterly.

•	The composition of the C02 stream will be measured upstream of the volumetric flow meter with a
continuous gas composition analyzer or representative sampling consistent with industry best
practices.

•	The gas composition measurements of the injected stream will be averaged quarterly.

•	The C02 measurement equipment will be calibrated according to manufacturer recommendations.

C02 Emissions from Leaks and Vented Emissions

•	Gas detectors will be operated continuously, except for maintenance and calibration.

•	Gas detectors will be calibrated according to manufacturer recommendations and API standards.

•	Calculation methods from subpart W will be used to calculate C02 emissions from equipment located
on the surface between the flow meter used to measure injection quantity and the injection
wellhead.

Measurement Devices

•	Flow meters will be continuously operated except for maintenance and calibration.

•	Flow meters will be calibrated according to the requirements in 40 CFR §98.3(i).

•	Flow meters will be operated per an appropriate standard method as published by a consensus-
based standards organization.

•	Flow meter calibrations will be traceable to the National Institute of Standards and Technology
(NIST).

All measured volumes of C02 will be converted to standard cubic meters at a temperature of 60 degrees

Fahrenheit and an absolute pressure of 1 atmosphere.

Missing Data

In accordance with 40 CFR §98.445, Stakeholder will use the following procedures to estimate missing data

if unable to collect the data needed for the mass balance calculations:

•	If a quarterly quantity of C02 injected is missing, the amount will be estimated using a representative
quantity of C02 injected from the nearest previous period of time at a similar injection pressure.

•	Fugitive C02 emissions from equipment leaks from facility surface equipment will be estimated and
reported per the procedures specified in subpart W of 40 CFR §98.

63


-------
MRV Plan Revisions

If any of the changes outlined in 40 CFR §98.448(d) occur, Stakeholder will revise and submit an amended
MRV plan within 180 days to the Administrator for approval.

64


-------
SECTION 10 - RECORDS RETENTION

Stakeholder will retain records as required by 40 CFR §98.3(g). These records will be retained for at least
three years and include:

•	Quarterly records of the C02 injected

o Volumetric flow at standard conditions
o Volumetric flow at operating conditions
o Operating temperature and pressure
o Concentration of the C02 stream

•	Annual records of the information used to calculate the C02 emitted by surface leakage from leakage
pathways.

•	Annual records of information used to calculate C02 emitted from equipment leaks and vented
emissions of C02 from equipment located on the surface between the flow meter used to measure
injection quantity and the injection wellhead.

65


-------
References

Broadhead, Ronald E., 2005. Regional Aspects of the Wristen petroleum system, southeastern New Mexico:
New Mexico Bureau of Geology and Mineral Resources Open File Report, no. 485.

Comer, John B., 1991. Stratigraphic Analysis of the Upper Devonian Woodford Formation, Permian Basin,
West Texas and Southeastern New Mexico: Bureau of Economic Geology Report of Investigations, no. 201.

George, Peter G., Mace, Robert E., and Petrossian, Rima, 2011. Aquifers of Texas: Texas Water Development
Board Report, no 380.

Hoak, T., Sundberg, K., and Ortoleva, P. Overview of the Structural Geology and Tectonics of the Central Basin
Platform, Delaware Basin, and Midland Basin, West Texas and New Mexico: Department of Energy Open File
Report.

Molina, Oscar, Vilarras, Victor, and Zeidouni, Mehdi, 2016. Geologic carbon storage for shale gas recovery:
13th International Conference on Greenhouse Gas Control Technologies, GHGT-13, 14-18.

Ruppel, Stephen C. and Holtz, Mark H., 1994. Depositional and Diagenetic Facies Patterns and Reservoir
Development in Silurian and Devonian Rocks of the Permian Basin: Bureau of Economic Geology Report of
Investigations, no. 216.

Snee, Jens-Erik Lund and Zoback, Mark D., 2016. State of stress in the Permian Basin, Texas and New Mexico:
Implications for induced seismicity.

Teeple, Andrew P., Ging, Patricia B., Thomas, Jonathan V., Wallace, David S., and Payne, Jason D., 2021.
Hydrogeologic Framework, Geochemistry, Groundwater-Flow System, and Aquifer Hydraulic Properties Used
in the Development of a Conceptual Model of the Ogallala, Edwards-Trinity (High Plains), and Dockum
Aquifers In and Near Gaines, Terry, and Yoakum Counties, Texas: USGS Scientific Investigations Report 2021-
5009.

66


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APPENDICES


-------
APPENDIX A-GEOLOGY

APPENDIX A-l: SILURIAN STRUCTURE MAP
APPENDIX A-2: NE-SW CROSS SECTION
APPENDIX A-3: NW-SE CROSS SECTION
APPENDIX A-4: FORMATION FLUID SAMPLE WELL MAP


-------

-------
mi

LONQU 1ST

SEQUESTRATION L

Stakeholder Midstream


-------
42501105700000
1-667

TEXAS CRUDE OIL CO

42501358340000
ROBERTS UNIT
2

APACHE

<14,201 FT>

42501369980000
RATTLESNAKE AG I
1

STAKEHOLDER GAS SERVICES


-------
Rattlesnake AGI No. 1
Maximum Monitoring Area
with

Formation Fluid Sample Wells

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 6/1/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY





ENGINEERS

ADVISORS



| AUSTIN • HOUSTON J

I CALGARY-WICHITA

| DENVER

• COLLEGE STATION |

[ BATON ROUGE • EDMONTON

-J- Rattlesnake AGI No. 1 SHL
|	I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent


-------
APPENDIX B -TRRC FORMS Rattlesnake AG I #1

APPENDIX B-l: UIC CLASS II ORDER

APPENDIX B-2: GAU GROUNDWATER PROTECTION DETERMINATION
APPENDIX B-3: DRILLING PERMIT
APPENDIX B-4: COMPLETION REPORT


-------
Christi Craddick, Chairman
Ryan Sitton, Commissioner
Wayne Christian, Commissioner

B-1

Danny Sorrells
Assistant Executive Director
Director, Oil and Gas Division
Leslie Savage

Assistant Director, Technical Permitting

Railroad Commission of Texas

OIL AND GAS DIVISION

PERMIT TO DISPOSE OF NON-HAZARDOUS OIL AND GAS WASTE BY INJECTION INTO A
POROUS FORMATION NOT PRODUCTIVE OF OIL AND GAS

PERMIT NO. 15848

SANTA FE MIDSTREAM PERMIAN LLC
5830 GRANITE PKWY STE 1025
PLANO, TX 75024

DOCKET NO. 8A-0312019

Authority is granted to inject Non-Hazardous Oil and Gas waste into the well identified herein in accordance
with Statewide Rule 9 of the Railroad Commission of Texas and based on information contained in the
application (Form W-14) dated March 12, 2018 for the permitted interval of the DEVONIAN formation and
subject to the following terms and special conditions:

RATTLESNAKE AGI (000000) LEASE

WASSON FIELD

YOAKUM COUNTY, DISTRICT 8A

WELL II

DENTIFIC ATION AND P]

ERMIT PA]

RAMET]

ERS:

Well No.

API No.

UIC Number

Permitted
Fluids

Top
Interval
(feet)

Bottom
Interval
(feet)

Maximum
Liquid
Daily
Injection
Volume
(BBL/day)

Maximum
Gas Daily
Injection
Volume
(MCF/day)

Maximum
Surface
Injection
Pressure
for Liquid
(PSIG)

Maximum
Surface
Injection
Pressure
for Gas
(PSIG)

1

50136998

000117143

C02, and
H2S

11,000

12,000

4,500

N/A

N/A

2,200

SPECIAL CONDITIONS:

Well No.

API No.

Special Conditions

1

50136998

1.	Open hole completions shall have a plug back depth no deeper than the bottom of the
permitted injection interval.

2.	The operator shall provide to the UIC section an annotated electric log, and a mud log if
available, of the subject well with the top(s) and bottom(s) of the permitted formation
indicated on the log. Top and bottom of the authorized injection interval may be modified
based on electric log or mud log indications of the top and bottom of the permitted
formations.

1701 NORTH CONGRESS AVENUE * POST OFFICE BOX 12967 * AUSTIN. TEXAS 78711-2967 * PHONE: 512/463-6792* FAX: 512/463-6780
TDD 800/735-2989 OR TDY 512/463-7284 * AN EQUAL OPPORTUNITY EMPLOYER* http://www.rrc.texas.gov


-------
STANDARD CONDITIONS:

1.	Injection must be through tubing set on a packer. The packer must be set no higher than 100 feet above the
top of the permitted interval.

2.	The District Office must be notified 48 hours prior to:

a.	running tubing and setting packer;

b.	beginning any work over or remedial operation;

c.	conducting any required pressure tests or surveys.

3.	The wellhead must be equipped with a pressure observation valve on the tubing and for each annulus.

4.	Prior to beginning injection and subsequently after any work over, an annulus pressure test must be
performed. The test pressure must equal the maximum authorized injection pressure or 500 psig, whichever
is less, but must be at least 200 psig. The test must be performed, and the results submitted in accordance
with the instructions of Form H-5.

5.	The injection pressure and injection volume must be monitored at least monthly and reported annually on
Form H-10 to the Commission's Austin office.

6.	Within 30 days after completion, conversion to disposal, or any work over which results in a change in well
completion, a new Form W-2 or G-l must be filed to show the current completion status of the well. The
date of the disposal well permit, and the permit number must be included on the new Form W-2 or G-l.

7.	Written notice of intent to transfer the permit to another operator by filing Form P-4 must be submitted to
the Commission at least 15 days prior to the date of the transfer.

8.	This permit will expire when the Form W-3, Plugging Record, is filed with the Commission. Furthermore,
permits issued for wells to be drilled will expire three (3) years from the date of the permit unless drilling
operations have commenced.

Provided further that, should it be determined that such injection fluid is not confined to the approved interval, then
the permission given herein is suspended and the disposal operation must be stopped until the fluid migration from
such interval is eliminated. Failure to comply with all of the conditions of this permit may result in the operator
being referred to enforcement to consider assessment of administrative penalties and/or the cancellation of the
permit.

APPROVED AND ISSUED ON November 14. 2018.

Injection-Storage Permits Unit

IN-HOUSE AMENDMENT TO CORRECT THE RATE.

Note: This document will only be distributed electronically.

PERMIT NO. 15848
Page 2 of 2


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GROUNDWATER PROTECTION DETERMINATION
Groundwater Advisory Unit

Form GW-2

B-2

Date Issued:

31 August 2017

GAU Number:

179154

Attention:

SANTA FE MIDSTREAM

API Number:





5700 GRANITE PARKWAY

County:

YOAKUM



PLANO, TX 75024

Lease Name:

Roberts Unit

Operator No.:

748093

Lease Number:

Well Number:

Total Vertical Depth:
Latitude:

Longitude:

Datum:

019212
1

11000
33.049990
-102.903464
NAD27

Purpose:

New Drill





Location:

Survey-Gibson, J H/Poole, J T; Block-D; Section-733



To protect usable-quality groundwater at this location, the Groundwater Advisory Unit of the Railroad Commission of
Texas recommends:

The interval from the land surface to a depth of 375 feet must be protected.

Note: Unless stated otherwise, this recommendation is intended to apply only to the subject well and not for area-wide use.
This recommendation is for normal drilling, production, and plugging operations only. It does not apply to saltwater disposal
operation into a nonproductive zone (RRC Form W-14).

This determination is based on information provided when the application was submitted on 08/30/2017. If the location
information has changed, you must contact the Groundwater Advisory Unit, and submit a new application if necessary.
If you have questions, please contact us at 512-463-2741 orgau@rrc.texas.gov.

Groundwater Advisory Unit, Oil and Gas Division

Form GW-2 P.O. Box 12967 Austin, Texas 78771-2967 512-463-2741 Internet address: www.rrc.texas.gov
Rev. 02/2014


-------
APINa 42-501-36998

RAILROAD COMMISSION OF TEXAS
OIL & GAS DIVISION

APPLICATION FOR PERMIT TO DRILL, RECOMPLETE, OR RE-ENTER

This facsimile W-l was generated electronically from data submitted to the RRC.

A certification of the automated data is available in the RRC's Austin office.

FORM W-l 07/2004

Drilling Permit #

839303

SWR Exception Case/Docket No.

Permit Status: Approved

B-3

1. RRC Operator No.

748093

2. Operator's Name (as shown on form P-5, Organization Report)

SANTA FE MIDSTREAM PERMIAN LLC

3. Operator Address (include street, city, state, zip):

5830 GRANITE PKWY STE 1025
PLANO, TX 75024-0000

4. Lease Name

RATTLESNAKE AGI

5. Well No.

1

GENERAL INFORMATION

6. Purpose of filing (mark ALL appropriate boxes): Ix] New Drill EH Recompletion EH Reclass EH Field Transfer EH Re-Enter

EH Amended EH Amended as Drilled (BHL) (Also File Form W-1D)

7. Wellbore Profile (mark ALL appropriate boxes): 0 Vertical EH Horizontal (Also File Form W-1H) EH Directional (Also File Form W-1D) EH Sidetrack

8. Total Depth

12000

9. Do you have the right to develop the [x] - | |
minerals under any right-of-way ?

10. Is this well subject to Statewide Rule 36 (hydrogen sulfide area)? IS Yes EH \0

SURFACE LOCATION AND ACREAGE INFORMATION

11. RRC District No.

8A

12. County I—, ,—, ,—, ,—¦

YOAKUM 13. Surface Location LXI Land 1—1 Bay/Estuary 1—1 Inland Waterway 1—1 Offshore

14. This well is to be located miles in a NW direction from DENVER CITY which is the nearest town in the county of the well site.

15. Section 16. Block 17. Survey 18. Abstract No.

733 D GIBSON, J H A-89

19. Distance to nearest lease line:

200 ft-

20. Number of contiguous acres in

lease, pooled unit, or unitized tract: 640

21.	Lease ]

22.	Survey

'erpendiculars: 200 ft from the NORTH line and 200 ft froi

nt
nt

ie WEST line.



PprppiiHii^iilars" 200 ft from the NORTH line and 200 ft froi

le WEST line.

23. Is this a pooled unit? EH Yes B No 24. Unitization Docket No:

25. Are you applying for Substandard Acreage Field? EH Yes (attach Form W-1A) S No

FIELD INFORMATION List all fields of anticipated completion including Wildcat. List one zone per line.

26. RRC
District No.

27. Field No.

28. Field Name (exactly as shown in RRC records)

29. Well Type

30. Completion Depth

31. Distance to Nearest
Well in this Reservoir

32. Number of Wells on
this lease in this
Reservoir

8A

95397001

WASSON

Injection Well

12000

0.00

1

8A

95399400

WASSON, NORTH (SAN ANDRES)

Injection Well

12000

0.00

1





























BOTTOMHOLE LOCATION INFORMATION is required for DIRECTIONAL, HORIZONTAL, AND AMENDED AS DRILLED PERMIT APPLICATIONS

Remarks

[FILER Apr 16, 2018 5:16 PM]: Filing for an acid gas injection well.

Certificate:

I certify that information stated in this application is true and complete, to the
best of my knowledge.

Jessica Risien, Regulatory Compliance

Specialist Apr 25, 2018

Name of filer Date submitted

(281)8729300 jrisien@ntglobal.com

Phone E-mail Address (OPTIONAL)

RRC Use Only Data Validation Time Stamp: Apr 27, 2018 10:36 AM( As Approved' Version )

Page 1 of 1


-------
NOTE: Acreages shown hereon ere based on Information provided by others.

This plat represents a staked well location and does not represent a boundary survey.
The Information shown does not meet the current TBPLS minimum standards for boundary
surveys. Limited field measurements were acquired. Lease and tract line Information is
compiled from record information and additional sources.

NOTES:

1)

2)

3-J

ALL BEARINGS. DISTANCES ANO COORDINATES SHOWN
HEREON WERE DERIVED FROM <3. P S. OBSERVATIONS
CONVERTED TO THE TEXAS COORDINATE SYSTEM,
NORTH CENTRAL ZONE (NAD 1993). US FOOT AND ARE
REFERENCED TO THE LOCAL GNSS RTK NETWORK.
THE PROPOSED WELL LOCATION IS SITUATED N 37~W -
7.3 MILES FROM DENVER CITY, TX.

THE PROPOSED WELL LOCATION IS SITUATED SOW FROM
THE NSL AND 200 FROM THE WSL.

6

5°X'

rC-< liw



SECTION 704. BLOCK D
J. H. GIBSON SURVEY-
ABSTRACT NO. 1144
YOAKUM COUNTY. TX

704

733

RA TTLESMAKE AGf No.
(PROPOSED)

.0^

SURFACE L OCA T/ON
NAD 83, TX-NC, U.S. FT.
NORTH/NG/Y; 7093713.4ST
EASTING/X 619409-13"

LATITUDE (DDJ- 33.05134722°
LONGITUDE (DO)- -102.90450555*

NAD 27, TX-NC, US- FT,
NORTHfNG/Y: 546285.34*
EAST/NG/X; 344968.61'

LA TTTUDE (DO)- 33.05124473"
LONGITUDE (DO)- -102.90401331°
SURFACEELEVA T/ON- 3627.05-

732

*

83^8

2

5>^0
S



Af /=>&?AfMA/LLG
rtATTL£SA/j4/C£-s4G/A/o. 7
*/.M. G/&SOA/ SURWEK
SEGT/OA/ 733, &LOC/C0
yOAKt/AS GCHSA/TX TjEXAS

m	Y aHcmws80i*a,7x:7B>

IhtebkityRk

i ] Positions, llc


-------
Railroad Commission of Texas

PERMIT TO DRILL, RE-COMPLETE, OR RE-ENTER ON REGULAR OR ADMINISTRATIVE EXCEPTION LOCATION

CONDITIONS AND INSTRUCTIONS

Permit Invalidation. It is the operator's responsibility to make sure that the permitted location complies with Commission density and
spacing rules in effect on the spud date. The permit becomes invalid automatically if, because of a field rule change or the drilling of another
well, the stated location is not in compliance with Commission field rules on the spud date. If this occurs, application for an exception to
Statewide Rules 37 and 38 must be made and a special permit granted prior to spudding. Failure to do so may result in an allowable not being
assigned and/or enforcement procedures being initiated.

Notice Requirements. Per H.B 630, signed May 8,2007, the operator is required to provide notice to the surface owner no later than the
15th business day after the Commission issues a permit to drill. Please refer to subchapter Q Sec. 91.751-91.755 of the Texas Natural
Resources Code for applicability.

Permit expiration. This permit expires two (2) years from the date of issuance shown on the original permit. The permit period will not
be extended.

Drilling Permit Number. The drilling permit number shown on the permit MUST be given as a reference with any notification to the
district (see below), correspondence, or application concerning this permit.

Rule 37 Exception Permits. This Statewide Rule 37 exception permit is granted under either provision Rule 37 (h)(2)(A) or 37(h)(2)(B).
Be advised that a permit granted under Rule 37(h)(2)(A), notice of application, is subject to the General Rules of Practice and Procedures
and if a protest is received under Section 1.3, "Filing of Documents," and/or Section 1.4, "Computation of Time," the permit may be deemed
invalid.

Before Drilling

Fresh Water Sand Protection. The operator must set and cement sufficient surface casing to protect all usable-quality water, as defined by
the Railroad Commission of Texas (RRC) Groundwater Advisory Unit (GWAU). Before drilling a well, the operator must obtain a letter from
the Railroad Commission of Texas stating the depth to which water needs protection, Write: Railroad Commission of Texas, Groundwater
Advisory Unit (GWAU), P.O. Box 12967, Austin, TX 78711-3087. File a copy of the letter with the appropriate district office.

Accessing the Well Site. If an OPERATOR, well equipment TRANSPORTER or WELL service provider must access the well site from a
roadway on the state highway system (Interstate, U.S. Highway, State Highway, Farm-to-Market Road, Ranch-to-Market Road, etc.), an
access permit is required from TxDOT. Permit applications are submitted to the respective TxDOT Area Office serving the county where the
well is located.

Water Transport to Well Site. If an operator intends to transport water to the well site through a temporary pipeline laid above
ground on the state's right-of-way, an additional TxDOT permit is required. Permit applications are submitted to the respective
TxDOT Area Office serving the county where the well is located.

^NOTIFICATION

The operator is REQUIRED to notify the district office when setting surface casing, intermediate casing, and production casing, or when
plugging a dry hole. The district office MUST also be notified if the operator intends to re-enter a plugged well or re-complete a well into a
different regulatory field. Time requirements are given below. The drilling permit number MUST be given with such notifications.

During Drilling

Permit at Drilling Site : A copy of the Form W-l Drilling Permit Application, the location plat, a copy of Statewide Rule 13
alternate surface casing setting depth approval from the district office, if applicable, and this drilling permit must be kept at the
permitted well site throughout drilling operations.

*Notification of Setting Casing : The operator MUST call in notification to the appropriate district office (phone number shown the
on permit) a minimum of eight (8) hours prior to the setting of surface casing, intermediate casing, AND production casing. The
individual giving notification MUST be able to advise the district office of the drilling permit number.

*Notification of Re-completion/Re-entry : The operator MUST call in notification to the appropriate district office (phone number
shown on permit) a minimum of eight (8) hours prior to the initiation of drilling or re-completion operations. The individual giving
notification MUST be able to advise the district office of the drilling permit number.

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 1 of 5


-------
Completion and Plugging Reports

Hydraulic Fracture Stimulation using Diesel Fuel: Most operators in Texas do not use diesel fuel in hydraulic fracturing fluids.

Section 322 of the Energy Policy Act of 2005 amended the Underground Injection Control (UIC) portion of the federal Safe Drinking Water
Act (42 USC 300h(d)) to define "underground Injection" to EXCLUDE " ...the underground injection of fluids or propping agents (other
than dieselfluels) pursuant to hydraulic fracturing operations related to oil, gas, or geothermal production activities." (italic and underlining
added.) Therefore, hydraulic fracturing may be subject to regulation under the federal UIC regulations if diesel fuel is injected or used as a
propping agent. EPA defined "diesel fuel" using the following five (5) Chemical Abstract Service numbers: 68334-30-5 Primary Name: Fuels,
diesel; 68476-34-6 Primary Name: Fuels, diesel, No. 2; 68476-30-2 Primary Name: Fuel oil No. 2; 68476-31-3 Primary Nmae: Fuel oil, No.
4; and 8008-20-6 Primary Name: Kerosene. As a result, an injection well permit would be required before performing hydraulic fracture
stimulation using diesel fuel as defined by EPA on any well in Texas. Hydraulic fracture stimulation using diesel fuel as defined by EPA on a
well in Texas without an injection well permit could result in enforcement action.

Producing Well: Statewide Rule 16 states that the operator of a well shall file with the Commission the appropriate completion report
within thirty (30) days after completion of the well or within ninety (90) days after the date on which the drilling operation is completed,
whichever is earlier. Completion of the well in a field authorized by this permit voids the permit for all other fields included in the permit
unless the operator indicates on the initial completion report that the well is to be a dual or multiple completion and promptly submits an
application for multiple completion. All zones are required to be completed before the expiration date on the existing permit. Statewide Rule
40(d) requires that upon successful completion of a well in the same reservoir as any other well previously assigned the same acreage,
proration plats and P-15s (if required) must be submitted with no double assignment of acreage.

Dry or Noncommercial Hole : Statewide Rule 14(b)(2) prohibits suspension of operations on each dry or non-commercial well without
plugging unless the hole is cased and the casing is cemented in compliance with Commission rules. If properly cased, Statewide Rule 14(b)(2)
requires that plugging operations must begin within a period of one (1) year after drilling or operations have ceased. Plugging operations must
proceed with due diligence until completed. An extension to the one-year plugging requirement may be granted under the provisions stated in
Statewide Rule 14(b)(2).

Intention to Plug : The operator must file a Form W-3 A (Notice of Intention to Plug and Abandon) with the district office at least five (5)
days prior to beginning plugging operations. If, however, a drilling rig is already at work on location and ready to begin plugging operations,
the district director or the director's delegate may waive this requirement upon request, and verbally approve the proposed plugging
procedures.

*Notification of Plugging a Dry Hole : The operator MUST call in notification to the appropriate district office (phone number shown on
permit) a minimum of four (4) hours prior to beginning plugging operations. The individual giving the notification MUST be able to advise
the district office of the drilling permit number and all water protection depths for that location as stated in the Texas Commission on
Environmental Quality letter.

DIRECT INQUIRIES TO: DRILLING PERMIT SECTION, OIL AND GAS DIVISION

PHONE
(512) 463-6751

MAIL:

PO Box 12967
Austin, Texas, 78711-2967

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 2 of 5


-------
RAILROAD COMMISSION OF TEXAS
OIL & GAS DIVISION

PERMIT TO DRILL, DEEPEN, PLUG BACK, OR RE-ENTER ON A REGULAR OR ADMINISTRATIVE EXCEPTION LOCATION

PERMIT NUMBER

839303

DATE PERMIT ISSUED OR AMENDED
04/27/2018

DISTRICT

8A

API NUMBER

42-501-36998

FORM W-l RECEIVED

04/25/2018

COUNTY

YOAKUM

TYPE OF OPERATION

New Drill

WELLBORE PROFILE(S)

Vertical

ACRES

640.0

OPERATOR 748093
SANTA FE MIDSTREAM PERMIAN LLC

5830 GRANITE PKWY STE 1025
PLANO, TX 75024-0000

NOTICE

This permit and any allowable assigned may
be revoked if payment for fee(s) submitted to
the Commission is not honored.
District Office Telephone No:

(806) 698-6509

LEASE NAME

RATTLESNAKE AGI

WELL NUMBER

1

LOCATION

7.3 miles NW direction from DENVER CITY

TOTAL DEPTH

12000

Section, Block and/or

SECTION 733 BLOCK D ABSTRACT 89
SURVEY GIBSON, J H

DISTANCE TO SURVEY LINES

200.0 ft NORTH 200.0 ft WEST

DISTANCE TO NEAREST LEASE LINE
200.0

DISTANCE TO LEASE LINES

200.0 ft NORTH 200.0 ft WEST

DISTANCE TO NEAREST WELL ON LEASE
See FIELD(s) Below

FIELD(s) and LIMITATIONS:

* SEE FIELD DISTRICT FOR REPORTING PURPOSES *

FIELDNAME	ACRES	DEPTH WELL#	DIST

LEASE NAME	NEAREST LEASE	NEAREST WELL

WASSON	"640!0	12000	1	8A

RATTLESNAKE AGI	200 0	0.0

This is a hydrogen sulfide field. This well shall be drilled in accordance with SWR 36.

Do not use this well for injection/disposal/hydrocarbon storage purposes without approval by the Environmental Services section of the Railroad Commission,
Austin, Texas office.

WASSON, NORTH (SAN ANDRES)	"64o!o	12000	1	8A

RATTLESNAKE AGI	200.0	0.0

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 3 of 5


-------
This is a hydrogen sulfide field. This well shall be drilled in accordance with SWR 36.

Do not use this well for injection/disposal/hydrocarbon storage purposes without approval by the Environmental Services section of the Railroad Commission,
Austin, Texas office.

THE FOLLOWING RESTRICTIONS APPLY TO ALL FIELDS
This well shall be completed and produced in compliance with applicable special field or statewide spacing and density rules. If this well is
to be used for brine mining, underground storage of liquid hydrocarbons in salt formations, or underground storage of gas in salt formations,
a permit for that specific purpose must be obtained from Environmental Services prior to construction, including drilling, of the well in
accordance with Statewide Rules 81, 95, and 97.

This well must comply to the new SWR 3.13 requirements concerning the isolation of any potential flow zones and zones with corrosive
formation fluids. See approved permit for those formations that have been identified for the county in which you are drilling the well in.

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 4 of 5


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Railroad Commission of Texas

Oil and Gas Division

SWR #13 Formation Data
YOAKUM (501) COUNTY

l-'oniiiilioii

Koniiirks

Order

I.ITcc(i\c
Diilo

RED BED-SANTA ROSA



1

01/01/2014

YATES



2

01/01/2014

SAN ANDRES

high flows, H2S, corrosive

3

01/01/2014

GLORIETA



4

01/01/2014

CLEARFORK

Active C02 Flood

5

01/01/2014

WICHITA



6

01/01/2014

LEONARD



7

01/01/2014

WOLFCAMP



8

01/01/2014

PENNSYLVANIAN



9

01/01/2014

STRAWN



10

01/01/2014

MISSISSIPPIAN



11

01/01/2014

DEVONIAN



12

01/01/2014

DEVONIAN-SILURIAN



13

01/01/2014

The above list may not be all inclusive, and may also include formations that do not intersect all wellbores. The listing order of the Formation
information reflects the general stratigraphic order and relative geologic age. This is a dynamic list subject to updates and revisions. It is the
operator's responsibility to make sure that at the time of spudding the well the most current list is being referenced. Refer to the RRC website
at the following address for the most recent information, http://www.rrc.texas.gov/oil-gas/compliance-enforcement/rule-13-geologic-
formation-info

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 5 of 5


-------
B-4

RAILROAD COMMISSION OF TEXAS	Form G-1

1701 N. Congress	Status:	Approved

P.O. Box 12967	Date:	07/25/2019

Austin, Texas 78701-2967	Tracking No.:	205926

GAS WELL BACK PRESSURE TEST, COMPLETION OR RECOMPLETION REPORT, AND LOG

OPERATOR INFORMATION

Operator Name: santa fe midstream permian llc	Operator No.: 748093

Operator Address: 5830 granite pkwy ste 1025 plano, tx 75024-0000

WELL INFORMATION

API No.: 42-501-36998

County: YOAKUM

Well No.: 1

RRC District No.: 8A

Lease Name: RATTLESNAKE AG I

Field Name: WASSON

RRC Gas ID No.: 286838

Field No.: 95397001

Location: Section: 733, Block: D, Survey: GIBSON, J H, Abstract: 89



Latitude:

Longitude:

This well is located 7.3 miles in a nw



direction from Denver city,



which is the nearest town in the county.



FILING INFORMATION

Purpose of filing: Well Record Only



Type of completion: New Well



Well Type: Active UIC

Completion or Recompletion Date: 08/31/2018

Type of Permit

Date Permit No.

Permit to Drill, Plug Back, or Deepen

04/27/2018 839303

Rule 37 Exception



Fluid Injection Permit



O&G Waste Disposal Permit

11/14/2018 15848

Other:



COMPLETION INFORMATION

ISpud date: 07/16/2018

Date of first production after rig released: 08/31/2018 I

Date plug back, deepening, recompletion, or Date plug back, deepening, recompletion, or

drilling operation commenced: 07/16/2018

drilling operation ended: 08/31/2018

Number of producing wells on this lease in

Distance to nearest well in lease &

this field (reservoir) including this well:

1 reservoir (ft.): 0.0

Total number of acres in lease: 640.00

Elevation (ft.): 3627 GR

Total depth TVD (ft.): 11980

Total depth MD (ft.):

Plug back depth TVD (ft.): 11980

Plug back depth MD (ft.):

Was directional survey made other than

Rotation time within surface casing (hours): 72.0

inclination (Form W-12)? Yes

Is Cementing Affidavit (Form W-15) attached? Yes

Recompletion or reclass? No

Multiple completion? No

Type(s) of electric or other log(s) run: Combo of Induction/Neutron/Density/Sonic

Electric Log Other Description:



Location of well, relative to nearest lease boundaries Off Lease: No

of lease on which this well is located:

200.0 Feet from the North Line and



200 0 Feet from the West Line of the



rattlesnake agi Lease.

FORMER FIELD (WITH RESERVOIR) & GAS ID OR OIL LEASE NO.

Field & Reservoir

Gas ID or Oil Lease No. Well No. Prior Service Type



Page 1 of4


-------
G1:	N/A

PACKET:	N/A

FOR NEW DRILL OR RE-ENTRY, SURFACE CASING DEPTH DETERMINED BY:
GAU Groundwater Protection Determination	Depth (ft.): 2025.0	Date: 01/12/2018

SWR 13 Exception	Depth (ft.):

GAS MEASUREMENT DATA

I Date of test: Gas measurement method(s):





Gas production during test (MCF):







Was the well preflowed for 48 hours? No







Orif. or 24 hr. Coeff.

Run Line Choke Orif. Or Choke Static Pm or Diff
No. size Size (in.) (in.) Choke (in.) (hw)

Flow

Temp Temp. Gravity
(°F) (l-tt) (hg)

Compress
(Fpv)

Volume
(MCF/day)

N/A







FIELD DATA AND PRESSURE CALCULATIONS

Gravity (dry gas):

Gas-Liquid Hydro Ratio (CF/Bbl):

Avg. shut in temp. (°F):

Gravity (liquid hydrocarbons) (Deg. API):

Gravity (mixture): Gmix=

Bottom hole temp, and depth: °F@ ft

Run No. Time of Run (Min.)

Choke Size (in.) Wellhead Pressure (PSIA) Wellhead Flow Temp (°F )

N/A



CASING RECORD

Casing Hole Setting Multi - Multi -	Cement Slurry Top of TOC

Type of

Size

Size

Depth Stage Tool Stage Shoe Cement Amount Volume Cement Determined

Row Casing

(in.)

(in.)

(ft.)

Depth (ft.) Depth (ft.)

Class

(sacks)

(cu. ft.)

(ft.)

By

1 Surface

13 3/8

17 1/2

504



c

510

687.5

0

Circulated to Surface

3 Intermediate

9 5/8

12 1/4

5498

5498

c

485

797.0

4275

Circulated to Surface

2 Intermediate

13 3/8

17 1/2

5498

4275

c

1650

3045.0

0

Circulated to Surface

6 Conventional Production

7

8 3/4

11023



WELL

60

337.0

9575

Calculation











LOCK









5 Conventional Production

7

8 3/4

11023

5591

PREM

380

906.5

0

Circulated to Surface











PLUS









4 Conventional Production

7

8 3/4

11023

9575

PREM

380

906.5

5591

Calculation











PLUS









LINER RECORD









Cement

Slurry

Top of

TOC

Liner Hole

Liner

Liner

Cement

Amount

Volume

Cement

Determined

Row Size (in.) Size (in.)

Top (ft.)

Bottom (ft.)

Class

(sacks)

(cu. ft.)

(ft.)

By

N/A















TUBING RECORD

Row

Size (in.)

Depth Size (ft.)

Packer Depth (ft.)/Type

1

3 1/2

10966

10966 / HALLIBURTON







BWD

PRODUCING/INJECTION/DISPOSAL INTERVAL

Row

Open hole?

From (ft.)

To (ft.)

1

Yes

L 11025

11980

Page 2 of4


-------
ACID, FRACTURE, CEMENT SQUEEZE,

CAST IRON BRIDGE PLUG, RETAINER, ETC.

Was hydraulic fracturing treatment performed? No

Is well equipped with a downhole actuation



sleeve? No

If yes, actuation pressure (PSIG):

Production casing test pressure (PSIG) prior to

Actual maximum pressure (PSIG) during hydraulic

hydraulic fracturing treatment:

fracturing:

Has the hydraulic fracturing fluid disclosure been



reported to FracFocus disclosure registry (SWR29)?

No

Row Type of Operation Amount and Kind of Material Used Depth Interval (ft.)

N/A



FORMATION RECORD

Is formation

Formations	Encountered Depth TVD (ft.) Depth MP (ft.) isolated? Remarks

YATES

Yes

3019.0

Yes



SAN ANDRES - HIGH FLOWS, H2S,

Yes

4465.0

Yes



CORROSIVE









GLORIETA

Yes

6316.0

Yes



CLEARFORK - ACTIVE C02 FLOOD

Yes

6492.0

Yes



WICHITA

Yes

8628.0

Yes



UPPER WOLFCAMP

Yes

9239.0

Yes



STRAWN

Yes

10030.0

Yes



ATOKA

Yes

10230.0

Yes



WOODFORD

Yes

10973.0

Yes



DEVONIAN

Yes

11036.0

No

DISPOSAL

WRISTEN

Yes

11268.0

No

DISPOSAL

FUSSELMAN

Yes

11538.0

No

DISPOSAL

MONTOYA

Yes

11974.0

No

DISPOSAL

RED BED-SANTA ROSA

No



No

NOT IN AREA

LEONARD

No



No

NOT IN AREA

WOLFCAMP

No



No

NOT IN AREA

PENNSYLVANIAN

No



No

NOT IN AREA

STRAWN

No



No

NOT IN AREA

MISSISSIPPIAN

No



No

NOT IN AREA

Do the producing interval of this well produce H2S with a concentration in excess of 100 ppm (SWR 36)?	No

s the completion being downhole commingled (SWR 10)?	No

REMARKS

NEW WELL PUTTING ON SCHEDULE.

Page 3 of4


-------
OPERATOR'S CERTIFICATION

Printed Name: Karen Zornes

Title:

Telephone No.: (281) 872-9300

Date Certified: 06/25/2019

Page 4 of4


-------
APPENDIX C - GAS COMPOSITION


-------
C-1

1 rv » n,,

natural Gas Analysis

www.permianls.com
575.397.3713 2609 W Marland HobbS NM 88240

11093G

30/30 Acid Gas

Sample Point Code

Sample Point Name

C6+ Gas Analysis Report

30/30 Acid Gas

Sample Point Location

Laboratory Services

Date Sampled

2021048523

1781

E Benavides - Spot

Source Laboratory



Lab File No

Container Identity

Sampler

USA

USA



USA

Texas

District

Area Name



Field Name

Facility Name

Nov 16, 2021



Nov 16, 2021

Nov 19, 2021 09:59

Nov 19, 2021

Date Effective

System Administrator

Ambient Temp (°F)

Flow Rate (Mcf)

Analyst

Date Received

21 @ 129

Press PSI @ Temp °F
Source Conditions

Date Reported

Stakeholder Midstream

30/30

Operator

Lab Source Description

Component

Normalized
Mol %

Un-Normalized
Mol %

GPM

H2S (H2S)

9.2000

9.2



Nitrogen (N2)

0.0000

0



C02 (C02)

89.6780

98.775



Methane (CI)

0.3030

0.331



Ethane (C2)

0.0580

0.063

0.0150

Propane (C3)

0.1080

0.118

0.0300

I-Butane (IC4)

0.0000

0

0.0000

N-Butane (NC4)

0.0250

0.027

0.0080

I-Pentane (IC5)

0.0000

0

0.0000

N-Pentane (NC5)

0.0000

0

0.0000

Hexanes Plus (C6+)

0.6280

0.686

0.2710

TOTAL

100.0000

109.2000

0.3240

Method(s): Gas C6+ - GPA 2261, Extended Gas - GPA 2286, Calculations - GPA 2172

Analyzer Information
Device Type: Gas Chromatograph Device Make: Shimadzu
Device Model: GC-2014	Last Cal Date: Nov 14, 2021

Gross Heating Values (Real, BTU/ft3)

14.696 PSI @ 60.00 A°F	14.65 PSI @ 60.00 A°F

Dry	Saturated	Dry	Saturated

98.7	98.00	98.4	97.7

Calculated Total Sample Properties

GPA2145-16 Calculated at Contract Conditions
Relative Density Real	Relative Density Ideal

1.5042	1.4956

Molecular Weight

43.3157

C6 - 60.000%

C6+ Group Properties

Assumed Composition

C7 - 30.000%

C8 - 10.000%

Field H2S

92000 PPM

PROTREND STATUS:	DATA SOURCE:

Passed By Validator on Nov 21, 2021 Imported

PASSED BY VALIDATOR REASON:

Close enough to be considered reasonable.

VALIDATOR:

Dustin Armstrong

VALIDATOR COMMENTS:

OK

Nov 22, 2021 7:57 a

Powered By ProTrend -www.criticalcontrol.com

Page 1 of 1


-------
APPENDIX D - MONITORING AREA MAPS

APPENDIX D-l: MMA MAP
APPENDIX D-2: AMA MAP


-------
A-1143

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& Stabilized Plume
with

1/2-Mile Maximum Monitoring Area (MMA)

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN • HOUSTON jfc CALGARY • WICHITA
DENVER • COLLEGE STATION T BATON ROUGE • EDMONTON

Rattlesnake AGI No. 1 SHL

I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

1560


-------
A-1143

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& 19-Year Plume
with

1/2-Mile Active Monitoring Area (AMA)

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

1560


-------
APPENDIX E - FACILITY SAFETY PLOT PLANS


-------
PLANT NORTH

LEGEND

•

FIRE EXTINGUISHER

~

SCBA/ESCAPE PACK

~

WIND SOCK

®

LEL/H2S MONITOR



ESD BUTTON

H

STROBE LIGHTS



HORN

E-1



	r

i| 1 | |—1 l\ 71 1 k 1 A 1 \ W—1 / \ 1 1









—\

JKI 1 IMINAKY 1 ()l>











	pn/ic\A/	







0

NO.

05/11 / 22
DATE

INITIAL RELEASE K C V 1 C V V
REVISION DESCRIPTION

KLD
BY

BEC
FCE

JB
CLIENT

CHAR1S ENGINEERING. LLC
"IX ENG. FIRM NO. F-1B8B4
MIDLAND. IX

STAKEHOLDER
MIDSTREAM

CLIENT ;

PROJECT ;

TITLE :

STAKEHOLDER MIDSTREAM

30-30 GAS PLANT

SAFETY EQUIPMENT PLOT PLAN

1" = 50'—0"

DATE

5/11/22

ME—PLNP—AOOO—0004

A


-------
APPENDIX F - MMA/AMA REVIEW MAPS

APPENDIX F-l: PLUME BOUNDARY AT END OF INJECTION, STABILIZED PLUME BOUNDARY AND MAXIMUM
MONITORING AREA MAP

APPENDIX F-2: ACTIVE MONITORING AREA MAP

APPENDIX F-3: OIL AND GAS WELLS WITHIN THE MMA MAP

APPENDIX F-4: OIL AND GAS WELLS WITHIN THE MMA LIST

APPENDIX F-5: INJECTION INTERVAL PENETRATING WELLS WITHIN THE MMA MAP

APPENDIX F-6: GROUNDWATER WELLS WITHIN THE MMA

APPENDIX F-7: WELLBORE SCHEMATICS FOR INJECTION INTERVAL PENETRATING WELLS


-------
A-1143

A-545

A-1866
A-572

A-£ 58

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& Stabilized Plume
with

1/2-Mile Maximum Monitoring Area (MMA)

Stakeholder Midstream
Yoakum Co., TX

A-1314

A-549

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY

1



ENGINEERS

ADVISORS



AUSTIN • HOUSTON jj

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

Rattlesnake AGI No. 1 SHL

I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

J Plume Boundary at End of Injection

1560


-------
A-1143

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& 19-Year Plume
with

1/2-Mile Active Monitoring Area (AMA)

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY

1



ENGINEERS

ADVISORS



AUSTIN • HOUSTON jj

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

F-2

Rattlesnake AGI No. 1 SHL

1 Active Monitoring Area Boundary

1 9-Year Plume

J Plume Boundary at End of Injection

Abstract

Note: All coordinates shown are in NAD83 (DD).

MAP EXTENT

~


-------
A-1866



A-1314

iiiiiiiiij

36998 l\

RATTLESNAKE AGI NO

33.0513499,1

-102.90450576

00000

32541

00261

32531

00000

iiiiiiiiii

00000"

00000

00262

000

\ 00645 •

00050

00643s

00644

00000

33349.

33530

00057

33173

32702

34984\

32065

00059

33172

33531

A-1484

33531'

32703

33351

32064

,00061

00000

00060

00058

32704

33 no 3

00065

00068

00064

^067 ^

32945

32975

32077

32075

: 30600

32076

36156

00267

00266

00066 3271 i

00063

02992

02991

02990

02989 35820

A-1816

34878

32070

36155

36151 30604 35791 30602

30606

JO fyy

36152

35821

30630

32072

36153

30601

30605

35794

35793 30598

36150

30603

36048

36154

35180

35703

35701

35705

30000

=3058.4;

32270

33065

1:34099;

00755

30583

30629

35961'

34797

56428 00000

• °l

36098

-34023 •

00768J

34124

30580

36327

33843

LONQUIST & CO LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN • HOUSTON jfc CALGARY • WICHITA
DENVER • COLLEGE STATION T BATON ROUGE • EDMONTON

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

+ Rattlesnake AC I No. 1 SHL
| ~ ~ ™ 1/2-Mile Buffer from Max. Plume Extent (MMA)
I ~ Z Z Z Combined Maximum Plume Extent
1	Stabilized Plume

I ~ ~ ~ Z Plume Boundary at End of Injection
Abstract

	Lateral (21)

API (42-501-...) SHL Status - Type (Count)
O Horizontal Surface Location (21)

•	Active - Oil (93)

Active - Injection/Disposal (21)

•» Active - Injection/Disposal from Oil (22)
X Plugged - Oil (69)

^ Plugged - Gas (1)

Plugged- Injection/Disposal from Oil (1)

Shut-In - Oil (1)

TA - Injection/Disposal (3)

TA - Injection/Disposal from Oil (7)

"0" Dry Hole (6)
o Permitted Location (2)
0 Canceled/Abandoned Location (6)
X Expired Permit (7)

API (42-501-...) BHL Status - Type (Count)

•	Active - Oil (11)

•A Active - Injection/Disposal from Oil (1)

Shut-In - Oil (1)

TA - Injection/Disposal from Oil (1)

o Permitted Location (4)

X Expired Permit (3)

Sou rce:

1.)	Oil/Cas Well SHL Data: DI-2022

2.)	Oil/Cas Well BHL Data: DI-2022

3.)	Oil/Cas Well Directional Data: DI-2022

* Note: All coordinates shown are in NAD83 (DD). *

Rattlesnake AGI No. 1
Maximum Monitoring Area
with

1/2-Mile MMA Oil/Gas Well
Area of Review

Stakeholder Midstream
Yoakum Co., TX

1

A-1531

A-1064

A-87

A-1483

A-1641

A-499

VI55 !

i .-1777

A


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

F-4

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250101829

DENVER UNIT

2215W

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5300

5300

2215W

4250101835

DENVER UNIT

2207

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5185

5185

2207

4250130914

DENVER UNIT

2222

OCCIDENTAL PERMIAN LTD.

Active - Oil





2222

4250101832

DENVER UNIT

2201W

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5190

5190

2201W

4250101826

DENVER UNIT

2203

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5250

5250

2203

4250101319

ROBERTS UNIT

4532W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5200

5200

4532W

4250130629

ROBERTS UNIT

4535

APACHE CORPORATION

Active - Oil

5280

5280

4535

4250130583

ROBERTS UNIT

4525

APACHE CORPORATION

Active - Oil

5286

5286

4525

4250101318

ROBERTS UNIT

4541

APACHE CORPORATION

TA - Injection/Disposal from Oil

5240

5240

4541

4250101889

ROBERTS UNIT

3614

APACHE CORPORATION

Plugged - Oil

5180

5180

3614

4250130598

Roberts Unit

3647

APACHE CORPORATION

Plugged - Oil

5281

5281

3647

4250130603

ROBERTS UNIT

3626

APACHE CORPORATION

Plugged - Oil

5289

5289

3626

4250102992

ROBERTS UNIT

3612W

APACHE CORPORATION

Plugged - Oil

5226

5226

3612W

4250100066

ROBERTS UNIT

3532

APACHE CORPORATION

Plugged - Oil

5231

5231

3532

4250101886

ROBERTS UNIT

3631

APACHE CORPORATION

Plugged - Oil





3631

4250101885

ROBERTS UNIT

3641

APACHE CORPORATION

Plugged - Oil

5212

5212

3641

4250100068

ROBERTS UNIT

3521

APACHE CORPORATION

Plugged - Oil

5225

5225

3521

4250100064

ROBERTS UNIT

3541

APACHE CORPORATION

Plugged - Oil

5264

5264

3541

4250102014

ROBERTS UNIT

2443

APACHE CORPORATION

Plugged - Oil

5226

5226

2443

4250100050

ROBERTS UNIT

1654

APACHE CORPORATION

Plugged - Oil

5198

5198

1654

4250133531

ROBERTS UNIT

2443A



Active - Injection/Disposal

5325

5325

2443A

4250133502

ROBERTS UNIT

2527A



Plugged - Oil

5308

5308

2527A

4250100000

C. A. ELLIOTT

6

AMERICAN LIBERTY OIL CO

Plugged - Oil

5229

5229

6

4250100000

C. A. ELLIOTT

7

AMERICAN LIBERTY AND ATLANTIC

Active - Oil

5182

5182

7

4250100000

GEO CLEVELAND

1

DELFERN OIL CO

Dry Hole

5071

5071

1

4250100000

JAMES H. LYNN

1614

AMERICAN LIBERTY

Active - Oil

5169

5169

1614

4250100000

J. H. LYNN

1634

AMERICAN LIBERTY

Active - Oil

5160

5160

1634

4250100000

A. T. MORRIS

1

ATLANTIC

Active - Oil

5235

5235

1

4250100000

A. T. MORRIS

2

AMERICAN LIBERTY OIL CO

Plugged - Oil

5179

5179

2

4250100000

W.J. CARPENTER

1642

AMERICAN LIBERTY OIL COMPANY

Plugged - Oil

5183

5183

1642

4250100000

E.S.SMITH

1

CREAT WESTERN FROD

Dry Hole

5216

5216

1

4250130607

ROBERTS UNIT

3546



Active - Oil





3546

4250135958

DENVER UNIT

2247

OCCIDENTAL PERMIAN LTD.

Active - Oil

2333

2333

2247

4250131542

DENVER UNIT

2229

SHELL OIL COMPANY

Dry Hole

2409

2409

2229

4250101320

ROBERTS UNIT

4543

APACHE CORPORATION

Active - Injection/Disposal from Oil

5120

5120

4543

4250137301

MILLER

8H

AMTEX ENERGY, INC.

Active - Oil

5157

5157

8H

4250137304

MILLER 732 C

10H

AMTEX ENERGY, INC.

Permitted Location

5157

5157

10H

4250137305

MILLER 732 D

11H

AMTEX ENERGY, INC.

Permitted Location

5157

5157

11H

4250101888

ROBERTS UNIT

3634W

APACHE CORPORATION

Plugged - Oil

5160

5160

3634W


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250101031

ROBERTS UNIT

3534W

APACHE CORPORATION

Plugged - Oil

5164

5164

3534W

4250101828

DENVER UNIT

2208

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5170

5170

2208

4250101032

ROBERTS UNIT

3544

APACHE CORPORATION

Plugged - Oil

5170

5170

3544

4250101841

DENVER UNIT

2206

OCCIDENTAL PERMIAN LTD.

TA - Injection/Disposal from Oil

5177

5177

2206

4250101842

ROBERTS UNIT

3643W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5180

5180

3643W

4250101035

ROBERTS UNIT

3533W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5180

5180

3533W

4250132704

ROBERTS UNIT

2615

APACHE CORPORATION

Active - Oil

5180

5180

2615

4250100261

ROBERTS UNIT

1643W

APACHE CORPORATION

Plugged - Oil

5180

5180

1643W

4250101323

ROBERTS UNIT

4542W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5182

5182

4542W

4250102989

ROBERTS UNIT

3642W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5182

5182

3642W

4250102991

ROBERTS UNIT

3622W

APACHE CORPORATION

Plugged - Oil

5185

5185

3622W

4250132417

MILLER

3

AMTEX ENERGY, INC.

Active - Oil

5186

5186

3

4250101025

ROBERTS UNIT

2613W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5188

5188

2613W

4250101887

ROBERTS UNIT

3644

APACHE CORPORATION

Active - Injection/Disposal from Oil

5189

5189

3644

4250101830

DENVER UNIT

2214WC

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5190

5190

2214WC

4250101103

ROBERTS UNIT

3621

APACHE CORPORATION

Plugged - Oil

5190

5190

3621

4250101024

ROBERTS UNIT

2623

APACHE CORPORATION

Plugged - Oil

5190

5190

2623

4250101023

ROBERTS UNIT

2622W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5190

5190

2622W

4250101022

ROBERTS UNIT

2632

APACHE CORPORATION

Active - Oil

5190

5190

2632

4250101019

ROBERTS UNIT

2621

APACHE CORPORATION

Active - Oil

5190

5190

2621

4250101030

ROBERTS UNIT

3524W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5193

5193

3524W

4250101829

DENVER UNIT

2205

OCCIDENTAL PERMIAN LTD.

TA - Injection/Disposal from Oil

5195

5195

2205

4250101836

DENVER UNIT

2213WC

OCCIDENTAL PERMIAN LTD.

TA - Injection/Disposal from Oil

5200

5200

2213WC

4250101833

DENVER UNIT

2202WC

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5200

5200

2202WC

4250134099

DENVER UNIT

2239WC

OCCIDENTAL PERMIAN LTD.

Dry Hole

5200

5200

2239WC

4250132717

ROBERTS UNIT

3531A

APACHE CORPORATION

TA - Injection/Disposal

5200

5200

3531A

4250101014

ROBERTS UNIT

2624W

APACHE CORPORATION

Plugged - Oil

5200

5200

2624W

4250101028

ROBERTS UNIT

3523

APACHE CORPORATION

Plugged - Oil

5205

5205

3523

4250101102

ROBERTS UNIT

3611

APACHE CORPORATION

Plugged - Oil

5206

5206

3611

4250101827

DENVER UNIT

2209W

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5210

5210

2209W

4250101015



2643

TEXACO INCORPORATED

Active - Injection/Disposal from Oil

5210

5210

2643

4250100266

ROBERTS UNIT

3522W

APACHE CORPORATION

Plugged - Oil

5211

5211

3522W

4250132632

MILLER

5

AMTEX ENERGY, INC.

Active - Oil

5213

5213

5

4250100057

ROBERTS UNIT

2512W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5213

5213

2512W

4250101890

ROBERTS UNIT

3624W

APACHE CORPORATION

Plugged - Oil

5214

5214

3624W

4250101033

ROBERTS UNIT

3543W

APACHE CORPORATION

Plugged - Oil

5215

5215

3543W

4250101012

ROBERTS UNIT

2634W

APACHE CORPORATION

Plugged- Injection/Disposal from Oil

5215

5215

2634W

4250101734

ROBERTS UNIT

2442

APACHE CORPORATION

Plugged - Oil

5215

5215

2442

4250101020

ROBERTS UNIT

2611W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5215

5215

2611W


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250100067

ROBERTS UNIT

3531

APACHE CORPORATION

Plugged - Oil

5216

5216

3531

4250101013

ROBERTS UNIT

2614W

APACHE CORPORATION

Plugged - Oil

5216

5216

2614W

4250101844

ROBERTS UNIT

3623W

APACHE CORPORATION

Plugged - Oil

5217

5217

3623W

4250131869

ROBERTS UNIT

A3534W

APACHE CORPORATION

Plugged - Oil

5220

5220

A3534W

4250102990

ROBERTS UNIT

3632W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5220

5220

3632W

4250100262

ROBERTS UNIT

1644W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5220

5220

1644W

4250132858

DENVER UNIT

2235

OCCIDENTAL PERMIAN LTD.

Shut-In - Oil

5225

5225

2235

4250100058

ROBERTS UNIT

2544W

APACHE CORPORATION

Plugged - Oil

5225

5225

2544W

4250130584

ROBERTS UNIT

4520

APACHE CORPORATION

Active - Oil

5230

5230

4520

4250130630

ROBERTS UNIT

3535

APACHE CORPORATION

Active - Oil

5230

5230

3535

4250100063

ROBERTS UNIT

3542W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5230

5230

3542W

4250132076

ROBERTS UNIT

3627

APACHE CORPORATION

Active - Oil

5230

5230

3627

4250100267

ROBERTS UNIT

3512W

APACHE CORPORATION

Plugged - Oil

5233

5233

3512W

4250101016

ROBERTS UNIT

2642W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5234

5234

2642W

4250134716

DENVER UNIT

2242

OCCIDENTAL PERMIAN LTD.

Active - Oil

5236

5236

2242

4250100061

ROBERTS UNIT

2524W

APACHE CORPORATION

Plugged - Oil

5238

5238

2524W

4250101021

ROBERTS UNIT

2633

APACHE CORPORATION

Plugged - Oil

5240

5240

2633

4250101011

ROBERTS UNIT

2644W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5241

5241

2644W

4250132541

FUTCH

1

AMTEX ENERGY, INC.

Active - Oil

5244

5244

1

4250101026

ROBERTS UNIT

2612W

APACHE CORPORATION

Plugged - Oil

5245

5245

2612W

4250100059

ROBERTS UNIT

2513W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5246

5246

2513W

4250132531

MILLER

4

AMTEX ENERGY, INC.

Plugged - Oil

5248

5248

4

4250132687

ROBERTS UNIT

2635

APACHE CORPORATION

Plugged - Oil

5248

5248

2635

4250131656

DENVER UNIT

2232WC

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5250

5250

2232WC

4250131791

DENVER UNIT

2231

SHELL OIL COMPANY

Canceled/Abandoned Location

5250

5250

2231

4250134118

DENVER UNIT

2238

OCCIDENTAL PERMIAN LTD.

Active - Oil

5250

5250

2238

4250101342

ROBERTS UNIT



APACHE CORPORATION

Plugged - Gas

5250

5250



4250132269

ROBERTS UNIT

3601

APACHE CORPORATION

Plugged - Oil

5250

5250

3601

4250101843

ROBERTS UNIT

3633W

APACHE CORPORATION

Plugged - Oil

5250

5250

3633W

4250130608

ROBERTS UNIT

3545

APACHE CORPORATION

Active - Oil

5250

5250

3545

4250132077

ROBERTS UNIT

3617

APACHE CORPORATION

Active - Oil

5250

5250

3617

4250134963

DENVER UNIT

2244WC

OCCIDENTAL PERMIAN LTD.

TA- Injection/Disposal

5251

5251

2244WC

4250100060

ROBERTS UNIT

2514

APACHE CORPORATION

Plugged - Oil

5251

5251

2514

4250101459

DENVER UNIT

2211

OCCIDENTAL PERMIAN LTD.

Active - Oil

5252

5252

2211

4250132521

DENVER UNIT

2233W

OCCIDENTAL PERMIAN LTD.

TA- Injection/Disposal from Oil

5253

5253

2233W

4250135211

DENVER UNIT

2241

OCCIDENTAL PERMIAN LTD.

Active - Oil

5253

5253

2241

4250101837

DENVER UNIT

2212W

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5255

5255

2212W

4250132793

MILLER

6

AMTEX ENERGY, INC.

Active - Oil

5258

5258

6

4250132356

MILLER

1

AMTEX ENERGY, INC.

Active - Oil

5260

5260

1


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250101017

ROBERTS UNIT

2641

APACHE CORPORATION

Active - Oil

5260

5260

2641

4250101825

DENVER UNIT

2204W

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5264

5264

2204W

4250132416

MILLER

2

AMTEX ENERGY, INC.

Active - Oil

5269

5269

2

4250100065

ROBERTS UNIT

3511W

APACHE CORPORATION

Plugged - Oil

5270

5270

3511W

4250101018

ROBERTS UNIT

2631

APACHE CORPORATION

Active - Oil

5270

5270

2631

4250130600

ROBERTS UNIT

3645

APACHE CORPORATION

Active - Oil

5273

5273

3645

4250130580

ROBERTS UNIT

4536

APACHE CORPORATION

Active - Oil

5279

5279

4536

4250130599

ROBERTS UNIT

3646

APACHE CORPORATION

Active - Oil

5279

5279

3646

4250130602

ROBERTS UNIT

3635

APACHE CORPORATION

Active - Oil

5283

5283

3635

4250132997

DENVER UNIT

2208WC

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5284

5284

2208WC

4250130601

ROBERTS UNIT

3636

APACHE CORPORATION

Active - Oil

5286

5286

3636

4250132174

SHEPHERD

1

YOUNG, MARSHALL R., OIL CO.

Dry Hole

5286

5286

1

4250130604

ROBERTS UNIT

3625

APACHE CORPORATION

Active - Oil

5287

5287

3625

4250130912

DENVER UNIT

2224

OCCIDENTAL PERMIAN LTD.

Active - Oil

5288

5288

2224

4250130911

DENVER UNIT

2225

OCCIDENTAL PERMIAN LTD.

Active - Oil

5290

5290

2225

4250130609

ROBERTS UNIT

4530

APACHE CORPORATION

Active - Oil

5291

5291

4530

4250130605

ROBERTS UNIT

3616

APACHE CORPORATION

Plugged - Oil

5291

5291

3616

4250130606

ROBERTS UNIT

3615

APACHE CORPORATION

Active - Oil

5293

5293

3615

4250133172

ROBERTS UNIT

2523

CONOCOPHILLIPS COMPANY

Plugged - Oil

5295

5295

2523

4250132739

CLEVELAND

1

HIGHLAND PRODUCTION COMPANY

Plugged - Oil

5300

5300

1

4250133064

DENVER UNIT

2238

SHELL WESTERN E&P INC.

Canceled/Abandoned Location

5300

5300

2238

4250132927

DENVER UNIT

2236

OCCIDENTAL PERMIAN LTD.

Active - Oil

5300

5300

2236

4250133065

DENVER UNIT

2237

SHELL WESTERN E&P INC.

Expired Permit

5300

5300

2237

4250132270

ROBERTS UNIT

4540

APACHE CORPORATION

Active - Oil

5300

5300

4540

4250132414

ROBERTS UNIT

3523A

APACHE CORPORATION

Active - Injection/Disposal

5300

5300

3523A

4250132712

ROBERTS UNIT

3537

APACHE CORPORATION

Plugged - Oil

5300

5300

3537

4250132722

ROBERTS UNIT

3547

APACHE CORPORATION

Active - Oil

5300

5300

3547

4250132945

ROBERTS UNIT

3541A

TEXACO PRODUCING INC.

Expired Permit

5300

5300

3541A

4250132975

ROBERTS UNIT

3641A

TEXACO PRODUCING INC.

Expired Permit

5300

5300

3641A

4250132711

ROBERTS UNIT

3620

APACHE CORPORATION

Active - Oil

5300

5300

3620

4250133527

ROBERTS UNIT

2518

APACHE CORPORATION

Active - Oil

5300

5300

2518

4250132714

ROBERTS UNIT

2637

APACHE CORPORATION

Plugged - Oil

5300

5300

2637

4250133351

ROBERTS UNIT

2526

TEXACO PRODUCING INC.

Expired Permit

5300

5300

2526

4250132703

ROBERTS UNIT

2516

APACHE CORPORATION

Plugged - Oil

5300

5300

2516

4250133348

ROBERTS UNIT

2533

TEXACO PRODUCING INC.

Expired Permit

5300

5300

2533

4250132702

ROBERTS UNIT

2515

APACHE CORPORATION

Active - Oil

5300

5300

2515

4250133350

ROBERTS UNIT

2525

APACHE CORPORATION

Active - Oil

5300

5300

2525

4250133498

ROBERTS UNIT

2532

TEXACO PRODUCING INC.

Expired Permit

5300

5300

2532

4250133173

ROBERTS UNIT

2522

APACHE CORPORATION

Active - Oil

5300

5300

2522


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250133499

ROBERTS UNIT

2527

TEXACO PRODUCING INC.

Dry Hole

5300

5300

2527

4250133530

ROBERTS UNIT

2507

APACHE CORPORATION

Active - Oil

5300

5300

2507

4250132685

ROBERTS UNIT

2638

APACHE CORPORATION

Plugged - Oil

5302

5302

2638

4250133349

ROBERTS UNIT

2517

APACHE CORPORATION

Active - Oil

5302

5302

2517

4250132718

ROBERTS UNIT

3532A

APACHE CORPORATION

Active - Injection/Disposal

5304

5304

3532A

4250132713

ROBERTS UNIT

2625

APACHE CORPORATION

Active - Oil

5308

5308

2625

4250133502

ROBERTS UNIT

2527A

APACHE CORPORATION

Plugged - Oil

5308

5308

2527A

4250132716

ROBERTS UNIT

3526

APACHE CORPORATION

Active - Oil

5309

5309

3526

4250100645

ROBERTS UNIT

1624W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5309

5309

1624W

4250130913

DENVER UNIT

2223

OCCIDENTAL PERMIAN LTD.

Active - Oil

5310

5310

2223

4250132686

ROBERTS UNIT

2636

APACHE CORPORATION

Active - Oil

5310

5310

2636

4250101457

DENVER UNIT

2210

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5325

5325

2210

4250133529

ROBERTS UNIT

2508

APACHE CORPORATION

Plugged - Oil

5325

5325

2508

4250133531

ROBERTS UNIT

2443A

APACHE CORPORATION

Active - Injection/Disposal

5325

5325

2443A

4250133528

ROBERTS UNIT

2511

APACHE CORPORATION

Active - Oil

5325

5325

2511

4250135912

ROBERTS UNIT

3771W

APACHE CORPORATION

Active - Injection/Disposal

5330

5330

3771W

4250132075

ROBERTS UNIT

3637

APACHE CORPORATION

Active - Oil

5330

5330

3637

4250132063

ROBERTS UNIT

2705

APACHE CORPORATION

Active - Oil

5330

5330

2705

4250135793

ROBERTS UNIT

3672

APACHE CORPORATION

Active - Oil

5334

5334

3672

4250135819

ROBERTS UNIT

3674W

APACHE CORPORATION

Active - Injection/Disposal

5336

5336

3674W

4250135792

ROBERTS UNIT

3671

APACHE CORPORATION

Active - Oil

5339

5339

3671

4250135820

ROBERTS UNIT

3675W

APACHE CORPORATION

Active - Injection/Disposal

5341

5341

3675W

4250135818

ROBERTS UNIT

3633RW

APACHE CORPORATION

Active - Injection/Disposal

5344

5344

3633RW

4250135790

ROBERTS UNIT

3647R

APACHE CORPORATION

Active - Oil

5345

5345

3647R

4250100768

CORNELL UNIT

3107W

XTO ENERGY INC.

Active - Injection/Disposal from Oil

5350

5350

3107W

4250130915

DENVER UNIT

2221

OCCIDENTAL PERMIAN LTD.

Active - Oil

5350

5350

2221

4250136048

ROBERTS UNIT

3634RW

APACHE CORPORATION

Active - Injection/Disposal

5350

5350

3634RW

4250135908

ROBERTS UNIT

3678W

APACHE CORPORATION

Active - Injection/Disposal

5350

5350

3678W

4250132072

ROBERTS UNIT

3525

APACHE CORPORATION

Active - Oil

5350

5350

3525

4250135915

ROBERTS UNIT

3626R

APACHE CORPORATION

Active - Oil

5350

5350

3626R

4250132281

ROBERTS UNIT

2446

APACHE CORPORATION

Active - Oil

5350

5350

2446

4250132064

ROBERTS UNIT

2704

APACHE CORPORATION

Active - Oil

5350

5350

2704

4250132280

ROBERTS UNIT

2445

APACHE CORPORATION

Plugged - Oil

5350

5350

2445

4250135791

ROBERTS UNIT

3670

APACHE CORPORATION

Active - Oil

5351

5351

3670

4250135794

ROBERTS UNIT

3673

APACHE CORPORATION

Active - Oil

5352

5352

3673

4250135821

ROBERTS UNIT

3676W

APACHE CORPORATION

Active - Injection/Disposal

5352

5352

3676W

4250135914

ROBERTS UNIT

3681W

APACHE CORPORATION

Active - Injection/Disposal

5352

5352

3681W

4250100643

ROBERTS UNIT

1634W

APACHE CORPORATION

Plugged - Oil

5353

5353

1634W

4250135796

ROBERTS UNIT

3669

APACHE CORPORATION

Active - Oil

5356

5356

3669


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250100644

ROBERTS UNIT

1614

APACHE CORPORATION

Plugged - Oil

5356

5356

1614

4250135913

ROBERTS UNIT

3680W

APACHE CORPORATION

Active - Injection/Disposal

5357

5357

3680W

4250135705

ROBERTS UNIT

3752

APACHE CORPORATION

Active - Oil

5360

5360

3752

4250135822

ROBERTS UNIT

3677W

APACHE CORPORATION

Active - Injection/Disposal

5362

5362

3677W

4250134984

ROBERTS UNIT

2626W

APACHE CORPORATION

Active - Injection/Disposal

5364

5364

2626W

4250135701

ROBERTS UNIT

3667

APACHE CORPORATION

Active - Oil

5365

5365

3667

4250132070

ROBERTS UNIT

3536

APACHE CORPORATION

Active - Oil

5370

5370

3536

4250132065

ROBERTS UNIT

2703

APACHE CORPORATION

Active - Oil

5370

5370

2703

4250100755

CORNELL UNIT

3101W

XTO ENERGY INC.

Active - Injection/Disposal from Oil

5373

5373

3101W

4250135703

ROBERTS UNIT

3668

APACHE CORPORATION

Active - Oil

5380

5380

3668

4250135229

DENVER UNIT

2240

OCCIDENTAL PERMIAN LTD.

Active - Oil

5388

5388

2240

4250136152

ROBERTS UNIT

3682W

APACHE CORPORATION

Active - Injection/Disposal

5397

5397

3682W

4250131539

DENVER UNIT

2230

SHELL OIL COMPANY

Canceled/Abandoned Location

5400

5400

2230

4250136327

ROBERTS UNIT

4547

APACHE CORPORATION

Active - Oil

5400

5400

4547

4250136154

ROBERTS UNIT

3624RW

APACHE CORPORATION

Active - Injection/Disposal

5400

5400

3624RW

4250136155

ROBERTS UNIT

3683W

APACHE CORPORATION

Active - Injection/Disposal

5402

5402

3683W

4250136156

ROBERTS UNIT

3686

APACHE CORPORATION

Active - Oil

5404

5404

3686

4250134797

CORNELL UNIT

3194

XTO ENERGY INC.

Active - Oil

5405

5405

3194

4250135696

CORNELL UNIT

113

XTO ENERGY INC.

Active - Oil

5406

5406

113

4250136150

ROBERTS UNIT

3684

APACHE CORPORATION

Active - Oil

5421

5421

3684

4250133629

CORNELL UNIT

3156

XTO ENERGY INC.

Active - Oil

5425

5425

3156

4250135961

DENVER UNIT

2246

OCCIDENTAL PERMIAN LTD.

Active - Oil

5425

5425

2246

4250135960

DENVER UNIT

2249

OCCIDENTAL PERMIAN LTD.

Active - Oil

5431

5431

2249

4250136153

ROBERTS UNIT

3623RW

APACHE CORPORATION

Active - Injection/Disposal

5439

5439

3623RW

4250135353

CORNELL UNIT

107

XTO ENERGY INC.

Active - Oil

5450

5450

107

4250135528

ROBERTS UNIT

3549

APACHE CORPORATION

Active - Oil

5452

5452

3549

4250136151

ROBERTS UNIT

3685

APACHE CORPORATION

Active - Oil

5463

5463

3685

4250135963

DENVER UNIT

2252

OCCIDENTAL PERMIAN LTD.

Active - Oil

5476

5476

2252

4250136434

ROBERTS UNIT

263H

APACHE CORPORATION

Expired Permit

5500

5500

263H

4250136433

ROBERTS UNIT

262H

APACHE CORPORATION

Expired Permit

5500

5500

262H

4250136098

CORNELL UNIT

110

XTO ENERGY INC.

Active - Injection/Disposal

5510

5510

110

4250133615

ROBERTS UNIT

2442A

APACHE CORPORATION

TA - Injection/Disposal

5516

5516

2442A

4250135180

ROBERTS UNIT

3534B

APACHE CORPORATION

Active - Injection/Disposal

5517

5517

3534B

4250136428

CORNELL UNIT

124

XTO ENERGY INC.

Active - Oil

5532

5532

124

4250134878

ROBERTS UNIT

3548

APACHE CORPORATION

Active - Oil

5550

5550

3548

4250135966

DENVER UNIT

2251

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2251

4250135962

DENVER UNIT

2250

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2250

4250135356

DENVER UNIT

2246

OCCIDENTAL PERMIAN LTD.

Expired Permit

5600

5600

2246

4250135959

DENVER UNIT

2248

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2248


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250135210

DENVER UNIT

2240

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2240

4250135211



2241

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2241

4250134710



2240

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2240

4250101845

ROBERTS UNIT

3613

APACHE CORPORATION

Active - Oil

7000

7000

3613

4250110083

RANDALL, E.

36

EXXON CORP.

Plugged - Oil

8595

8595

36

4250110046

ELLIOTT, C.A.

2

MCCLURE OIL COMPANY, INC.

Plugged - Oil

9000

9000

2

4250136692

MISS KITTY 704-669

3XH

RILEY EXPLORATION OPG CO, LLC

Expired Permit

9000

9000

3XH

4250133793

RANDALL, E.

39

XTO ENERGY INC.

Active - Oil

9000

9000

39

4250137375

RIP WHEELER 705-668

5XH

RILEY PERMIAN OPERATING CO, LLC

Permitted Location

9000

9000

5XH

4250137358

RIP WHEELER 705-668

1XH

RILEY PERMIAN OPERATING CO, LLC

Permitted Location

9000

9000

1XH

4250133843

ELLIOTT

1

DELTA C02, LLC

Plugged - Oil

9050

9050

1

4250134124

RANDALL, E

46

EXXON CORP.

Canceled/Abandoned Location

9100

9100

46

4250133792

RANDALL, E.

40

XTO ENERGY INC.

Plugged - Oil

9591

9591

40

4250110079

RANDALL, E.

32

EXXON CORP.

Plugged - Oil

9615

9615

32

4250135418

RANDALL, E.

46

XTO ENERGY INC.

Active - Oil

9650

9650

46

4250134023

RANDALL, E.

42

XTO ENERGY INC.

Active - Oil

9660

9660

42

4250134016

RANDALL, E.

43

XTO ENERGY INC.

Active - Oil

9740

9740

43

4250132388

RANDALL, E.

38

EXXON CORP.

Canceled/Abandoned Location

10300

10300

38

4250137302

MILLER 732 B

9H

AMTEX ENERGY, INC.

Active - Oil

5183

10662

9H

4250136432

ROBERTS UNIT

261 H

APACHE CORPORATION

Active - Oil

5151

11117

261 H

4250136998

RATTLESNAKE AGI

1

SANTA FE MIDSTREAM PERMIAN LLC

Active - Injection/Disposal

11980

11980

1

4250137252

MILLER SWD

7

AMTEX ENERGY, INC.

Permitted Location

13000

13000

7

4250136984

MADCAP 731-706

1XH

RILEY PERMIAN OPERATING CO, LLC

Active - Oil

5261

13274

1XH

4250137127

MISS KITTY A 669-704

25XH

RILEY PERMIAN OPERATING CO, LLC

Active - Oil

5321

13428

25XH

4250137287

MISS KITTY A 669-704

4XH

RILEY PERMIAN OPERATING CO, LLC

Shut-In - Oil

5340

13452

4XH

4250137236

MISS KITTY 669-704

2XH

RILEY PERMIAN OPERATING CO, LLC

Active - Oil

5317

13622

2XH


-------
A-1143

Rattlesnake AGI No. 1
Maximum Monitoring Area
with

1/2-Mile MMA Oil/Gas Well Penetrators
Area of Review

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 6/1/2022

Approved by: RH

LONQUIST & CO. LLC



PETROLEUM

ENERGY





ENGINEERS

ADVISORS

1

AUSTIN • HOUSTON jj

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

F-5

+ Rattlesnake AGI No. 1 SHL

I	'

I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

Stabilized Plume

J Plume Boundary at End of Injection

Abstract

API (42-501-...) SHL Status - Type (Count)

• Active - Oil (4)

Active - Injection/Disposal (1)

Plugged - Oil (4)

® Permitted Location (1)

Sou rce:

1.)	Oil/Gas Well SHL Data: DI-2022

2.)	Oil/Gas Well BHL Data: DI-2022

3.)	Oil/Gas Well Directional Data: DI-2022

* Note: All coordinates shown are in NAD83 (DD).

1560


-------
A-1143

Rattlesnake AGI No. 1
Maximum Monitoring Area
with

1/2-Mile MMA Groundwater Well
Area of Review

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY

F-6



ENGINEERS

ADVISORS

| AUSTIN • HOUSTON J

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

+ Rattlesnake AGI No. 1 SHL

|	I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

Stabilized Plume

J Plume Boundary at End of Injection

Abstract

SDRDB Groundwater Wells [TWDB-2022]

Proposed Use (Labeled with Well Report No.)
A Industrial (1)

Irrigation (5)

TWDB Groundwater Wells [TWDB-2022]

Well Type (Labeled with State Well No.)
¦ Withdrawal of Water (1)

Sou rce:

1.)	SDRDB Groundwater Well SHL Data: TWDB-2022

2.)	TWDB Groundwater Well SHL Data: TWDB-2022

3.)	Brackish Groundwater Well SHL Data: TWDB-2022
* Note: All coordinates shown are in NAD83 (DD). *

1560


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Cement Plug #9
@7'-1,013'

Cement Plug #8
@ 1,730'- 1,800'

Cement Plug #7
@ 2,031' - 2,100

Cement Plug #6
@2,430'-2,500'

Cement Plug #5
@2,660'-2,719'

Cement Plug #4
@2,790'-2,860'

Cement Plug #3
@3,172'-3,239'

Cement Plug #2
@3,765'-3,831'

Cement Plug #1
@ 3,900'-3,960'

Perfs @ 8,231
8,396', 8,420'
8,447', 8,462'

Casing Information

Label

1

2

Type

Surface

Production

OD

8-5/8"

4-1/2"

Depth Set

2,134'

9,601'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-10079

RRC District No: 8-A

Drawn: KAS

E. Randall No. 32

State/Province: Texas

Spud Date: 05/10/1965

Field: Wasson (Wichita Albany)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 18231

Date: 05/31/2022

Approved: SLP


-------
Cement Plug #5
@ 0' - 458'

Cement Plug #4
@2,070'-2,295'

Cement Plug #3
@2,780'- 3,009'

Cement Plug #2
@4,450'-4,870'

Cement Plug #1
@5,184'-5,266'

Perfs@ 9,496'-9,516'

TD@ 9,591'
PBTD @ 9,560'



DV Tool ® 4,522'

DV Tool @ 5,676'

Casing Information

Label

1

3

Type

Surface

Production

OD

9-5/8"

5-1/2"

Weight

36 lb/ft

UNK

Depth Set

2,162'

9,569'

Hole Size

12-1/4"

7-7/8"

TOC

Surface

2,350'

Volume

880 sks

5,450 sks

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

XTO Energy Inc.

Country: USA

Location: Section 833, Block D

API No: 42-501-337932

RRC District No: 8-A

Drawn: KAS

E. Randall No. 40

State/Province: Texas

Spud Date: 12/04/1992

Field: Wasson (Wichita Albany)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—





A

Perfs (5) 9,536' - 9,540'

SI

[S

: . I





DV Tool @ 5,968'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54 lb/ft

36 lb/ft
40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,129'

5,606'

9,699'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

Surface

Volume

1,790 sks

2,910 sks

1,590 sks

2-3/8" Tubing & Packer Set @ 9,331'

TD @ 9,700'
PBTD @ 9,654'

MD

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN • HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 832, Block D

API No: 42-501-33885

RRC District No: 8-A

Drawn: KAS

E. Randall No. 41L

State/Province: Texas

Spud Date: 02/05/1994

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Perfs (5) 9,533' - 9,553'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,167'

5,830'

9,658'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

440'

1,800'

Volume

1,530 sks

3,500 sks

1,050 sks

DV Tool ® 7,414'

2-3/8" Tubing & Packer Set @ 8,970'

TD @ 9,660' \-(3)
PBTD @ 9,623' W

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-34023

RRC District No: 8-A

Drawn: KAS

E. Randall No. 42L

State/Province: Texas

Spud Date: 07/01/1995

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—



Li;.

Perfs @ 9,550' - 9,538'
9,603'-9,610'

sf.

.... «¦
*'¦ •-

4/?

¦A ¦







" B ¦'





" ¦ /





?







, 4' i

,

"4

t" '

'*¦ ?r









. v.







> .¦







"A



' 'i



;



¦ 'v



„ .: '



4* •"

/











CIBP ® 8,917'

CIBP @ 9,590'

TD @ 9,740'
PBTD @ 8,917'

rv@

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,166'

5,902'

9,735'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

2,000'

Volume

1,530 sks

3,505 sks

967 sks

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 832, Block D

API No: 42-501-34016

RRC District No: 8-A

Drawn: KAS

E. Randall No. 43L

State/Province: Texas

Spud Date: 04/08/1995

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Perfs @ 8,762' - 8,782'

(Sqz w/100 sx)

Perfs @8,822'-8,831'

(Sqz w/ 75 sx)

Perfs @ 9,562' - 9,570'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft
29 lb/ft

Depth Set

2,158'

5,904'

9,620'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

1,600'

Volume

1,450 sks

5,190 sks

1,100 sks

DV Tool ® 7,482'

2-3/8" Tubing & Packer Set @ 9,552'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-34024

RRC District No: 8-A

Drawn: KAS

E. Randall No. 44

State/Province: Texas

Spud Date: 08/09/1995

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Perfs (5) 9,565' - 9,575'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,175'

5,898'

9,615'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

1,500'

Volume

1,530 sks

3,525 sks

1,170 sks

DV Tool ® 7,508'

2-3/8" Tubing Set @ 9,580'

Packer Set (5) 9,394'

TD @ 9,684'

PBTD @ 9,593'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-34017

RRC District No: 8-A

Drawn: KAS

E. Randall No. 45L

State/Province: Texas

Spud Date: 02/05/1994

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
Perfs (5) 9,504' - 9,512'

TD @ 9,650'
PBTD @ 9,594'

Casing/Tubing
Information

Label

1

2

Type

Surface

Production

OD

8-5/8"

5-1/2"

Weight

24 lb/ft

17 lb/ft

Depth Set

2,120'

9,650'

Hole Size

11"

7-7/8"

TOC

Surface

Surface

Volume

900 sks

3,400 sks

DV Tool ® 8,656' & 8,674'

2-7/8" Tubing & Packer Set @ 9,184'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

XTO Energy, Inc.

Country: USA

Location: Section 833, Block D

API No: 42-501-35418

RRC District No: 8-A

Drawn: KAS

E. Randall No. 46

State/Province: Texas

Spud Date: 05/23/2007

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
u

Cement Plug #4
@48'-60'

Cement Plug #3
@ 270' - 450'

Cement Plug #1
@7,549'-8,000'

Perfs @ 8,292' - 8,428'

Cement Plug #2
@3,273'-3,439'

Top of Cut @ 750'
Top of Cut @ 1,439'

TD ® 9,645'

v@

Casing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

5-1/2"

Depth Set

300'

3,200'

9,610'

TOC

Surface

Surface

Surface

Volume

400 sks

300 sks

425 sks

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Bonanza Oil Corp.

Country: USA

Location: Section 832, Block D

API No: 42-501-10046

RRC District No: 8-A

Drawn: KAS

C.A. Elliott No. 2

State/Province: Texas

Spud Date: 05/10/1965

Field: Wasson (Wichita Albany)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 18875

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

w

if.

II

: .



Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

48 lb/ft

40 lb/ft

26 lb/ft
28 lb/ft

Depth Set

500'

5,500'

10,695'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

Surface

Volume

350 sks

1,705 sks

1,635 sks

3-1/2" Tubing & Packer Set @ 10,650'

MD

TD @ 13,000'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Amtex Energy, Inc.

Country: USA

Location: Section 732, Block D

API No: 42-501-37252

RRC District No: 7-C

Drawn: KAS

Miller SWD No. 7 (Permitted)

State/Province: Texas

Spud Date: 08/09/1995

Field: Wasson

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

Permit Number: 16637

Date: 05/31/2022

Approved: SLP


-------
Appendix B: Submissions and Responses to Requests for Additional

Information


-------
STAKEHOLDER

I!MIDSTREAM

Subpart RR Monitoring, Reporting, and
Verification (MRV) Plan
Rattlesnake AGI #1

Yoakum County, Texas

Prepared for Stakeholder Gas Services, LLC
San Antonio, TX

By

Lonquist Sequestration, LLC
Austin, TX

Version 3
September 2022



LONQUIST

SEQUESTRATION LLC


-------
INTRODUCTION

Stakeholder Gas Services, LLC ("Stakeholder") currently has a Class II acid gas injection ("AGI") permit, issued
by the Texas Railroad Commission ("TRRC") in November 2018, for the Rattlesnake AGI #1 well, API No. 42-
501-36998. This permit was originally issued to Santa Fe Midstream Permian, LLC, in 2018 and the asset was
subsequently acquired by Stakeholder in December of 2020. This permit currently authorizes Stakeholder to
inject up to 4,500 barrels per day ("bbls/d") of treated acid gas ("TAG") into the Devonian formation at a
depth of 11,000' to 12,000' with a maximum allowable surface pressure of 2,200 psi. Since being permitted,
injection has proceeded without incident. This AGI well is associated with Stakeholder's 30-30 gas treating
and processing plant ("30-30") located in a rural, sparsely populated area of Yoakum County, Texas,
approximately seven miles northwest of the town of Plains, as shown in Figure 1.

I t

H-



Ula

homa















STAKEHOLDER
MIDSTREAM



Mexlip

TT
:

1

t

L

Y



I











H

iti































l^vas

J L















riV





r\ fV















WES

T OIL F

IELD

















































Yoakum

ink Bas.n



















Rattlesnake
AGI(RS#1)



























¦





























WASSON OIL

FIELD



° *





9
"S













W























i
|















Four Mi



	 | 1

Ji|—k s ¦/- 1 i
§



YbAKUM





GAINrS

^ Gaines







0 0.5 1 2 Miles

GEOROi

ALLEN

OIL

FIELD

# Stakeholder AGI Well

Figure 1 - Location of Rattlesnake AGI #3 Well

1


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Stakeholder is submitting this Monitoring, Reporting, and Verification ("MRV") plan to the EPA for approval
under 40 CFR §98.440(a), Subpart RR, of the Greenhouse Gas Reporting Program ("GHGRP"). In addition to
submitting this MRV plan to the EPA, Stakeholder is also applying to the TRRC for an amendment to the
Rattlesnake AGI #1 well's Class II permit to increase its authorized injection volume and maximum allowable
surface injection pressure ("MASIP"). Approval of the permit amendment will allow Stakeholder to increase
the capacity of its existing 30-30 Facility, which removes H2S and C02 from natural gas production using amine
treating, as well as increase the injection well capacity for a future gas processing facility which is currently
under development by Stakeholder. Additionally, expanded capacity allows Stakeholder to potentially
provide future disposal in its AGI well for oil and gas waste derived TAG from similar third-party gas processing
facilities. Increased disposal capacity will allow for greater gas processing capacity in the region, ultimately
helping to reduce flaring and its associated emissions. Throughout this document, both in written reference
and in modeling inputs, Stakeholder has used the applied-for expanded permit capacity of 16 million standard
cubic feet per day ("MMSCF/d"). Stakeholder plans to inject C02 for approximately 14 more years.

2


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ACRONYMS AND ABBREVIATIONS

%

°c

°F

AMA

BCF

CH4

CMG

C02

E

EOS

EPA

ESD

FG

ft

GAU

GEM

GHGs

GHGRP

H2S

md

mi

MIT

MM

MMA

MCF

MMCF

MMSCF

Feet

Percent(Percentage)

Degrees Celsius
Degrees Fahrenheit
Active Monitoring Area
Billion Cubic Feet
Methane

Computer Modelling Group

Carbon Dioxide (may also refer to other Carbon Oxides)
East

Equation of State

U.S. Environmental Protection Agency
Emergency Shutdown
Fracture Gradient
Foot (Feet)

Groundwater Advisory Unit

Computer Modelling Group's GEM 2020.11

Greenhouse Gases

Greenhouse Gas Reporting Program

Hydrogen Sulfide

Millidarcy(ies)

Mile(s)

Mechanical Integrity Test
Million

Maximum Monitoring Area
Thousand Cubic Feet
Million Cubic Feet
Million Standard Cubic Feet


-------
MSCF/D	Thousand Cubic Feet per Day

MMSCF/d	Million Standard Cubic Feet per Day

MRV	Monitoring, Reporting and Verification

v	Poisson's Ratio

N	North

NW	Northwest

OBG	Overburden Gradient

PG	Pore Gradient

pH	Scale of Acidity

ppm	Parts per Million

psi	Pounds per Square Inch

psig	Pounds per Square Inch Gauge

S	South

SE	Southeast

SF	Safety Factor

SWD	Saltwater Disposal

TAC	Texas Administrative Code

TAG	Treated Acid Gas

TOC	Total Organic Carbon

TRRC	Texas Railroad Commission

UIC	Underground Injection Control

USDW	Underground Source of Drinking Water

W	West

4


-------
TABLE OF CONTENTS

INTRODUCTION	1

ACRONYMS AND ABBREVIATIONS	3

SECTION 1 - FACILITY INFORMATION	8

Reporter number	8

Underground Injection Control (UIC) Class II Permit	8

UIC Well Identification Number	8

SECTION 2- PROJECT DESCRIPTION	9

Regional Geology	10

Regional Faulting	15

Site Characterization	15

Stratigraphy and Lithologic Characteristics	15

Upper Confining Interval - Woodford Shale	16

Injection Interval - Fasken Formation	17

Lower Confining Zone - Fusselman Formation	21

Local Structure	21

Injection and Confinement Summary	26

Groundwater Hydrology	26

Description of the Injection Process	31

Current Operations	31

Planned Operations	32

Reservoir Characterization Modeling	32

Simulation Modeling	35

SECTION 3 - DELI NATION OF MONITORING AREA	39

Maximum Monitoring Area	39

Active Monitoring Area	40

SECTION 4 - POTENTIAL PATHWAYS FOR LEAKAGE	42

Leakage from Surface Equipment	42

Leakage from Wells in the Monitoring Area	44

Oil and Gas Operations within Monitoring Area	44

Groundwater wells	48

Leakage Through Faults or Fractures	50

Leakage Through Confining Layers	51

Leakage from Natural or Induced Seismicity	51

SECTION 5 - MONITORING FOR LEAKAGE	54

Leakage from Surface Equipment	54

Leakage from Existing and Future Wells within Monitoring Area	55

Leakage through Faults, Fractures or Confining Seals	56

Leakage through Natural or Induced Seismicity	56

SECTION 6 - BASELINE DETERMINATIONS	57

Visual Inspections	57

H2S Detection	57

C02 Detection	57

Operational Data	57

Continuous Monitoring	57

Groundwater Monitoring	58

SECTION 7 - SITE SPECIFIC CONSIDERATIONS FOR MASS BALANCE EQUATION	59

5


-------
Mass of C02 Received	59

Mass of C02 Injected	59

Mass of C02 Produced	60

Mass of C02 Emitted by Surface Leakage	60

Mass of C02 Sequestered	60

SECTION 8- IMPLEMENTATION SCHEDULE FOR MRV PLAN	62

SECTION 9 - QUALITY ASSURANCE	63

Monitoring QA/QC	63

Missing Data	63

MRV Plan Revisions	64

SECTION 10- RECORDS RETENTION	65

References	66

APPENDICES	67

LIST OF FIGURES

Figure 1 - Location of Rattlesnake AGI #1 well	1

Figure 2 - Illustrative overview of Rattlesnake AGI #1 and 30-30 Facility	9

Figure 3 - Regional Map of the Permian Basin	10

Figure 4 - Stratigraphic column of the Northwest Shelf	11

Figure 5 - Stratigraphic column depicting the composition of the Silurian group	12

Figure 6 - Thickness map of the Silurian system which composes the Fusselman and Wristen group	14

Figure 7 - Type Log (42-501-10238) with tops, confining and injection zones depicted	15

Figure 8 - Core description of the Woodford Shale and Upper Silurian (Ruppel and Holtz, 1994)	16

Figure 9 - Table of reservoir properties found within the Wristen buildups and platform plays	18

Figure 10 - Rattlesnake AGI #1 open hole log (42-501-36998)	19

Figure 11 - Offset wells used for Formation Fluid Characterization	20

Figure 12 - Silurian Structure Map (subsea depths)	23

Figure 13 - Structural Northeast-Southwest Cross Section	24

Figure 14 - Structural Northwest-Southeast Cross Section	25

Figure 15 - Northwest-Southeast Cross Section of aquifers in the Rattlesnake AGI #1 well area 	27

Figure 16 - Potentiometric surfaces from wells completed in A Ogallala aquifer, B the Edwards-Trinity aquifer

and Cthe Dockum aquifer	28

Figure 17 - Regional extent of the Dockum freshwater aquifer (TWDB)	29

Figure 18 -Total dissolved solids in groundwater from the Dockum Aquifer	29

Figure 19-Regional extent of the Edwards-Trinity freshwater aquifer	30

Figure 20 - Regional extent of the Ogallala freshwater aquifer 	31

Figure 21 - 30-30 Facility Process Flow Diagram	32

Figure 22 - Permeability Distribution of Karst Limestone	34

Figure 23 - Areal View Gas Saturation Plume, 2036 (End of Injection)	37

Figure 24 - Areal View Gas Saturation Plume, 2779 (End of Density Drift)	38

Figure 25 - Well Injection Rate and Bottomhole Pressure over Time	38

Figure 26 - Plume Boundary at End of Injection, Stabilized Plume, and Maximum Monitoring Area	40

Figure 27 - Active Monitoring Area	41

Figure 28 - Site Plan, 30-30 Facility	43

Figure 29 - Rattlesnake AGI #1 Wellbore Schematic	45

Figure 30 - Oil and Gas Wells within the MMA	46

6


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Figure 31 - Penetrating Oil and Gas Wells within the MMA	47

Figure 32 - Groundwater Wells within MMA	49

Figure 33 - Seismicity Review (TexNet - 06/01/2022)	52

Figure 34 - Probabilistic Fault Slip Potential Analysis with Rattlesnake AGI #1 location	53

LIST OF TABLES

Table 1 - Analysis of Silurian-Devonian age formation fluids from nearby oil-field brine samples	20

Table 2 - Fracture Gradient Assumptions	21

Table 3 - Geologic and hydrogeologic units with accompanying lithologic descriptions near Gaines, Terry and

Yoakum Counties, Texas	26

Table 4 - Gas Composition of 30-30 Facility outlet	31

Table 5 - Modeled Initial Gas Composition	33

Table 6 - CMG Model Layer Properties	34

Table 7 - All Offset SWDs included in the model	36

Table 8 - All Offset Producers included in the model	36

Table 9 - Groundwater Well Summary	50

Table 10 - Summary of Leakage Monitoring Methods	54

7


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SECTION 1 - FACILITY INFORMATION

This section contains key information regarding the Acid Gas and C02 injection facility.

Reporter number:

•	Gas Plant Facility Name: 30-30 Gas Plant

•	Greenhouse Gas Reporting Program ID: 574501

o Currently reporting under Subpart UU

•	Operator: Stakeholder Gas Services, LLC

Underground Injection Control (UIC) Permit Class: Class II

The TRRC regulates oil and gas activities in Texas and has primacy to implement the Underground Injection
Control ("UIC") Class II program. TRRC classifies the Rattlesnake AGI #1 well as a UIC Class II well. A Class II
permit was issued to Stakeholder under TRRC Rule 9 (entitled "Disposal into Non-Productive Formations")
and Rule 36 (entitled "Oil, Gas, or Geothermal Resource Operation in Hydrogen Sulfide Areas").

UIC Well Identification Number:

Rattlesnake AGI #1, API No. 42-501-36998, UIC #000117143.

8


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SECTION 2 - PROJECT DESCRIPTION

This Project Description discusses the geologic setting, planned injection volumes and process, and the
reservoir modeling performed for the Rattlesnake AGI #1 well. The Class II UIC permit was initially applied
for and received by Santa Fe Midstream Permian, LLC. The asset was acquired in 2020 by Stakeholder and
has been in operation since that time. Since the original application, Lonquist has revised and updated the
geology and the plume modeling within the reservoir in preparing this MRV Plan.

The Rattlesnake AGI #1 well is located and designed to protect against migration of C02 out of the injection
interval and to prevent surface releases. The injection interval for Rattlesnake AGI #1 is located over 4,720'
below the primary producing formation, the San Andres, in the area and 8,593' below the base of the lowest
useable quality water table, as shown in Figure 2. This well injects both H2S and C02, therefore the well and
the facility are designed to minimize any leakage to the surface.

STAKEHOLDER
TREATING & PROCESSING
PLANT

2,450'

LOWEST
WATER TABLE
DEPTH

5,500'

CASING DEPTH

Casing consists of
reinforced steel
and concrete

11,000'

INJECTION WELL
DEPTH

>8,500'

BELOW THE
WATER TABLE

Figure 2 - Illustrative overview of Rattlesnake AGI tt1 and 30-30 Facility

9


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Regional Geology

The Rattlesnake AGI #1 well is located on the southern portion of the Northwestern Shelf within the larger
Permian Basin as seen in Figure 3. The Northwestern Shelf is a broad marine shelf located in the northern
portion of the Permian Basin,

Basin

Matador Arch

Eastern
Shelf

f..	NEW MEXICO

Jtexas |
Delaware'^
Basin \

Ozona
, Arch

>Val Verde
' Basin

.Ouach/h
NJ

NEW
MEXICO

		WO ml

100 Km

I I Permian Basin

Figure 3 - Regional Map of the Permian Basin. Red Star is approximate location of Rattlesnake AGI #1 well

Figure 4 depicts the stratigraphic column found at the Rattlesnake AGI #1 well location with red stars
referencing the injection formation and green stars indicating the productive intervals in the area. The
primary injection interval is found within the Wristen group, of Silurian-age, as seen in Figure 5. The TRRC
refers to this sequence under the general terms "Devonian", "Silurian-Devonian" or "Siluro-Devonian".

10


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Period

Epoch

Formation

General Lithology

Permian

Ochoan

Dewey Lake

Redbeds/Anhydrite

Rustler

Halite

Salado

Halite/Anhydrite

Guadalupian

Tansil

Anhydrite/Dolomite

Yates

Anhydrite/Dolomite

Seven Rivers

Dolomite/Anhydrite

Queen

Sandy Dolomite/Anhydrite/Sandstone

Grayburg

Dolomite/Anhydrite/Shale/Sandstone

Leonardian

~ San Andres

Dolomite/Anhydrite

Glorieta

Sandy Dolomite

Yeso

Paddock

Dolomite/Anhydrite/Sandstone

Blinebry

Tubb

Drinkard

Abo

Dolomite/Anhydrite/Shale

Wolfcampian

^ Wolfcamp

Limestone/Dolomite

Pennsylvanian

Virgilian

Cisco

Limestone/Dolomite

Missourian

Canyon

Limestone/Shale

Des Moinesian

Strawn

Limestone/Sandstone

Atokan

Bend

Limestone/Sandstone/Shale

Morrowan

Morrow

Mississippian



Mississippian Lime

Limestone

Devonian



Woodford

Shale

Silurian



-^Wristen Group

Dolomite/Limestone



^ Fusselman

Dolomite/Chert

Ordovician

Upper

Montoya

Dolomite/Chert

Middle

Simspson Gp

Limestone/Sandstone/Shale

Lower

Ellenburger

Dolomite

Figure 4 - Stratigraphic column of the North west Shelf. Red stars indicate injection interval. Green stars indicate productive

intervals.


-------
Mississippian

Chesterian

undivided

Meramecian

Osagian



Kinderhookian

Devonian

Upper

Woodford Shale



Middle

Lower

Thirtyone Fm.

Silurian

Pridolian

Wristen Gp.

~

Fasken
Fm.

Frame Fm.

Ludlovian

Wink Fm.

Wenlockian

Llandoverian



Fusselman Fm.

Ordovician

Upper

Montoya Fm.

Simpson Gp.

Middle

Lower

Ellenburger Fm.

Figure 5 - Stratigraphic column depicting the composition of the Silurian group. Red star indicates injection interval (Broadhead,

2005)

The Wristeri group was deposited in a basin platform setting across the northern half of the Permian Basin.
The depositional environment over Yoakum County during the Silurian period was a shallow inner platform,
the margin of which exists to the south, in southern Andrews County, Texas. The Silurian-age lithology on
the inner platform is dominated by grain-rich skeletal carbonates. Carbonate buildups are common within
the shallow inner platform, mainly skeletal wackestone, indicating a lower-energy deposition on the inner
platform. The carbonate shelf margin to the south acted as a barrier from basin-ward wave energy (Ruppel
and Holtz, 1994).

Depositional cycles within the inner platform indicate it was controlled by episodic sea level rise and fail,
resulting in sub-areal exposure and diagenesis. The diagenesis of the Silurian-age carbonate rocks initiated

12


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secondary porosity development and increased permeability. Dolomite and solution-related features are the
most prominent diagenetic characteristics found within the Silurian. The Wristen Group is composed of three
formations: Fasken, Frame, and Wink formations. The Frame and Wink formations are found near the ramp
boundary to the south, while the Fasken formation is found predominantly in the inner platform, where the
Rattlesnake AGI #1 well is located. The Fasken formation is predominately dolomite grading to limestone,
occurring as cycles, down section. This dolomitization is due in part to sub-areal exposure, during which
karsts and secondary porosity developed. Additional dolomitization was possible during successive sea level
fluctuations via movement of magnesium-rich solution through karsts and vugs, which acted as channels for
fluid flow (Ruppel and Holtz, 1994).

Figure 6 shows a regional isopach map of the Silurian (combined Fasken and Fusselman formations) with a
red star depicting the Rattlesnake AGI #1 well location. Thickness of the Silurian-age rock is approximately
1,000' at the Rattlesnake AGI #1 well location.

North of Andrews County there is little differentiation between the Fasken and Fusselman formations which
are both carbonate deposits with the potential for sub-areal exposure and porosity development. For
purposes of this MRV Plan, the combined Fasken and Fusselman formations are defined as the injection
interval, and the underlying Montoya formation serves as the lower confining unit.

13


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ThjChMSJ (ft)

W'Uin plait ttf iM'tm

M«l$COC« |4?t«U«IS

wiOtAI

4.0*1*4

Ttm

S kM>M

c«o«rTT

Figure 6- Thickness map of the Silurian system which composes the Fusselman and Wristen group

14


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Regional Faulting

A major uplift that began during the Pennsylvanian Period to the south, the Central Basin Platform, ceased
in the Early Permian (Wolfcampian), which caused a regional unconformity of the underlying formations
(Hoak, Sundberg, and Ortoleva). Faulting on the Northwest Shelf can be seen through high angle basement
faults that tend to die within the Pennsylvanian strata. These faults predominately represent contractional
(thrust) faults that were initiated during the Pennsylvanian as a result of regional tectonics. Hydrocarbon
traps within the Wristen group are primarily anticlinal structures dependent upon reservoir development
(Broadhead, 2005).

Site Characterization

The Rattlesnake AGI #1 well is located in Section 733, Block D, John H. Gibson Survey, in Yoakum County,
Texas. Stakeholder owns the 82.42-acre surface tract where the plant and Rattlesnake AGI #1 well are
located. The following discusses the geological character of this site.

Stratigraphy and Lithologic Characteristics

Figure 7 depicts an open hole log from an offset well (API No. 42-501-10238) to the Rattlesnake AGI #1 well
indicating the injection and primary upper confining zone. This well is approximately 1.8 miles to the
northwest of the Rattlesnake AGI #1 well, An offset well log was used to depict the upper confining intervals
as electric logs were only run in the Rattlesnake AGI #1 well across the injection zone.

15


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Upper Confining Interval - Woodford Shale

The Woodford is a late Devonian-age organic-rich shale deposited as a result of a widespread marine
transgression. The flooding event occurred over the majority of the Permian basin, which produced a low-
relief blanket-like shale deposit of the Woodford. Two major lithofacies found within the Woodford are black
shale and siltstone. Nutrient-rich surface waters promoted the decay of abundant organic matter within the
Woodford, resulting in a high total organic carbon ("TOC") percentage. The Woodford shale acts as the
primary source and sealant rock for the Wristen Group (Comer, 1991).

Figure 8 is a description of a core sample taken in Lea County, New Mexico just southwest of the Rattlesnake
AGI #1 well location. This sample is referenced as C9 in the reference map with the blue star representing
the Rattlesnake AGI #1 well. In the core description, black shale with abundant illitic clays is observed in the
upper section, and medium gray dolomitic siltstone found in the basal section. The mineralogic and lithologic
properties recorded in this description serve as excellent sealant characteristics to prohibit any injected fluids
from migrating above the injection interval.

The Woodford at the Rattlesnake AGI #1 well location is encountered at 10,973 ft and is approximately 63 ft
thick.

C9

Shell No. 5 Pacific Royalty
Lea County, New Mexico
Section 10.T15S-R37E
		Elevation 3814 ft

X

Q

TOC

Weight
percent

1 2 3 4 5
—I	I	I	I	L_

GR i

C9 5

cs s

C9 7

Description

(ft)

35+
-12.200

Medium* to dark-gray limestone Lime mudstone with a few thin beds of brachiopod
wackestone and skeletal and pellet grainstone Some intervals highly fractured; all
fractures are filled, some with calcite, some with silica. Lowor contact not
preserved, probably conformable.	

Green limestone. Clay rich. Lower contact not preserved, probably disconformablo.

Black shale. Parallel laminae Abundant fllitic clay; pyritic. Scattered grains of sift*
sized quartz, dolomite, and mica. Spores scattered or concentrated in thin laminae,
some spores replaced by pyrite, some by carbonate; sparse laminao of Radiolana;
rare burrows filled by chert, carbonate, and anhydrite Scarce veinlets filled with
calcite. Lower contact not preserved, probably conformable and abruptly gradatiorial.

I

| Boii»y	

•Cochron

JRqCtMT

Medium-gray dolomitic siltstone. Abundant silt-sized anhedral and subnedral dolomite;
s»lt-sized quartz common Interbedded and interlaminated dark-gray shate and
medium-gray line-grained catcite grainstone, packs tone, and lime mudstone Wavy to
discontinuous bods near top; becomes more discontinuous, contorted, and mottled
downward; shales have parallel to wavy laminae. Pyritjc; micacoous. Sparse burrows;
rare Lmgula and wood fragments. Grades downward into lighter gray dolomitic
siltstone with fewer shale inter bods Lower contact not preserved, probably
disconfonrtablo.

Pale brownish pink crystalline dolostone. Vuggy.

^Medium-gray shale. Dolomitic; silty.

69+

Pale brownish-pink crystalline dolostone Vuggy.

»-12,400

l£	

| Y00hum

I

I

I ~

' Coirct

Figure 8- Core description of the Woodford Shale and Upper Silurian (Ruppel and Holtz, 1994)

16


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Injection Interval - Fasken Formation

The Rattlesnake AGI #1 well reaches total depth in the Fasken/Fusselman formation (Silurian in age), directly
below the Woodford formation. Dolomites at the top of the Fasken formation underwent multiple leaching
and diagenetic episodes which developed secondary porosity. This is evidenced in offset wells by the practice
of only drilling through the top 30' of the Fasken, in anticipation of encountering the best reservoir quality.
In Figure 8, the uppermost Silurian section is described as 'vuggy dolostone' in the core description. Beds
below the top of the Fasken section may also have similar petrophysical attributes if exposed to multiple
diagenetic events. Solution-collapse and karst breccia horizons can be found within inner platform deposits,
some occurring as much as 100 ft below the Fasken top (Ruppel and Holtz, 1994).

Porositv/Permeabilitv Development

Porosity in the Fasken formation at the Rattlesnake AGI #1 well location is typically moldic and intercrystalline
associated with leaching of allochem-rich intervals. Porosity is directly related to these leaching events which
occurred during and post-deposition, resulting in vugs and karst-like features. Figure 9 provides reservoir
information from core data within fields in the Wristen buildup and platform carbonate play. The average
porosity of these cores is 7.1% with an average permeability of 45.28 millidarcies (Ruppel and Holtz, 1994).
The porosity and permeability described in the offset core data indicate the Fasken formation provides
sufficient accessible pore space for the amount of fluid injection proposed.

Using the above values as reference points, the Rattlesnake AGI #1 porosity log (API No. 42-501-36998) was
evaluated. Figure 10 is the product of the petrophysical analysis performed on the open hole logs run within
the injection interval at the Rattlesnake AGI #1 well. A permeability curve was generated from the effective
porosity curve using the table in Figure 9 to establish the porosity-permeability relationship. In Figure 10,
the majority of the injection interval's porosity and permeability is found at the top of the Fasken formation,
which correlates with the diagenetic processes described above. These curves are extrapolated to the
injection site and used to establish reservoir characteristics in the plume model.

17


-------














Wristen







Fusselman

Buildups and

Thirtyone

Thirtyone



Shallow Platform

Platform

Ramp

Deep-Water



Carbonate play

Carbonate play

Carbonate play

Chert play



Porosity (%>





Numbe/ o' data points

33

30

16

35

Mean

7,93

7. to

e.4i

14,85

Mnimum

1.00

2.70

3.50

2.00

Maximum

17,70

14.00

0.50

30.00

Standard devation

4.01

2.67

1.75

6.76



Permeability (md)





dumber ot (Jala points

21

24

12

33

Mean

11.61

45.28

1.51

9.56

Minimum

0.60

2.90

0.40

1.00

Maximum

84.80

400.00

30.00

100.00

Standard deviation

22.48

99.17

8.36

22.23



Initial water saturation {%)





Number oi data points

24

28

10

31

Mean

26.96

31.55

24.70

31.46

Mmmnum

10.00

20.00

16.00

10.00

Maximum

50.00

55.00

40.00

45.00

Standard deviation

9.31

10.4b

7.39

8.33



Residua) oil saturation {%)





Number a', data points

8

13

5

22

Mean

34.06

30.54

21.30

29.17

Minimum

30.00

20.00

9.00

14.00

Maximum

50.00

35.00

35.00

48.20

Standard devation

6.99

4.61

11.66

9.76



Oil viscosity (op)





Number oi data points

11

12

5

21

Mean

0.69

1.10

0.33

0.68

Mrnmum

0.13

0.32

0.04

0.07

Maximum

1.08

2.00

1.00

1.03

Standard devation

0.81

0.75

0.40

0.42



Oil formation volume factor





Number oi data points

21

22

6

32

Mean

1.57

1.22

1.65

1.50

Mnirnum

1.05

1.05

1.31

1.30

Maximum

1.91

1.55

1.66

1.73

Standard deviation

0.28

0.14

0.48

0.16



Bubble-point pressure (psi)





Number of data points

9

9

5

19

Mean

2.272

1,055

3.750

2.752

Minimum

798

450

2.660

1.755

Maximum

4.C50

2,600

4,440

4.655

Standard devation

1.300

689

756

667











Figure 9 - Table of reservoir properties found within the Wristen buildups and platform plays (Ruppel and Holtz, 1994)


-------
Low Perm

42501369980000
RATTLESNAKE AG I
1

STAKEHOLDER GAS SERVICES

0

[PLJ]=11036.9

Figure 10- Rattlesnake AG I #1 open hole log (42-501-36998) with effective porosity (green) and permeability (black)

Formation Fluid

Four wells were identified through a review of chemical analyses of oil-field brines from the U.S. Geological
Survey National Produced Waters Geochemical Database v2.1 within the Devonian, Silurian-Devonian, or
Fusselman formations within 20 miles of the Rattlesnake AGI #1 well. The location of these wells is shown in
Figure 11. Water chemistry analyses conducted on oil-field brines in Gaines County, as reported to the Texas

19


-------
Water Development Board, provided additional data on Devonian and Silurian reservoir fluids. Results from
the synthesis of these two sources are provided in Table 1. The fluids have greater than 20,000 parts per
million ("ppm") total dissolved solids, therefore these aquifers are considered saline. These analyses indicate
the in-situ reservoir fluid of the Devonian, Silurian, and Fusselman formations are compatible with the
proposed injection fluids.

Figure 11 - Offset wells used for Formation Fluid Characterization

Table 1 - Analysis of Silurian-Devonian age formation fluids from nearby oil-field brine samples



Average

Low

High

Total Dissolved Solids (ppm)

41,428

23,100

55,953

pH

7,2

7.0

7.3

Sodium (ppm)

12,458

7,426

15,948

Calcium (ppm)

1,759

1,010

2,320

Chlorides (ppm)

23,423

12,810

31,930

Fracture Pressure Gradient

Fracture pressure gradient was estimated using Eaton's equation. Eaton's equation is commonly accepted
as the standard practice for the determination of fracture gradients. Poisson's ratio ("v"), overburden
gradient ("OBG"), and pore gradient ("PG") are all variables that can be changed to match the site-specific
injection zone. Through literature review and industry standards, we are able to determine the expected

20


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fracture gradient. First, 1.05 psi/ft and 0.465 psi/ft were assumed for both the overburden and pore
gradients, respectively. These values are considered best practice values when there are no site-specific
numbers available. For limestone/dolomite rock, the Poisson's ratio to be assumed to be 0.3 through
literature review (Molina, Vilarras, Zeidouni 2016). Using these values in the equation below, a fracture
gradient of 0.72 psi/ft was calculated. A 10% safety factor was then applied to this number resulting in
maximum allowed bottom hole pressure of 0.64 psi/ft. This was done to ensure that the injection pressure
would never exceed the fracture pressure of the injection zone.

For the upper confining interval, a similar fracture gradient as the limestone was calculated. Shale has an
increased chance to vertically fracture if the injection interval is fractured (Molina, Vilarras, Zeidouni 2016),
so assuming a Poisson's ratio equal to the injection interval was used as a conservative estimate. The lower
confining zone was assumed to be of a similar matrix to that of the injection interval, with the key difference
being that the formation is much tighter (lower porosity/permeability). The Poisson's ratio was assumed to
be slightly higher in this rock. As seen in Table 2, the fracture gradient is slightly higher than the upper zones.

Table 2 - Fracture Gradient Assumptions



Injection Interval

Upper Confining

Lower Confining

Overburden Gradient (psi/ft)

1.05

1.05

1.05

Pore Gradient (psi/ft)

0.465

0.465

0.465

Poisson's Ratio

0.30

0.30

0.31

Fracture Gradient psi/ft

0.72

0.72

0.73

FG +10% Safety Factor (psi/ft)

0.64

0.64

0.66

The following steps were taken to calculate fracture gradient:

FG = —-—(OBG - PG) + PG
1 — v

0.3

FG = 1_Q3(1-05 - °-465) + °-465 = °-72
FG with SF = 0.72 x (1 - 0.1) = 0.64

Lower Confining Zone - Montoya Formation

The low-permeability Montoya Formation is a tight limestone/dolomite that will act as the lower confining
unit for the injection interval. Figure 10 shows the decreasing trend in porosity of the limestone rock in the
lower section that was not exposed to leaching diagenesis. Porosity in the lower section can range from 2-
3% with permeabilities below 1 millidarcy. The Rattlesnake AGI #1 well drilled 6' into the Montoya formation,
but the section was not logged. The Montoya is anticipated to be roughly 250' thick. These petrophysical
characteristics represent ideal sealing properties to prohibit any migration of injected fluid outside of the
injection interval.

Local Structure

Regional structure in the area of the Rattlesnake AGI #1 well is dictated by carbonate buildups and structural
events causing anticlinal to synclinal features throughout the area. The Rattlesnake AGI #1 well is specifically
located at the base of a syncline with anticlinal features to the northeast, south, and east. Figure 12 is a

21


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structure map of the Silurian formation of subsea depths with the star representing the location of the
Rattlesnake AGI #1 well. The red and blue lines represent the cross-section reference lines.

Faulting can be seen to the south and east of the Rattlesnake AGI #1 well location. These faults were
interpreted from roughly 9 square miles of 3D seismic indicated by the purple outline in Figure 12. Many of
these faults are minor, with offsets less than 50'. The nearest large fault is found southeast of the Rattlesnake
AGI #1 well and has an offset of roughly 120'. None of these faults project above the Wolfcamp formation,
rather, they appear to terminate between the Strawn and base of the Wolfcamp formation. Production is
associated with a hydrocarbon trap set up by the larger fault to the southeast, indicating the fault is vertically
sealing in nature. If, in the unlikely event the faults' sealing properties are compromised post-injection,
secondary confinement is provided by the tight limestones found within the overlying Mississippian Lime
formation along with shale layers found in the Atoka and Wolfcamp formations. As seen in Figure 14, the
largest fault found southeast of the Rattlesnake AGI #1 well, terminates within the Atoka formation. Though
it crosses the Silurian section, this fault thrusts the Mississippian Lime upward against the Atoka shales. The
tight reservoir characteristics of the Mississippian Lime and shaley section of the Atoka create a confining
environment vertically and laterally to contain potential upward migration of buoyant fluids. Shales within
the Wolfcamp formation provide additional confining beds between overlying USDWs and the fault plane.
Figures 13 and 14 are north-south and west-east structural cross sections showing the structural dips. As
seen in these figures, the Woodford formation is laterally present above the injection interval, alleviating risk
of erosion of the upper sealant formation.

Larger versions of Figures 11, 12, 13 and 14 are provided in Appendix A.

22


-------

-------

-------
NW

3T?w'

42501105700000
1-667

TEXAS CRUDE OIL CO
+

<14,201 FT>

42501369980000
RATTLESNAKE AG I
1

STAKEHOLDER GAS SERVICES



42501358340000
ROBERTS UNIT
2

APACHE



42501335110000
CORNELL UNIT

3019D
EXXON MOBIL

SE

asr

MONTOYA [PUJ

25


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Injection and Confinement Summary

The lithologic and petrophysical characteristics of the Faskeri and Fusseiman formations at the Rattlesnake
AGI #1 well location indicate the formations have sufficient thickness, porosity, permeability, and lateral
continuity to accept the proposed injection fluids. The Woodford formation shale at the Rattlesnake AGI #1
well has low permeability and is of sufficient thickness and lateral continuity to serve as the upper confining
zone. Beneath the injection interval, the low permeability, low porosity Montoya formation is unsuitable for
fluid migration and serves as the lower confining zone. Deeper, laterally continuous formations, including the
Simpson Group, provide additional confinement.

Groundwater Hydrology

Yoakum County falls within the boundary of the Sandy Land Underground Water Conservation District. Three
aquifers are identified by the Texas Water Development Board's Aquifers of Texas report in the vicinity of the
proposed Rattlesnake AGI #1 well: the Dockum Aquifer, Edwards-Trinity Aquifer, and Ogallala Aquifer
(George, Mace and Petrossian, 2011). Table 3 references the aquifers' positions in geologic time and the
associated geologic formations. A schematic cross section in Figure 15, near the proposed Rattlesnake AGI
#1 well, illustrates the structure and stratigraphy of these water-bearing formations. Groundwater flow
direction is the same for the three aquifers, generally from northwest to southeast, Figure 16 (Teeple, et al.,
2021).

Table 3 - Geologic and hydrogeologic units with accompanying lithologic descriptions near Gaines, Terry and Yoakum Counties, Texas
(Teeple, et al. 2021)

Era

Period

Epoch or series

Geologic unit group
or formation

Lithologic descriptions

Hydrogeologic unit

Cenozoic

Tertiary

Pliocene

Ogallala Formation

Gravel, sand, silt,
and clay

High Plains
aquifer system
(Ogallala aquifer)

Miocene

Mesozoic

Cretaceous'

Comanchean
Series

Washita Group2

Shale and limestone

Edwards-T rinity
(High Plains)
aquifer system

Fredericksburg Group

Clay, shale, and
limestone

Trinity Group

Sand and gravel

Triassic

Upper

Dockum Group

Sillstone, mudstone,
shale, and sandstone

Dockum aquifer

26


-------
Figure 15- NW-SE Cross Section of aquifers in the Rattlesnake AG! #1 well area (George, Mac and Petrossian, 2011)

27


-------
IOCKLEV COI NTY 8 103°0'
/ •

HOC KLEV COl.Vn

"J	\^J! In* • •• •Hv4. •

V , " •. A " *

r I J ' *1 nnvaJ^Sil'

/ • • t / • 'I** *	i» 1

K.-.'- l\i^\\s>* I

lY\ 3| ~7	. 1

/ ' <8 jX • /• *> / ~**. i' >!

[ <. OTvKsl ,. • ,

icuiNfu" fr;—7

i	if _ \ »V*^r"

C 1Q3°D'	,K

rrir

33°20' I

I ~
L-'

Y0AKUM
»v \ | x COUNTY

©#xr /

/ fMiu \ ~'

y .<

l«s

f Mjch

\ / n*L"IMkt jif

v^'	(

ftpy ' ' v x liruu^lfcUi x

~ ' j

artr'

32"4G'

-HOCKLEY COUNTY

0	5 10 (SMILES

1	. 1 r i1	1

0 5 tO T5 KILOMETERS

Base modified tram U S Geological Survey 1 250 000-scale to 1 2,000.000-scale digital data.
Universal Transverse Mercator projection, ione 13
North American Datum of 15&3

Groundwater-level altitude, in
leal above North American
Vertical Oatum of 1988

|^m" >3,750

Hj- 3,500

3,250

3,000

<2,750

EXPLANATION

Study area boundary

Edwards-Trinity I High Plains} nquilor downdip enfant
Underground water conservation district boundary

Llano Estacado Underground Water Conservation District
Sandy Land Underground Water Conservation District
South Plains Underground Water Conservation District

Potenriometric contour Shows altitude at
which water level would have stood in
tightly cased wells. Contour interval is
100 feel Datum it North American
Vertical Datum of 1988 Dashed where
mlerred.

Groundwater How pallia Dashed where
interred

• Groundwater tevol measurement (Payne
and others. 2020)

Figure 16 - Potentiometric surfaces from wells completed in A, Ogallala aquifer, B, the Edwards-Trinity aquifer and C, the Dockum
aquifer (George, Mace and Petrossian, 2011).

The Dockum Aquifer is the oldest of the three aquifers, formed from Triassic-age Dockum Group sediments,
and underlies the Cretaceous Trinity and Fredericksburg Groups (Teeple, et al., 2021). Figure 17 shows the
subsurface and outcrop extent of the Dockum Aquifer. As shown in Figure 18, the total dissolved solids in
western Yoakum County exceed 5,000 milligrams per liter ("mg/L"), therefore the aquifer is considered
brackish.

28


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Dockum

Aquifer

Figure 17 - Regional extent of the Dockum freshwater aquifer (TWDBj

Figure 18 - Total dissolved solids in groundwater from the Dockum Aquifer (Ewing et at, 2008)

The Edwards-Trinity Aquifer is a collection of Cretaceous age sediments - primarily the Trinity Group Antlers
formation sandstone and limestones of the Fredericksburg Group, specifically the Comanche Peak and
Edwards formations. Figure 19 shows the subsurface and outcrop extent of the Edwards-Trinity Aquifer.
Freshwater infiltration to this aquifer is primarily from the overlying Ogallala Aquifer (George, Mace and
Petrossian, 2011).

29


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The Ogallala aquifer consists of sand, gravel, clay and silt sediments (George, Mace and Petrossian, 2011) and
produces the majority of the freshwater for Yoakum County. Figure 20 shows the subsurface and outcrop
extent of the Ogallala Aquifer.

The base of the deepest aquifer is separated from the injection interval by approximately 8,600' of rock,
including 576' of Salado salt. Though unlikely for reasons outlined in the confinement and potential leaks
sections, if migration of injected fluid did occur above the Woodford Shale, thousands of feet of tight
sandstone, limestone, shale, salt and anhydrite beds occur between the injection interval and the lowest
water-bearing aquifer.

30


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The TRRC's Groundwater Advisory Unit ("GAU") identified the base of Underground Sources of Drinking
Water ("USDW") at 375' at the location of the Rattlesnake AGI #1 well. Therefore, there is approximately
10,661' separating the base of the USDW and the injection interval. A copy of the GAU's Groundwater
Protection Determination letter issued by the TRRC as part of the Class II permitting process for the
Rattlesnake AGI #1 well is provided in Appendix B.

Description of the Injection Process
Current Operations

The 30-30 Facility and its associated Rattlesnake AGI #1 well began operating in March of 2019. Since
operations began, 258 million cubic feet ("MMCF") of treated acid gas ("TAG") has been injected, which
equates to 12,316 metric tons of C02. Over the life of the injection period, the average daily injection rate
has been 223 MSCF/d. The approximate current composition of the TAG stream is as follows;

Table 4 - Gas Composition of 30-30 Facility outlet

Component

Mol %

C02

89.68%

H2S

9.20%

Other

1.12%

31


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The 30-30 Facility is designed to compress, treat, and process natural gas produced from the surrounding
counties in Texas and New Mexico. The gas is dehydrated to remove the water content, then processed to
separate natural gas liquids which are then sold, along with the pipeline quality natural gas, to various
customers. TAG is then directly routed from the plant amine regen system to the Rattlesnake AGI #1 well.
The facility is manned 24 hours per day, 7 days per week.

Planned Operations

Stakeholder anticipates increasing the amount of CO2 injected into Rattlesnake AGI #1 well from the current
rate up to 16 MMSCF/d. Additional growth is expected both at Stakeholder facilities and regionally as rising
sour gas production and flaring reduction mandates create the need for additional CO2 and H2S disposal
capacity. Stakeholder plans to inject into this AGI well for another 14 years for a total of 17 years from the
start of injection in 2019.

Figure 21 shows a high-level view of the current process flow plus the prospective additional operations over
time.

Amine Regen
System

>96% C02
1,090-1,150 psig

CO, Offta ke

13% H2S, 87% COj
1,400-2,200 psig

AGI
Compression

Prospective Facilities

Meter

er XV

Meter

&

XV

A

l_
"l
I

-L

596-13% HjS, 87%-

95% C02
1,400-2,500 psig

Injection
Pumps

XV

Current Operation

AGI
Well

Figure 21 - 30-30 Facility Process Flow Diagram

Reservoir Characterization Modeling

The modeling software used to evaluate this project was Computer Modelling Group's GEM 2020.11 ("GEM")
simulator. Computer Modelling Group ("CMG") has put together one of the most accurate and technically
sound reservoir simulation software packages for conventional, unconventional, and secondary recovery.
GEM utilizes equation-of-state ("EOS") algorithms along with some of the most advanced computational
methods to evaluate compositional, chemical, and geochemical processes and characteristics to produce
highly accurate and reliable simulation models for carbon injection and storage. The GEM model is
recognized by the EPA for use in area of review delineation modeling as listed in the Class VI Well Area of
Review Evaluation and Corrective Action Guidance document.

The Silurian (Fasken/Fusselman) formation is the target formation for Rattlesnake AGI #1 well. The Petra
software package was used to create the geologic model of the target formation. The faulting and geologic
structure was then imported into GEM and used to create contours for the model grid.

Porosity and permeability estimates were determined using the porosity log from the Rattlesnake AGI #1
well and a petrophysical analysis was performed to correlate porosity values by depth with core porosities

32


-------
as shown in the Holtz paper. The Coates permeability equation was then used to calculate permeability with
depth. Both porosity and permeability are assumed to be laterally homogeneous in the reservoir.

The reservoir is assumed to be at hydrostatic equilibrium and initially saturated with 100% brine. An infinite
acting reservoir was created to simulate boundary conditions. The gas injectate is composed of H2S, CO2,
CH4, and other components as shown in Table 5. Core data from literature review was used to determine
residual gas saturation (Ruppel and Holtz, 1994). The modeled composition only takes into consideration the
carbon dioxide and hydrogen sulfide as they comprise nearly 99% of total stream. For the initial injection
period, these compositions are normalized up to 100%. For the proposed additional injection period, it is
expected that a larger portion of the gas added is carbon dioxide, changing the composition to ~93% CO2 and
~7% H2S.

Table 5 - Modeled Initial Gas Composition



Measured Current

2019-2024 Model

2024-2036 Model

Component

Composition (mol%)

Composition (mol%)

Composition (mol%)

Carbon Dioxide (C02)

89.678

90.696

92.921

Hydrogen Sulfide (H2S)

9.200

9.304

7.079

Methane (CI)

0.303

0

0

Ethane (C2)

0.058

0

0

Propane (C3)

0.108

0

0

N-Butane (NC4)

0.025

0

0

Hexane Plus (C6+)

0.628

0

0

Core data from literature review was used to determine relative permeability curves between carbon dioxide
and the connate brine within the Silurian-Devonian carbonates (Ruppel and Holtz, 1994). The key inputs
used in the model include an irreducible water saturation of 25% and a maximum residual gas saturation of
21%.

The grid contains 141 blocks in the x-direction (E-W) and 201 blocks in the y-direction (N-S), totaling 28,341
grid blocks per layer. The grid blocks are each 150' by 150' by layer thickness as specified in Table 6. This
results in the grid being 21,150' by 30,150' totaling just over a 23-square mile area (14,640 acres). Each layer
in the model was determined by identifying higher permeability zones as targets for injection from the logs
and assigning each high permeability and intermediary low permeability zone its own layer. One zone was
identified as being a karst limestone (layers 2-7). Due to the "karsted" nature of this rock, it was determined
that most of the injectate would flow into this zone. Therefore, the karst limestone was further split into
layers by permeability to provide higher resolution and more accurately simulate which layer will have more
gas flow into it. Figure 22 provides a detailed breakdown of the "karsted" rock.

33


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Permeability Distribution of Karst Zone

2

3

4

l—

(D
_l

5

6

7

1	10	100	1000

Permeability (mD)

Figure 22 - Permeability Distribution of Karst Limestone

In total, there are sixteen (16) layers in the model, representing ten (10) layers of pay and six (6) layers of
intermediary low permeability zones. The properties of each of these layers are summarized in Table 6
below.

Table 6 - CMG Model Layer Properties

Layer #

Top (ft)

Thickness (ft)

Permeability (mD)

Porosity

1

11,037

71

1

2.8%

2

11,108

57

47

8.0%

3

11,165

19

223

11.9%

4

11,184

16

15

6.3%

5

11,200

39

70

9.2%

6

11,238

11

228

12.3%

7

11,249

21

49

8.3%

8

11,270

251

2

3.7%

9

11,520

46

9

5.6%

10

11,566

13

3

4.3%

11

11,579

19

17

6.5%

12

11,597

14

2

3.9%

13

11,611

103

13

6.0%

14

11,714

46

2

3.7%

15

11,759

67

23

6.1%

16

11,826

125

2

3.6%

34


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Simulation Modeling

The primary objectives of the model simulation were to:

1)	Estimate the maximum areal extent and density drift of the acid gas plume after injection

2)	Assess the impact of offset saltwater disposal ("SWD") well injection on density drift of the plume

3)	Assess the impact of offset producing wells on the density drift of the plume

4)	Determine the ability of the target formation to handle the required injection rate without
fracturing the injection zone

5)	Assess the likelihood of the acid gas plume migrating into potential leak pathways

The reservoir is assumed to be an aquifer filled with 100% brine. The salinity of the formation is estimated
to be 53,000 ppm (Texas Water Development Board, 1972). The acid gas stream is primarily composed of
C02 and H2S as stated previously. Core data was used to help generate relative permeability curves. Cores,
from the literature reviews previously discussed, that most closely represent the vuggy carbonate seen in
this region were identified and the Corey-Brooks equations were used to develop the curves. The lowest
residual gas saturation found in the cores was then used for a conservative estimate of plume size. From
offset injection well analysis, the initial reservoir pressure was determined to be 5,132 psi which is equivalent
to a 0.465 psi/ft pressure gradient. The fracture gradient of the injection zone was estimated to be 0.72
psi/ft, which was determined using Eaton's equation. A 10% safety factor was then applied to this number,
putting the maximum bottom-hole pressure allowed in the model at 0.64 psi/ft which is equivalent to 7,064
psi.

The model also takes into account offset saltwater disposal ("SWD") injection volumes within five (5) miles
of the Rattlesnake AGI #1 well. These SWDs create a pressure front that push the plume further up-dip of
the formation. A total of twenty (20) offset wells currently injecting into the target formation were identified.
Eleven (11) of these offset SWDs were out of the confines of the grid, but were still accounted for in the
model. Nine (9) salt-water disposals were modeled within the boundaries of the 23-square-mile grid. Two
(2) of these offset injectors are currently only permitted (not drilled) but were assumed to start active
injection within the first year of the model. Both permits were simulated at the forecasted injection rate
schedule for 30 years. These forecasts were provided by the operators of these wells. Historical injection
rates of each of the other existing wells were analyzed and projected into the model. This simulation includes
the effect of water injection on the density drift of the plume and bottom hole pressure.

Further review of the area revealed production wells in the Silurian-Devonian formation that could impact
the density drift of the plume by creating a "pressure sink". A "pressure sink" is an area of lower pressure
caused by the production of formation fluids. To simulate this effect, nine (9) production wells were grouped
together and their respective production rates combined into a single well to add more conservatism into
the model. These producers were forecasted an additional 15 years to simulate their potential economic
lifespan. This simulation includes the effect of fluid production on the density drift of the plume and bottom
hole pressure. Overall, the "pressure sink" has little effect on the density drift and, as discussed below, the
plume never reaches the producing wells.

The model runs for a total of 814 years, starting in 1965 with the beginning of offset production until the
calculated stabilization of the plume in 2779. The injection of TAG from Rattlesnake AGI #1 is modeled from
the beginning of injection in 2019 through the planned 14 years of future injection. The model also includes
the 57 years of historical plus 15 years of forecasted future oil and gas production.

Additionally, historical monthly injection rates of all nearby SWDs were incorporated into the model to
simulate any additional near-wellbore pressure increase that may occur due to offset injection. The

35


-------
modelling of the saltwater injection begins in 1984 when the first offset SWD well became operational. The
SWDs to the North were grouped into four (4) separate groups to simulate their combined effect on the
density drift of the plume. All offset injection wells and their groupings are included in Table 7. All offset
production wells are listed in Table 8.

Table 7 - All Offset SI/l/Ds included in the model

Grouping

API

Well Name

Well#



42-501-32511

SAWYER, DESSIE

1



42-501-02068

WEST, M. M.

2

Group 1

42-501-02053

NORTH CENTRAL OIL CO. "A"

1



42-501-01453

SMITH, EDS. HEIRS "B"

1



42-501-02059

SMITH, ED "C"

1W

Group 2

42-501-30051

JOHNSON

2

42-501-30001

JOHNSON

ID

Group 3

42-501-37066

MISS KITTY SWD 669

1W

42-501-36650

RUSTY CRANE 604

1W

Group 4

42-501-36745

SUNDANCE 642

1

42-501-33887

WINFREY 602

3WD



42-501-37252

Miller SWD

7



42-501-37367

BLONDIE 704

1W



42-501-37206

BRUSHY BILL 707

1WD



42-501-36622

WISHBONE FARMS 710

1W

Standalone

42-501-35834

ROBERTS UNIT

2



42-501-33297

STATE ELMORE

1



42-501-10238

SHEPHERD SWD

1



42-501-33511

CORNELL UNIT

3019D



42-501-32868

WILLARD UNIT

1WD

Table 8 - All Offset Producers included in the model

API

Well Name

Well #

42-501-10046

ELLIOTT, C.A.

2

42-501-10079

RANDALL, E

32

42-501-337932

RANDALL, E

40

42-501-33885

RANDALL, E

41L

42-501-34016

RANDALL, E

43 L

42-501-34017

RANDALL, E.

45 L

42-501-34023

RANDALL, E

42L

42-501-34024

RANDALL, E

44

42-501-35418

RANDALL, E

46

Rattlesnake AGI #1 came online in 2019 and the model simulated its historical monthly injection rates until
2024. After this initial period, it is conservatively assumed that the injection rate increases to the maximum
permitted rate of 16 MMSCF/d for the remainder of the active injection period in 2036. At this point, the

36


-------
Rattlesnake AGI #1 well stops injection while the offset SWD injectors continue operations for thirty more
years. Density drift then occurs until plume stabilizes, which was determined to be 814 years from the start
of the model in 1965. Stabilization of the plume is determined to occur when the model shows no further
lateral movement horizontally or vertically. The plume boundary is then defined by a weighted average gas
saturation in the aquifer of 3%.

The maximum plume extent during the 17-year Rattlesnake injection period is shown in Figure 23. The final
extent after 743 years of density drift after injection ceases is shown in Figure 24. The extensive time of the
modeled density drift of the plume is driven by the buoyant forces of the gas, the permeability/porosity of
the rock, and the residual gas saturation. Initially, the karsted region takes on most of the injection, but due
to the buoyant forces, it is slowly pushed up higher into the less permeable layers of the injection interval.
These lower permeable layers, increase the amount of time it takes for the plume to reach its maximum areal
extent. As all the inputs to the model were based on the most conservative approach, the maximum extent
of the plume will likely be smaller and the effective impact on reaching potential leakage pathways will be
minimal as the amount of CO2 at those far extents will be small.

State Elmore

Brushy Bills 707

Shepherd SWD

Rattlesnake AGI Plume
Global Mote froction(CQ2) 2036-Jqn-Ol K Plone: 2 of 16

-0.70
¦ -060

1050
o.
-
0.20

Group 2 Group 4 Group 3 Group 1

Blondie 704

Mi ter SWD

Rattlesnake AGI

Willard Unit

Roberts Unit

Production Wells

Cornell Unit

Figure 23 - AreaI View Gas Saturation Plume, 2036 (End of Injection)

37


-------
Brushy Bills 707

19,215'

Miller SWD

6,900'

Blondie 704

Production Wells

Rattlesnake AGI

Willard Unit

Roberts Unit

Cornell Unit

Group 2 Group 4 Group 3 Group 1

State Elmore

Shepherd SWD

1.00-—
!¦

090
080
-070
-060

-

t

-030
020

Rattlesnake AGI Plume
Global Mole Fractlon{C02) 2779-Doc-OI K Plane: 2 of 16

Figure 24- Area! View Gas Saturation Plume, 2779 (End of Density Drift)

Figure 25 shows the surface injection rate and bottom hole pressure over the injection period and the period
of density drift after injection ceases. The bottomhole pressure increases the most as the injection rate
reaches its peak, reaching a maximum pressure of 5,413 psi. This buildup of 280 psi keeps the bottomhole
pressure well below the fracture pressure of 7,064 psi. The maximum surface pressure associated with the
maximum bottomhole pressure reached is 2,494 psi.

16.000,000

I" 14.000,000

£ 12,000,000

= 10,000,000
o

¦ 8,000,000
O

6,000,000

£

a 4,000,000

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2021 2023 2025 2027 2029 2031 2033 2035 2037 2039 2041 2043 2045 2047 2049 2051 2053 2055

5400 I

6370 J
S340 |
5310 b

O

5280 ®
T3

5250 ®
w

5220 c
at

5190 9*

v>

5160 —

—	Rattlesnake AGI, Gas Rate SC - Daily

—	Rattlesnake AGI, Well Bottom-hole Pressure

Figure 25 - Well Injection Rate and Bottomhole Pressure over Time

38


-------
SECTION 3 - DELINATION OF MONITORING AREA

This section discusses the delineation of Maximum Monitoring Area ("MMA") and Active Monitoring Area
("AMA") as described in EPA 40 CFR §98.448(a)(l).

Maximum Monitoring Area

The MMA is defined as equal to or greater than the area expected to contain the free-phase C02 plume until
the C02 plume has stabilized plus an all-around buffer zone of at least one-half mile. Numerical simulation
was used to predict the size and drift of the plume. With CMG's GEM software package, reservoir modeling
was used to determine the areal extent and density drift of the plume. The model takes into account the
following considerations:

•	Offset well logs to estimate geologic properties

•	Petrophysical analysis to calculate the heterogeneity of the rock

•	Geological interpretations to determine faulting and geologic structure

•	Offset injection history to adequately predict the density drift of the plume

Acid gas injectate was analyzed by a third-party vendor to determine the initial composition used in the
model. The report is provided in Appendix C. The molar composition of the gas is primarily C02 with some
H2S and CH4. The change in molar composition was also incorporated into the model as future predominantly
C02 streams are added for injection. As discussed in Section 2, the gas was injected into the Silurian
formation, specifically, the Fasken/Fusselman formation. The geomodel was created based off the rock
properties seen in the Fasken/Fusselman.

The plume boundary was defined by the weighted average gas saturation in the aquifer. A value of 3% gas
saturation was used to determine the boundary of the plume. When injection ceases in 2036, the areal
expanse of the plume will be 1,052 acres. The maximum distance between the wellbore and the edge of the
plume is approximately 0.87 miles to the southeast. After 743 additional years of density drift, the areal
extent of the plume is 2,177 acres with a maximum distance to the edge of the plume of approximately 1.35
miles to the southeast.

Figure 26 shows the plume boundary at the end of injection, the stabilized plume boundary and the MMA.

39


-------
f















Rattlesnake ACI No. 1
PI use Boundary at End of Injection
6 Stabilized Plune

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Figure 26 - Plume Boundary at End of Injection, Stabilized Plume Boundary, and Maximum Monitoring Area

Active Monitoring Area

The initial AMA will cover a 14-year monitoring period. This period equates to the time of expected future
injection. The AMA will be established by superimposing the area based on a half-mile buffer around the
anticipated plume location at the end of injection (2036) with the area of the projected free-phase C02 plume
at five additional years (2041). In this case, the plume boundary in 2041 is within the plume at 2036 plus a
half-mile buffer. By 2036 at the latest, a revised MRV plan will be submitted to define a new AMA. Figure 27
shows the area covered by the AMA.

Larger size versions of Figures 26 and 27 are provided in Appendix D.

40


-------
ID

1 Inch = 0.51 Mile
1:32,000 m



&

Rattlesnake ACI No. 1
PI use Boundary at End of Injection
& 19-Year Plume
wi th

1/Z-Hile Active Monitoring Area (AHA)
Stakeholder Midstream

	Yoakum Co.. TX	

PCS: NADB3 TX-NC FIPS 4202 
-------
SECTION 4 - POTENTIAL PATHWAYS FOR LEAKAGE

This section identifies the potential pathways for C02 to leak to the surface within the MMA and the
likelihood, magnitude and timing of such leakage. The potential leakage pathways are:

•	Leakage from surface equipment

•	Leakage through existing wells within MMA

•	Leakage through faults and fractures

•	Leakage through the confining layer

•	Leakage from Natural or Induced Seismicity

Leakage from Surface Equipment

The surface facilities at the 30-30 Facility are designed for injecting acid gas containing H2S, and therefore
minimize leakage points such as valves and flanges following industry standards and best practices. H2S gas
detectors are located around the facility and the well site. These gas detectors trigger alarms at 10 parts per
million ("ppm"). Additionally, all Stakeholder field personnel are required to wear H2S monitors which are
triggered at 5 ppm of H2S. A shut-in valve is located at the wellhead and is locally controlled by pressure,
with a high pressure and low pressure shut-off.

The facilities have been designed and constructed with additional safety systems to provide for safe
operations. These systems include Emergency Shutdown ("ESD") valves to isolate portions of the plant and
pipeline, pressure relief valves along the pipeline to prevent over pressurization, and flares to allow piping
and equipment to be de-pressured rapidly under safe and controlled operating conditions in the event of a
leak. Figures 28 and 29 display the facility safety plot plan, taken from the 30-30 H2S Contingency Plan, and
show the location of the H2S monitors in the vicinity of the plant and the Rattlesnake AGI #1 well. Should
Stakeholder construct additional C02 facilities, as indicated in Figure 21, a separate meter will be installed for
the additional stream in order to comply with the 40 CFR §98.448(a)(5) measurement. As this meter will be
in close proximity to the existing facilities, it will utilize the existing monitoring programs discussed previously.
Additionally, C02 monitors will be installed near the new meter and tied into the facility monitoring systems.

42


-------
Figure 28 - Site Plan, 30-30 Facility

43


-------
With the level of monitoring at the 30-30 Facility and the Rattlesnake AGI #1 well, any release of H2S and C02
would be quickly identified, and the safety systems would quickly minimize the volume of the release. The
C02 injected into the Rattlesnake AGI #1 is injected with H2S at a concentration of 10% (100,000 ppm). At
this high level of H2S concentration, even a small leakage would trigger personal and facility H2S monitors set
to alarm at 5 ppm and 10 ppm respectively. If any leakage were to be detected, the volume of C02 released
will be quantified based on the operating conditions at the time of release, as stated in Section 7 in
accordance with 40 CFR §98.448(a)(5).

A larger scale version of Figure 28 is provided in Appendix E.

Leakage from Existing Wells within MMA
Oil and Gas Operations within Monitoring Area

A significant number of wells have historically been drilled within the area of the Rattlesnake AGI #1 well,
however production has primarily been from the shallower San Andres formation in the Wasson Field. The
San Andres is separated from the Silurian-Devonian interval by 4,720' in this area. In addition to the primary
San Andres production, a few wells have produced from the Wolfcamp. The Wolfcamp is separated from the
Siluro-Devonian interval by is 1,800'. Within the projected plume area of the Rattlesnake AGI #1 well, there
are no penetrations of the injection interval. There are ten wells within the MMA that penetrate the
injection interval.

A review of the TRRC records for all of the wells which penetrate the injection interval within the MMA,
shows the wells were properly cased and cemented to prevent annular leakage of C02 to the surface. The
plugged wells are also adequately protected against migration from the Devonian by the placement of the
plugs within the wellbores. Additionally, the Rattlesnake AGI #1 well was designed to prevent migration from
the injection interval to the surface through the casing and cement placed in the well, as shown in Figure 29.
Mechanical integrity tests ("MIT") required under TRRC rules are run annually to verify the well and wellhead
can hold the appropriate amount of pressure. If the MIT were to indicate a leak, the well would be isolated
and the leak mitigated quickly to prevent leakage to the atmosphere.

A map of all wells within the MMA is shown in Figure 30. Figure 31 shows only those wells which penetrate
the injection interval within the MMA. The MMA review maps, a summary of all the wells in the MMA and
detailed wellbore schematics for those wells which penetrate the injection interval are provided in Appendix
F.

44


-------
Base of USDW@375'

Rustler @ 2,345'

Salado @ 2,443'

Yates @ 3,019'

Seven Rivers @ 3,440'

dH

Grayburg @ 4; 190'
San Andres @ 4,465'

DV Tool @ 4,275'

DV Tool @5,591'

Glorieta @ 6,316'
Clearfork @ 6,492'

Wichita @ 8,628'

12,500' -
13,000' -
15,500' -

GK

Upper Wolfcamp @ 9,239'

Strawn @ 10,030'

Atoka @ 10,230'

Woodford @ 10,973'
Devonian @ 11,036'
Wristen@ 11,268'
Fusselman@ 11,538' Ci)
Montoya @ 11,974'

¦

ir

DV Tool @9,575'
Packer @ 10,966'

TD@ 11,980'

KB:

N/A

BHF:

NA

GL:

3,627'

Spud:

5/27/2018

Casing/Tubing Information

Label

1

2

3

4

Type

Surface

Intermediate

Production

Tubing

OD

13-3/8"

9-5/8"

7"

3-1/2"

Weight

48

40

29

9,2

WT

.330

.395

.408

NA

Grade

H40/J55 STC

L- 80 BTC

L80 LTC
2535 Vam Top

L80 Vam Top:
G3 Vam Top'

Hole Size

17-1/2"

12-1/4"

8 3/4

6"

Depth Set

504'

5.498'

11,014'

10,966'

TOC

Surface

Surface

Surface

NA

Volume

510 sks

2,135 sks

760 sks

NA

LONQUIST & CO. LLC

PETROLEUM

ENER6Y

ENGINEERS

ADVISORS

HOUSTON'CALGARY
AUSTIN I WICHITA I DENVER

Stakeholder Midstream

Country: USA

Location: 33.07884, -103.904514

API No: 42-501-36998

Rattlesnake No. 1

State/Province: Texas

Site:

County/Parish: Yoakum

Survey:

Well Type/Status: AG I

Texas License F-9147

RRC District No:

Project No: LS 128

Date: 5/27/2022

12912 Hill Country Blvd Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Reviewed: SLP

Approved: SLP

Figure 29 - Rattlesnake AG! #1 Well bore Schematic

45


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3.) 0,1,Gas Wei Dresioaa OK* B-2022

i Scte: AH aoorisslei Sewn are •- MADSB COD). 1

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Figure 30 - Oil arid Gas Wells within the MMA

46


-------


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Drawn by: ER | Date: 6/1/2022 | Approved by: RH

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» Ncte: 41! eocra't-;: s«o»n ait in HA.D43 iDD) »

~

Figure 31 - Penetrating Oil and Gas Wells within the MMA

47


-------
Future Drilling

Potential leak pathways caused by future drilling in the area are not expected to occur. The deeper
formations, such as the Devonian, have proven to-date to be less productive or non-productive in this area,
which is why the location was selected for injection. Furthermore, any drilling permits issued by the TRRC in
the area of the Rattlesnake AGI #1 well include a list of formations for which oil and gas operators are
required to comply with TRRC Rule 13 (entitled "Casing, Cementing, Drilling, Well Control, and Completion
Requirements"). 16 TAC § 3.13. By way of example, see the Rattlesnake AGI #1 well drilling permit provided
in Appendix B. The Devonian is among the formations listed for which operators in Yoakum County (where
the Rattlesnake #1 is located) are required to comply with TRCC Rule 13 (Appendix B, pg. 5). TRRC Rule 13
requires oil and gas operators to set steel casing and cement across and above all formations permitted for
injection under TRRC Rule 9 or immediately above all formations permitted for injection under Rule 46 for
any well proposed within a one-quarter mile radius of an injection well. In this instance, any new well
permitted and drilled to the Rattlesnake AGI #1 well's injection zone, and located within a one-quarter mile
radius of the Rattlesnake AGI #1 well, will be required under TRRC Rule 13 to set steel casing and cement
above the Rattlesnake AGI #1 well injection zone. Additionally, Rule 13 requires operators to case and
cement across and above all potential flow zones and/or zones with corrosive formation fluids. The TRRC
maintains a list of such known zones by TRRC district and county and provides that list with each drilling
permit issued, which is also shown in the above-mentioned permit in Appendix B.

If any leakage were to be detected, the volume of C02 released will be quantified based on the operating
conditions at the time of release.

Groundwater wells

There are seven groundwater wells located within the MMA, as identified by the Texas Water Development
Board. All of the identified groundwater wells in the area have total depths less than or equal to 265', as
shown in Figure 32 and Table 9. One of the wells is located on the 30-30 facility property with a total depth
of 119'and is operated by Stakeholder.

The surface and intermediate casings of the Rattlesnake AGI #1 well, as shown in Figure 29, are designed to
protect the shallow freshwater aquifers consistent with applicable TRRC regulations and the GAU letter
issued for this location. See GAU letter included within Appendix B. The wellbore casings and cements also
serve to prevent C02 leakage to the surface along the borehole.

A larger scale version of Figure 32 is provided in Appendix F.

48


-------


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Maximum Monitoring Area
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Area of Review

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD 83 TX-NC FIPS 4202 
-------
Table 9 - Groundwater Well Summary

State Well ID

Owner Name

Primary Use Well Depth Data Source

370449

Frances Barbini

Irrigation

237

SDRDB

443840

Frances Jean Barbini

Irrigation

250

SDRDB

482963

Santa Fe Midstream Permian

Industrial

119

SDRDB

510854

FRANCIS BARNINI

Irrigation

255

SDRDB

520249

Thomas Durham

Irrigation

264

SDRDB

543433

FRANCIS BARBIDI

Irrigation

240

SDRDB

84760

TEXACO PRODUCING INC





TWDB BW

Leakage Through Faults and Fractures

Faults were interpreted from roughly 9 square miles of 3D seismic indicated by the purple outline in Figure
12. Faulting in this region terminates vertically below the Pennsylvanian-age rock. Secondary confining
shales within the Wolfcampian and younger strata provide additional, redundant confining layers that would
prevent C02from migrating into freshwater aquifers. None of the mapped faults project above the Wolfcamp
formation; rather, they appear to terminate between the Strawn and base of the Wolfcamp formation. If, in
the unlikely event the faults' sealing properties are compromised post-injection, secondary confinement is
provided by the tight limestones found within the overlying Mississippianan Lime formation and the shale
layers found in the Atoka and Wolfcamp formations. As seen in Figure 14, the largest fault found SE of the
Rattlesnake AGI #1 well, terminates within the Atoka formation. Though it crosses the Silurian section, this
fault thrusts the Mississippian Lime upward against the Atoka shales. The tight reservoir characteristics of
the Mississippian Lime and shaley section of the Atoka create a confining environment vertically and laterally
to contain potential upward migration of buoyant fluids. Shales within the Wolfcamp formation provide
additional confining beds between overlying USDWs and the fault plane.

Should an unmapped fault exist within the plume boundary, the offset would be below 3D seismic resolution.
The offset would be less than the thickness of the Woodford shale, juxtaposing the Woodford against itself,
preventing vertical migration.

Fractures and subsequent subaerial exposure are responsible for porosity development within the injection
intervals. Open hole logs show little to no porosity development indicating the Woodford or Mississippian
Lime were not exposed at this location. Upward migration of injected gas through confining bed fractures is
unlikely.

50


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Leakage Through the Confining Layer

The Silurian-Devonian injection zones have competent sealing rocks above and below the porous sub-aerially
exposed carbonate. The properties of the overlying transgressive Woodford shale (widespread deposition,
high illite clay and organic matter composition, and low porosity and permeability) make an excellent sealing
rock to the underlying Silurian formation. Tight Mississippian Lime of roughly 660 ft, lay between Atoka and
Woodford shale formations, forming an impermeable upper seal to the injection interval. Above this
confining unit, correlative shales of the Wolfcamp, Abo and Tubb formations will prevent any upper fluid
migration. These impermeable shales are capped by hundreds of feet of the regionally present Salado
formation evaporites. The USDW lies above the sealing properties of the formations outlined above, making
stratigraphic migration of fluids into the USDW highly unlikely. The underlying low porosity and permeability
Montoya carbonate minimizes the likelihood of downward migration of injected fluids. The relative
buoyancy of injected gas to the in-situ reservoir fluid makes migration below the lower confining layer
unlikely.

Leakage from Natural or Induced Seismicitv

The location of Rattlesnake AGI #1 is in an area of the Permian Basin that is inactive from a seismicity
perspective, whether induced or natural. A review of historical seismic events on the USGS's Advanced
National Seismic System site (from 1971 to present) and the Bureau of Economic Geology's TexNet catalog
(from 2017 to present), as shown in Figure 33, indicates the nearest seismic event occurred more than 60
miles away.

A regional analysis of the probabilistic fault slip potential across the Permian Basin (Snee & Zoback 2016), as
seen in Figure 34, further demonstrates that the Rattlesnake AGI #1 well is located in a seismically inactive
area and confirms that this area has little to no potential for an induced seismicity event.

Therefore, there is no indication that seismic activity poses a risk for loss of C02 to the surface within the
MMA.

Pressures will be kept significantly below the fracture gradient of the injection and confining intervals.
Additionally, continuous well monitoring combined with seismic monitoring will identify any operational
anomalies associated with a seismicity event.

51


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52


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53


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SECTION 5 - MONITORING FOR LEAKAGE

This section discusses the strategy that Stakeholder will employ for detecting and quantifying surface leakage
of C02 through the pathways identified in Section 4 to meet the requirements of 40 CFR §98.448(a)(3). As
the injectate stream contains both H2S and C02, the H2S will be a proxy for C02 leakage and therefore the
monitoring systems in place to detect H2S will also indicate a release of C02. Table 10 summarizes the
monitoring of potential leakage pathways to the surface. Monitoring will occur during the planned 17-year
injection period, or cessation of injection operations, plus a proposed 5-year post-injection period.

•	Leakage from surface equipment

•	Leakage through existing and future wells within MMA

•	Leakage through faults , fractures or confining seals

•	Leakage through natural or induced seismicity

Because the acid gas injection stream also contains H2S, any leakage would be detected by the H2S alarms
located around the facility and would be quickly addressed which would minimize the release of C02 into the
atmosphere.

Table 10- Summary of Leakage Monitoring Methods

Leakage Pathway

Monitoring Method

Leakage from surface equipment

Fixed H2S monitors throughout the AGI facility

Daily visual inspections

Personal H2S monitors

Distributed Control System Monitoring (Volumes and Pressures)

Leakage through existing wells

Fixed H2S monitor at the AGI well

SCADA Continuous Monitoring at the AGI Well

Annual Mechanical Integrity Tests ("MIT") of the AGI Well

Visual Inspections

Quarterly C02 Measurements within AMA

Leakage through groundwater wells

Annual GroundwaterSamples on Property

Leakage from future wells

H2S Monitoring during offset drilling operations

Leakage through faults and fractures

SCADA Continuous Monitoring at the AGI Well (volumes and pressures)

Fixed In-field H2S monitors

Leakage through confining layer

SCADA Continuous Monitoring at the AGI Well (volumes and pressures)

Fixed In-field H2S monitors

Leakage from natural or induced
seismicity

Seismic monitoring station to be installed

54


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Leakage from Surface Equipment

As the 30-30 Facility and the Rattlesnake AGI #1 well are designed to handle H2S, leakage from surface
equipment is unlikely to occur and would be quickly detected and addressed. The facility design minimizes
leak points through the equipment used and the type of connections are designed to minimize corrosion
points. The H2S in the injectate serves as a proxy for the release of C02. The facility and well site contain a
number of H2S alarms, set with a high alarm setpoint of 10 ppm of H2S, which are shown in Figure 28 above.
Additionally, all Stakeholder field personnel are required to wear H2S monitors, which trigger the alarm at 5
ppm H2S.

The AGI facility is continuously monitored through automated systems. In addition, field personnel conduct
daily visual field inspections of gauges, monitors and leak indicators such as vapor plumes. The effectiveness
of the internal and external corrosion control program is monitored through the periodic inspection of the
system, analysis of liquids collected from the line, and inspection of the cathodic protection system. These
inspections, in addition to the automated systems, allow Stakeholder to quickly respond to any leakage
situation. Monitoring will occur for the duration of injection and the post-injection period. Should leakage
be detected during active injection operations, the volume of C02 released will be calculated based on
operating conditions at the time of the event, per 40 CFR §98.448(a)(5).

Pressures and flowrates through the surface equipment are continuously monitored during operations. If a
release occurred from surface equipment, the amount of C02 released would be quantified based on the
operating conditions at the time, including pressure, flow rate, size of the leak point opening, and duration
of the leak.

Leakage from Existing and Future Wells within MMA

Stakeholder continuously monitors and collects injection volumes, pressures, temperatures and gas
composition data, through their SCADA systems, for the Rattlesnake AGI #1 well. This data is reviewed by
qualified personnel and will follow response and reporting procedures when data is outside acceptable
performance limits. Rattlesnake AGI #1 has a pressure and temperature gauge placed in the injection stream
at its wellhead, and a pressure gauge on the casing annulus. A change of pressure on the annulus would
indicate the presence of a possible leak. Mechanical integrity tests ("MITs") performed annually would also
indicate the presence of a leak. Upon a negative MIT, the well would immediately be isolated and the leak
mitigated.

The ten offset penetrating wells within the MMA are adequately cased and cemented to prevent potential
leakage of C02 from the Rattlesnake AGI #1 well plume. Additionally, the plugged wells were done so in a
way to prevent migration of C02 as provided in Appendix E. As discussed previously, Rule 13 would ensure
that new wells in the field would be constructed in a manner to prevent migration from the injection interval.

In addition to the fixed and personal monitors described previously, Stakeholder will also establish and
operate an in-field monitoring program to detect any C02 leakage within the AMA. The scope of work will
include H2S and C02 monitoring at the AGI well site as well as minimum, quarterly atmospheric monitoring
near identified penetrations within the AMA. Upon approval of the MRV and through the post-injection
monitoring period, Stakeholder will have these monitoring systems in place. Additional monitoring will be
added as the AMA is updated over time.

At the well site, H2S and C02 concentrations will be monitored continuously with fixed monitors that detect

55


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atmospheric concentrations of H2S and C02. At penetrating well sites, Stakeholder will similarly measure
atmospheric concentrations of C02 and H2S using mobile gas monitors. This data will be recorded at least
quarterly.

Groundwater Quality Monitoring

Stakeholder will monitor the groundwater quality in fluids above the confining interval by sampling the well
on the facility property and analyzing the sample with a third-party laboratory on an annual basis. Any
significant changes to the water analysis would be investigated to determine if such change was a result of
leakage from the Rattlesnake AGI #1 well. The parameters to be measured will include pH, total dissolved
solids, total inorganic and organic carbons, density, temperature and other standard laboratory
measurements. Any significant differences in these parameters from the baseline sample will be evaluated
to determine if leakage of C02 to the USDW may have occurred.

Leakage through Faults, Fractures or Confining Seals

Stakeholder continuously monitors the operations of the Rattlesnake AGI #1 well through automated
systems. Any deviation from normal operating conditions indicating movement into a potential pathway
such as a fault or breakthrough of the confining seal would trigger an alert. Any such alert would be reviewed
by field personnel and action taken to shut in the well, if necessary. Field H2S monitoring systems would alert
field personnel for any release of H2S/C02 caused by such leakage.

Leakage through Natural or Induced Seismicitv

While the likelihood of a natural or induced seismicity event is extremely low, Stakeholder plans to install a
seismic monitoring station in the general area of the Rattlesnake AGI #1 well. The installation of this station
would start upon approval of the MRV plan, with an expected in-service data within six months after the
commencement of the installation project. This monitoring station will be tied in to the Bureau of Economic
Geology's TexNet Seismic Monitoring system. If a seismic event of 3.0 magnitude or greater is detected,
Stakeholder will review the injection volumes and pressures at the Rattlesnake AGI #1 well to determine if
any significant changes occur that would indicate potential leakage.

56


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SECTION 6 - BASELINE DETERMINATIONS

This section identifies the strategies Stakeholder will undertake to establish the expected baselines for
monitoring C02 surface leakage per 40 CFR §98.448(a)(4). Stakeholder will use the existing SCADA monitoring
systems to identify changes from expected performance that may indicate leakage of C02.

Visual Inspections

Daily inspections will be conducted by field personnel at the 30-30 Facility and the Rattlesnake AGI #1 well.
These inspections will aid with identifying and addressing issues timely to minimize the possibility of leakage.
If any issues are identified, such as vapor clouds or ice formations, corrective actions would be taken to
address such issues.

H2S Detection

H2S will be initially injected into the AGI well at a concentration of approximately ten (10) percent or 100,000
ppm. The concentration will drop to approximately seven (7) percent as additional volumes are added. H2S
gas detectors are located throughout the AGI facility and well site and are set to trigger the alarm at 10 ppm.
Additionally, all field personnel are required to wear personal H2S monitors, which are set to trigger the alarm
at 5 ppm. Any alarm would trigger an immediate response to protect personnel and verify that the monitors
are working properly. If monitors are working correctly, immediate actions would be taken to secure the
facility and mitigate potential leaks.

CO2 Detection

Any C02 release would be accompanied by H2S and therefore the H2S monitors at the facility would also serve
as a C02 release warning system. In addition to the fixed and personal monitors described previously,
Stakeholder will also establish and operate an in-field monitoring program to detect any C02 leakage within
the AMA. The scope of work will include H2S and C02 monitoring at the AGI well site as well as atmospheric
monitoring near identified penetrations within the AMA.

Operational Data

Upon starting injection operations, baseline measurements of injection volumes and pressures will be taken.
Any significant deviations over time will be analyzed for indication of leakage of C02.

Continuous Monitoring

Mass of C02 emitted by surface leakage and equipment leaks will not be measured directly as the injection
stream for this well contains H2S which would be extremely dangerous for personnel to perform a direct leak
survey. Any leakage would be detected and managed as per Texas regulations and Stakeholder's TRRC-
approved H2S Contingency Plan. Gas detectors and continuous monitoring systems would trigger an alarm
upon a release. The mass of the C02 released would be calculated for the operating conditions at the time,
including pressure, flow rate, size of the leak point opening, and duration of the leak. This method is
consistent with 40 CFR §98.448(a)(5), allowing the operator to calculate site-specific variables used in the
mass balance equation.

57


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No C02 emissions will occur from venting because of the high H2S concentrations. Blowdown emissions are
sent to flares and would be reported as part of the required reporting for the gas plant.

Groundwater Monitoring

An initial sample will be taken from the groundwater well on Stakeholder's property, identified as Well #
482963 in Table 9 above, upon approval of Stakeholder's MRV and prior to increasing injection. The sample
will be analyzed by a third-party laboratory to establish the baseline properties of the groundwater.

58


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SECTION 7 - SITE SPECIFIC CONSIDERATIONS FOR MASS BALANCE

EQUATION

This section identifies how Stakeholder will calculate the mass of C02 injected, emitted, and sequestered.
This also includes site-specific variables for calculating the C02 emissions from equipment leaks and vented
emissions of C02 between the injection flow meter and the injection well, per 40 CFR §98.448(a)(5).

Mass of CO2 Received

Per 40 CFR §98.443, the mass of C02 received must be calculated using the specified C02 received equations
"unless you follow the procedures in 40 CFR §98.444(a)(4)." 40 CFR §98.444(a)(4) states that "if the C02 you
receive is wholly injected and is not mixed with any other supply of C02, you may report the annual mass of
C02 injected that you determined following the requirements under paragraph (b) of this section as the total
annual mass of C02 received instead of using Equation RR-1 or RR-2 of this subpart to calculate C02 received."
The C02 received for this injection well is wholly injected and not mixed with any other supply and the annual
mass of C02 injected will equal the amount received. Any future streams would be metered separately before
being combined into the calculated stream.

Mass of CO2 Injected

Per 40 CFR §98.444(b), since the flow rate of C02 injected will be measured with a volumetric flow meter, the
total annual mass of C02, in metric tons, will be calculated by multiplying the mass flow by the C02
concentration in the flow according to Equation RR-5:

C02,u = Annual C02 mass injected (metric tons) as measured by flow meter u

QP,u = Quarterly volumetric flow rate measurement for flow meter u in quarter p (metric tons per

D = Density of C02 at standard conditions (metric tons per standard cubic meter): 0.0018682

Cco2,P,u = Quarterly C02 concentration measurement in flow for flow meter u in quarter p (wt. percent
C02, expressed as a decimal fraction)

p = Quarter of the year

u = Flow meter

4

p = 1

where:

quarter)

59


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Mass of CO2 Produced

The Rattlesnake AGI #1 well is not part of an enhanced oil recovery project; therefore, no C02 will be
produced.

Mass of CO2 Emitted by Surface Leakage

Mass of C02 emitted by surface leakage and equipment leaks will not be measured directly as the injection
stream for this well contains H2S which would be extremely dangerous for personnel to perform a direct leak
survey. Any leakage would be detected and managed as a major upset event. Gas detectors and continuous
monitoring systems would trigger an alarm upon a release. The mass of the C02 released would be calculated
for the operating conditions at the time, including pressure, flow rate, size of the leak point opening, and
duration of the leak. This method is consistent with 40 CFR §98.448(a)(5), allowing the operator to calculate
site-specific variables used in the mass balance equation.

In the unlikely event that C02 was released as a result of surface leakage, the mass emitted would be
calculated for each surface pathway according to methods outlined in the plan and totaled using Equation
RR-10 as follows:

C02 = Total annual C02 mass emitted by surface leakage (metric tons) in the reporting year
C02,x= Annual C02 mass emitted (metric tons) at leakage pathway x in the reporting year
X = Leakage pathway

Calculation methods from subpart W will be used to calculate C02 emissions from equipment located on
the surface between the flow meter used to measure injection quantity and the injection wellhead

Mass of CO2 Sequestered

The mass of C02 sequestered in subsurface geologic formations will be calculated based off Equation RR-12,
as this well will not actively produce oil or natural gas or any other fluids, as follows:

X

X=1

Where:

CO 2 — C02i C02e C02fi

Where:

60


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C02 = Total annual C02 mass sequestered in subsurface geologic formations (metric tons) at the
facility in the reporting year

CO21 = Total annual C02 mass injected (metric tons) in the well or group of wells covered by this source
category in the reporting year

C02E = Total annual C02 mass emitted (metric tons) by surface leakage in the reporting year

CO 2fi - Total annual C02 mass emitted (metric tons) from equipment leaks and vented emissions of
C02 from equipment located on the surface between the flow meter used to measure injection
quantity and the injection wellhead

CO 2fi will be calculated in accordance with Subpart W reporting of GHGs. Because no venting would occur
due to the high H2S concentrations of the injectate stream, the calculations would be based on the blowdown
emissions that would be sent to flares and would be reported as part of the required GHG reporting for the
gas plant.

• Calculation methods from subpart W will be used to calculate C02 emissions from equipment located
on the surface between the flow meter used to measure injection quantity and the injection
wellhead.

61


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SECTION 8 - IMPLEMENTATION SCHEDULE FOR MRV PLAN

The Rattlesnake AGI #1 well currently reports GHGs under Subpart UU, but Stakeholder has elected to submit
an MRV plan under, and otherwise comply with, Subpart RR. The MRV plan will be implemented upon
receiving EPA approval. The Annual Subpart RR Report will be filed on March 31st of the year following the
reporting year.

62


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SECTION 9 - QUALITY ASSURANCE

This section identifies how Stakeholder plans to manage quality assurance and control, to meet the

requirements of 40 CFR §98.444.

Monitoring QA/QC

C02 Injected

•	The flow rate of the C02 being injected will be measured with a volumetric flow meter, consistent
with industry best practices. These flow rates will be compiled quarterly.

•	The composition of the C02 stream will be measured upstream of the volumetric flow meter with a
continuous gas composition analyzer or representative sampling consistent with industry best
practices.

•	The gas composition measurements of the injected stream will be averaged quarterly.

•	The C02 measurement equipment will be calibrated according to manufacturer recommendations.

C02 Emissions from Leaks and Vented Emissions

•	Gas detectors will be operated continuously, except for maintenance and calibration.

•	Gas detectors will be calibrated according to manufacturer recommendations and API standards.

•	Calculation methods from subpart W will be used to calculate C02 emissions from equipment located
on the surface between the flow meter used to measure injection quantity and the injection
wellhead.

Measurement Devices

•	Flow meters will be continuously operated except for maintenance and calibration.

•	Flow meters will be calibrated according to the requirements in 40 CFR §98.3(i).

•	Flow meters will be operated per an appropriate standard method as published by a consensus-
based standards organization.

•	Flow meter calibrations will be traceable to the National Institute of Standards and Technology
(NIST).

All measured volumes of C02 will be converted to standard cubic meters at a temperature of 60 degrees

Fahrenheit and an absolute pressure of 1 atmosphere.

Missing Data

In accordance with 40 CFR §98.445, Stakeholder will use the following procedures to estimate missing data

if unable to collect the data needed for the mass balance calculations:

•	If a quarterly quantity of C02 injected is missing, the amount will be estimated using a representative
quantity of C02 injected from the nearest previous period of time at a similar injection pressure.

•	Fugitive C02 emissions from equipment leaks from facility surface equipment will be estimated and
reported per the procedures specified in subpart W of 40 CFR §98.

63


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MRV Plan Revisions

If any of the changes outlined in 40 CFR §98.448(d) occur, Stakeholder will revise and submit an amended
MRV plan within 180 days to the Administrator for approval.

64


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SECTION 10 - RECORDS RETENTION

Stakeholder will retain records as required by 40 CFR §98.3(g). These records will be retained for at least
three years and include:

•	Quarterly records of the C02 injected

o Volumetric flow at standard conditions
o Volumetric flow at operating conditions
o Operating temperature and pressure
o Concentration of the C02 stream

•	Annual records of the information used to calculate the C02 emitted by surface leakage from leakage
pathways.

•	Annual records of information used to calculate C02 emitted from equipment leaks and vented
emissions of C02 from equipment located on the surface between the flow meter used to measure
injection quantity and the injection wellhead.

65


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References

Broadhead, Ronald E., 2005. Regional Aspects of the Wristen petroleum system, southeastern New Mexico:
New Mexico Bureau of Geology and Mineral Resources Open File Report, no. 485.

Comer, John B., 1991. Stratigraphic Analysis of the Upper Devonian Woodford Formation, Permian Basin,
West Texas and Southeastern New Mexico: Bureau of Economic Geology Report of Investigations, no. 201.

George, Peter G., Mace, Robert E., and Petrossian, Rima, 2011. Aquifers of Texas: Texas Water Development
Board Report, no 380.

Hoak, T., Sundberg, K., and Ortoleva, P. Overview of the Structural Geology and Tectonics of the Central Basin
Platform, Delaware Basin, and Midland Basin, West Texas and New Mexico: Department of Energy Open File
Report.

Molina, Oscar, Vilarras, Victor, and Zeidouni, Mehdi, 2016. Geologic carbon storage for shale gas recovery:
13th International Conference on Greenhouse Gas Control Technologies, GHGT-13, 14-18.

Ruppel, Stephen C. and Holtz, Mark H., 1994. Depositional and Diagenetic Facies Patterns and Reservoir
Development in Silurian and Devonian Rocks of the Permian Basin: Bureau of Economic Geology Report of
Investigations, no. 216.

Snee, Jens-Erik Lund and Zoback, Mark D., 2016. State of stress in the Permian Basin, Texas and New Mexico:
Implications for induced seismicity.

Teeple, Andrew P., Ging, Patricia B., Thomas, Jonathan V., Wallace, David S., and Payne, Jason D., 2021.
Hydrogeologic Framework, Geochemistry, Groundwater-Flow System, and Aquifer Hydraulic Properties Used
in the Development of a Conceptual Model of the Ogallala, Edwards-Trinity (High Plains), and Dockum
Aquifers In and Near Gaines, Terry, and Yoakum Counties, Texas: USGS Scientific Investigations Report 2021-
5009.

66


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APPENDICES


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APPENDIX A-GEOLOGY

APPENDIX A-l: SILURIAN STRUCTURE MAP
APPENDIX A-2: NE-SW CROSS SECTION
APPENDIX A-3: NW-SE CROSS SECTION
APPENDIX A-4: FORMATION FLUID SAMPLE WELL MAP


-------

-------
mi

LONQU 1ST

SEQUESTRATION L

Stakeholder Midstream


-------
42501105700000
1-667

TEXAS CRUDE OIL CO

42501358340000
ROBERTS UNIT
2

APACHE

<14,201 FT>

42501369980000
RATTLESNAKE AG I
1

STAKEHOLDER GAS SERVICES


-------
Rattlesnake AGI No. 1
Maximum Monitoring Area
with

Formation Fluid Sample Wells

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 6/1/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY





ENGINEERS

ADVISORS



| AUSTIN • HOUSTON J

I CALGARY-WICHITA

| DENVER

• COLLEGE STATION |

[ BATON ROUGE • EDMONTON

-J- Rattlesnake AGI No. 1 SHL
|	I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent


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APPENDIX B -TRRC FORMS Rattlesnake AG I #1

APPENDIX B-l: UIC CLASS II ORDER

APPENDIX B-2: GAU GROUNDWATER PROTECTION DETERMINATION
APPENDIX B-3: DRILLING PERMIT
APPENDIX B-4: COMPLETION REPORT


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Christi Craddick, Chairman
Ryan Sitton, Commissioner
Wayne Christian, Commissioner

B-1

Danny Sorrells
Assistant Executive Director
Director, Oil and Gas Division
Leslie Savage

Assistant Director, Technical Permitting

Railroad Commission of Texas

OIL AND GAS DIVISION

PERMIT TO DISPOSE OF NON-HAZARDOUS OIL AND GAS WASTE BY INJECTION INTO A
POROUS FORMATION NOT PRODUCTIVE OF OIL AND GAS

PERMIT NO. 15848

SANTA FE MIDSTREAM PERMIAN LLC
5830 GRANITE PKWY STE 1025
PLANO, TX 75024

DOCKET NO. 8A-0312019

Authority is granted to inject Non-Hazardous Oil and Gas waste into the well identified herein in accordance
with Statewide Rule 9 of the Railroad Commission of Texas and based on information contained in the
application (Form W-14) dated March 12, 2018 for the permitted interval of the DEVONIAN formation and
subject to the following terms and special conditions:

RATTLESNAKE AGI (000000) LEASE

WASSON FIELD

YOAKUM COUNTY, DISTRICT 8A

WELL II

DENTIFIC ATION AND P]

ERMIT PA]

RAMET]

ERS:

Well No.

API No.

UIC Number

Permitted
Fluids

Top
Interval
(feet)

Bottom
Interval
(feet)

Maximum
Liquid
Daily
Injection
Volume
(BBL/day)

Maximum
Gas Daily
Injection
Volume
(MCF/day)

Maximum
Surface
Injection
Pressure
for Liquid
(PSIG)

Maximum
Surface
Injection
Pressure
for Gas
(PSIG)

1

50136998

000117143

C02, and
H2S

11,000

12,000

4,500

N/A

N/A

2,200

SPECIAL CONDITIONS:

Well No.

API No.

Special Conditions

1

50136998

1.	Open hole completions shall have a plug back depth no deeper than the bottom of the
permitted injection interval.

2.	The operator shall provide to the UIC section an annotated electric log, and a mud log if
available, of the subject well with the top(s) and bottom(s) of the permitted formation
indicated on the log. Top and bottom of the authorized injection interval may be modified
based on electric log or mud log indications of the top and bottom of the permitted
formations.

1701 NORTH CONGRESS AVENUE * POST OFFICE BOX 12967 * AUSTIN. TEXAS 78711-2967 * PHONE: 512/463-6792* FAX: 512/463-6780
TDD 800/735-2989 OR TDY 512/463-7284 * AN EQUAL OPPORTUNITY EMPLOYER* http://www.rrc.texas.gov


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STANDARD CONDITIONS:

1.	Injection must be through tubing set on a packer. The packer must be set no higher than 100 feet above the
top of the permitted interval.

2.	The District Office must be notified 48 hours prior to:

a.	running tubing and setting packer;

b.	beginning any work over or remedial operation;

c.	conducting any required pressure tests or surveys.

3.	The wellhead must be equipped with a pressure observation valve on the tubing and for each annulus.

4.	Prior to beginning injection and subsequently after any work over, an annulus pressure test must be
performed. The test pressure must equal the maximum authorized injection pressure or 500 psig, whichever
is less, but must be at least 200 psig. The test must be performed, and the results submitted in accordance
with the instructions of Form H-5.

5.	The injection pressure and injection volume must be monitored at least monthly and reported annually on
Form H-10 to the Commission's Austin office.

6.	Within 30 days after completion, conversion to disposal, or any work over which results in a change in well
completion, a new Form W-2 or G-l must be filed to show the current completion status of the well. The
date of the disposal well permit, and the permit number must be included on the new Form W-2 or G-l.

7.	Written notice of intent to transfer the permit to another operator by filing Form P-4 must be submitted to
the Commission at least 15 days prior to the date of the transfer.

8.	This permit will expire when the Form W-3, Plugging Record, is filed with the Commission. Furthermore,
permits issued for wells to be drilled will expire three (3) years from the date of the permit unless drilling
operations have commenced.

Provided further that, should it be determined that such injection fluid is not confined to the approved interval, then
the permission given herein is suspended and the disposal operation must be stopped until the fluid migration from
such interval is eliminated. Failure to comply with all of the conditions of this permit may result in the operator
being referred to enforcement to consider assessment of administrative penalties and/or the cancellation of the
permit.

APPROVED AND ISSUED ON November 14. 2018.

Injection-Storage Permits Unit

IN-HOUSE AMENDMENT TO CORRECT THE RATE.

Note: This document will only be distributed electronically.

PERMIT NO. 15848
Page 2 of 2


-------
GROUNDWATER PROTECTION DETERMINATION
Groundwater Advisory Unit

Form GW-2

B-2

Date Issued:

31 August 2017

GAU Number:

179154

Attention:

SANTA FE MIDSTREAM

API Number:





5700 GRANITE PARKWAY

County:

YOAKUM



PLANO, TX 75024

Lease Name:

Roberts Unit

Operator No.:

748093

Lease Number:

Well Number:

Total Vertical Depth:
Latitude:

Longitude:

Datum:

019212
1

11000
33.049990
-102.903464
NAD27

Purpose:

New Drill





Location:

Survey-Gibson, J H/Poole, J T; Block-D; Section-733



To protect usable-quality groundwater at this location, the Groundwater Advisory Unit of the Railroad Commission of
Texas recommends:

The interval from the land surface to a depth of 375 feet must be protected.

Note: Unless stated otherwise, this recommendation is intended to apply only to the subject well and not for area-wide use.
This recommendation is for normal drilling, production, and plugging operations only. It does not apply to saltwater disposal
operation into a nonproductive zone (RRC Form W-14).

This determination is based on information provided when the application was submitted on 08/30/2017. If the location
information has changed, you must contact the Groundwater Advisory Unit, and submit a new application if necessary.
If you have questions, please contact us at 512-463-2741 orgau@rrc.texas.gov.

Groundwater Advisory Unit, Oil and Gas Division

Form GW-2 P.O. Box 12967 Austin, Texas 78771-2967 512-463-2741 Internet address: www.rrc.texas.gov
Rev. 02/2014


-------
APINa 42-501-36998

RAILROAD COMMISSION OF TEXAS
OIL & GAS DIVISION

APPLICATION FOR PERMIT TO DRILL, RECOMPLETE, OR RE-ENTER

This facsimile W-l was generated electronically from data submitted to the RRC.

A certification of the automated data is available in the RRC's Austin office.

FORM W-l 07/2004

Drilling Permit #

839303

SWR Exception Case/Docket No.

Permit Status: Approved

B-3

1. RRC Operator No.

748093

2. Operator's Name (as shown on form P-5, Organization Report)

SANTA FE MIDSTREAM PERMIAN LLC

3. Operator Address (include street, city, state, zip):

5830 GRANITE PKWY STE 1025
PLANO, TX 75024-0000

4. Lease Name

RATTLESNAKE AGI

5. Well No.

1

GENERAL INFORMATION

6. Purpose of filing (mark ALL appropriate boxes): Ix] New Drill EH Recompletion EH Reclass EH Field Transfer EH Re-Enter

EH Amended EH Amended as Drilled (BHL) (Also File Form W-1D)

7. Wellbore Profile (mark ALL appropriate boxes): 0 Vertical EH Horizontal (Also File Form W-1H) EH Directional (Also File Form W-1D) EH Sidetrack

8. Total Depth

12000

9. Do you have the right to develop the [x] - | |
minerals under any right-of-way ?

10. Is this well subject to Statewide Rule 36 (hydrogen sulfide area)? IS Yes EH \0

SURFACE LOCATION AND ACREAGE INFORMATION

11. RRC District No.

8A

12. County I—, ,—, ,—, ,—¦

YOAKUM 13. Surface Location LXI Land 1—1 Bay/Estuary 1—1 Inland Waterway 1—1 Offshore

14. This well is to be located miles in a NW direction from DENVER CITY which is the nearest town in the county of the well site.

15. Section 16. Block 17. Survey 18. Abstract No.

733 D GIBSON, J H A-89

19. Distance to nearest lease line:

200 ft-

20. Number of contiguous acres in

lease, pooled unit, or unitized tract: 640

21.	Lease ]

22.	Survey

'erpendiculars: 200 ft from the NORTH line and 200 ft froi

nt
nt

ie WEST line.



PprppiiHii^iilars" 200 ft from the NORTH line and 200 ft froi

le WEST line.

23. Is this a pooled unit? EH Yes B No 24. Unitization Docket No:

25. Are you applying for Substandard Acreage Field? EH Yes (attach Form W-1A) S No

FIELD INFORMATION List all fields of anticipated completion including Wildcat. List one zone per line.

26. RRC
District No.

27. Field No.

28. Field Name (exactly as shown in RRC records)

29. Well Type

30. Completion Depth

31. Distance to Nearest
Well in this Reservoir

32. Number of Wells on
this lease in this
Reservoir

8A

95397001

WASSON

Injection Well

12000

0.00

1

8A

95399400

WASSON, NORTH (SAN ANDRES)

Injection Well

12000

0.00

1





























BOTTOMHOLE LOCATION INFORMATION is required for DIRECTIONAL, HORIZONTAL, AND AMENDED AS DRILLED PERMIT APPLICATIONS

Remarks

[FILER Apr 16, 2018 5:16 PM]: Filing for an acid gas injection well.

Certificate:

I certify that information stated in this application is true and complete, to the
best of my knowledge.

Jessica Risien, Regulatory Compliance

Specialist Apr 25, 2018

Name of filer Date submitted

(281)8729300 jrisien@ntglobal.com

Phone E-mail Address (OPTIONAL)

RRC Use Only Data Validation Time Stamp: Apr 27, 2018 10:36 AM( As Approved' Version )

Page 1 of 1


-------
NOTE: Acreages shown hereon ere based on Information provided by others.

This plat represents a staked well location and does not represent a boundary survey.
The Information shown does not meet the current TBPLS minimum standards for boundary
surveys. Limited field measurements were acquired. Lease and tract line Information is
compiled from record information and additional sources.

NOTES:

1)

2)

3-J

ALL BEARINGS. DISTANCES ANO COORDINATES SHOWN
HEREON WERE DERIVED FROM <3. P S. OBSERVATIONS
CONVERTED TO THE TEXAS COORDINATE SYSTEM,
NORTH CENTRAL ZONE (NAD 1993). US FOOT AND ARE
REFERENCED TO THE LOCAL GNSS RTK NETWORK.
THE PROPOSED WELL LOCATION IS SITUATED N 37~W -
7.3 MILES FROM DENVER CITY, TX.

THE PROPOSED WELL LOCATION IS SITUATED SOW FROM
THE NSL AND 200 FROM THE WSL.

6

5°X'

rC-< liw



SECTION 704. BLOCK D
J. H. GIBSON SURVEY-
ABSTRACT NO. 1144
YOAKUM COUNTY. TX

704

733

RA TTLESMAKE AGf No.
(PROPOSED)

.0^

SURFACE L OCA T/ON
NAD 83, TX-NC, U.S. FT.
NORTH/NG/Y; 7093713.4ST
EASTING/X 619409-13"

LATITUDE (DDJ- 33.05134722°
LONGITUDE (DO)- -102.90450555*

NAD 27, TX-NC, US- FT,
NORTHfNG/Y: 546285.34*
EAST/NG/X; 344968.61'

LA TTTUDE (DO)- 33.05124473"
LONGITUDE (DO)- -102.90401331°
SURFACEELEVA T/ON- 3627.05-

732

*

83^8

2

5>^0
S



Af /=>&?AfMA/LLG
rtATTL£SA/j4/C£-s4G/A/o. 7
*/.M. G/&SOA/ SURWEK
SEGT/OA/ 733, &LOC/C0
yOAKt/AS GCHSA/TX TjEXAS

m	Y aHcmws80i*a,7x:7B>

IhtebkityRk

i ] Positions, llc


-------
Railroad Commission of Texas

PERMIT TO DRILL, RE-COMPLETE, OR RE-ENTER ON REGULAR OR ADMINISTRATIVE EXCEPTION LOCATION

CONDITIONS AND INSTRUCTIONS

Permit Invalidation. It is the operator's responsibility to make sure that the permitted location complies with Commission density and
spacing rules in effect on the spud date. The permit becomes invalid automatically if, because of a field rule change or the drilling of another
well, the stated location is not in compliance with Commission field rules on the spud date. If this occurs, application for an exception to
Statewide Rules 37 and 38 must be made and a special permit granted prior to spudding. Failure to do so may result in an allowable not being
assigned and/or enforcement procedures being initiated.

Notice Requirements. Per H.B 630, signed May 8,2007, the operator is required to provide notice to the surface owner no later than the
15th business day after the Commission issues a permit to drill. Please refer to subchapter Q Sec. 91.751-91.755 of the Texas Natural
Resources Code for applicability.

Permit expiration. This permit expires two (2) years from the date of issuance shown on the original permit. The permit period will not
be extended.

Drilling Permit Number. The drilling permit number shown on the permit MUST be given as a reference with any notification to the
district (see below), correspondence, or application concerning this permit.

Rule 37 Exception Permits. This Statewide Rule 37 exception permit is granted under either provision Rule 37 (h)(2)(A) or 37(h)(2)(B).
Be advised that a permit granted under Rule 37(h)(2)(A), notice of application, is subject to the General Rules of Practice and Procedures
and if a protest is received under Section 1.3, "Filing of Documents," and/or Section 1.4, "Computation of Time," the permit may be deemed
invalid.

Before Drilling

Fresh Water Sand Protection. The operator must set and cement sufficient surface casing to protect all usable-quality water, as defined by
the Railroad Commission of Texas (RRC) Groundwater Advisory Unit (GWAU). Before drilling a well, the operator must obtain a letter from
the Railroad Commission of Texas stating the depth to which water needs protection, Write: Railroad Commission of Texas, Groundwater
Advisory Unit (GWAU), P.O. Box 12967, Austin, TX 78711-3087. File a copy of the letter with the appropriate district office.

Accessing the Well Site. If an OPERATOR, well equipment TRANSPORTER or WELL service provider must access the well site from a
roadway on the state highway system (Interstate, U.S. Highway, State Highway, Farm-to-Market Road, Ranch-to-Market Road, etc.), an
access permit is required from TxDOT. Permit applications are submitted to the respective TxDOT Area Office serving the county where the
well is located.

Water Transport to Well Site. If an operator intends to transport water to the well site through a temporary pipeline laid above
ground on the state's right-of-way, an additional TxDOT permit is required. Permit applications are submitted to the respective
TxDOT Area Office serving the county where the well is located.

^NOTIFICATION

The operator is REQUIRED to notify the district office when setting surface casing, intermediate casing, and production casing, or when
plugging a dry hole. The district office MUST also be notified if the operator intends to re-enter a plugged well or re-complete a well into a
different regulatory field. Time requirements are given below. The drilling permit number MUST be given with such notifications.

During Drilling

Permit at Drilling Site : A copy of the Form W-l Drilling Permit Application, the location plat, a copy of Statewide Rule 13
alternate surface casing setting depth approval from the district office, if applicable, and this drilling permit must be kept at the
permitted well site throughout drilling operations.

*Notification of Setting Casing : The operator MUST call in notification to the appropriate district office (phone number shown the
on permit) a minimum of eight (8) hours prior to the setting of surface casing, intermediate casing, AND production casing. The
individual giving notification MUST be able to advise the district office of the drilling permit number.

*Notification of Re-completion/Re-entry : The operator MUST call in notification to the appropriate district office (phone number
shown on permit) a minimum of eight (8) hours prior to the initiation of drilling or re-completion operations. The individual giving
notification MUST be able to advise the district office of the drilling permit number.

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 1 of 5


-------
Completion and Plugging Reports

Hydraulic Fracture Stimulation using Diesel Fuel: Most operators in Texas do not use diesel fuel in hydraulic fracturing fluids.

Section 322 of the Energy Policy Act of 2005 amended the Underground Injection Control (UIC) portion of the federal Safe Drinking Water
Act (42 USC 300h(d)) to define "underground Injection" to EXCLUDE " ...the underground injection of fluids or propping agents (other
than dieselfluels) pursuant to hydraulic fracturing operations related to oil, gas, or geothermal production activities." (italic and underlining
added.) Therefore, hydraulic fracturing may be subject to regulation under the federal UIC regulations if diesel fuel is injected or used as a
propping agent. EPA defined "diesel fuel" using the following five (5) Chemical Abstract Service numbers: 68334-30-5 Primary Name: Fuels,
diesel; 68476-34-6 Primary Name: Fuels, diesel, No. 2; 68476-30-2 Primary Name: Fuel oil No. 2; 68476-31-3 Primary Nmae: Fuel oil, No.
4; and 8008-20-6 Primary Name: Kerosene. As a result, an injection well permit would be required before performing hydraulic fracture
stimulation using diesel fuel as defined by EPA on any well in Texas. Hydraulic fracture stimulation using diesel fuel as defined by EPA on a
well in Texas without an injection well permit could result in enforcement action.

Producing Well: Statewide Rule 16 states that the operator of a well shall file with the Commission the appropriate completion report
within thirty (30) days after completion of the well or within ninety (90) days after the date on which the drilling operation is completed,
whichever is earlier. Completion of the well in a field authorized by this permit voids the permit for all other fields included in the permit
unless the operator indicates on the initial completion report that the well is to be a dual or multiple completion and promptly submits an
application for multiple completion. All zones are required to be completed before the expiration date on the existing permit. Statewide Rule
40(d) requires that upon successful completion of a well in the same reservoir as any other well previously assigned the same acreage,
proration plats and P-15s (if required) must be submitted with no double assignment of acreage.

Dry or Noncommercial Hole : Statewide Rule 14(b)(2) prohibits suspension of operations on each dry or non-commercial well without
plugging unless the hole is cased and the casing is cemented in compliance with Commission rules. If properly cased, Statewide Rule 14(b)(2)
requires that plugging operations must begin within a period of one (1) year after drilling or operations have ceased. Plugging operations must
proceed with due diligence until completed. An extension to the one-year plugging requirement may be granted under the provisions stated in
Statewide Rule 14(b)(2).

Intention to Plug : The operator must file a Form W-3 A (Notice of Intention to Plug and Abandon) with the district office at least five (5)
days prior to beginning plugging operations. If, however, a drilling rig is already at work on location and ready to begin plugging operations,
the district director or the director's delegate may waive this requirement upon request, and verbally approve the proposed plugging
procedures.

*Notification of Plugging a Dry Hole : The operator MUST call in notification to the appropriate district office (phone number shown on
permit) a minimum of four (4) hours prior to beginning plugging operations. The individual giving the notification MUST be able to advise
the district office of the drilling permit number and all water protection depths for that location as stated in the Texas Commission on
Environmental Quality letter.

DIRECT INQUIRIES TO: DRILLING PERMIT SECTION, OIL AND GAS DIVISION

PHONE
(512) 463-6751

MAIL:

PO Box 12967
Austin, Texas, 78711-2967

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 2 of 5


-------
RAILROAD COMMISSION OF TEXAS
OIL & GAS DIVISION

PERMIT TO DRILL, DEEPEN, PLUG BACK, OR RE-ENTER ON A REGULAR OR ADMINISTRATIVE EXCEPTION LOCATION

PERMIT NUMBER

839303

DATE PERMIT ISSUED OR AMENDED
04/27/2018

DISTRICT

8A

API NUMBER

42-501-36998

FORM W-l RECEIVED

04/25/2018

COUNTY

YOAKUM

TYPE OF OPERATION

New Drill

WELLBORE PROFILE(S)

Vertical

ACRES

640.0

OPERATOR 748093
SANTA FE MIDSTREAM PERMIAN LLC

5830 GRANITE PKWY STE 1025
PLANO, TX 75024-0000

NOTICE

This permit and any allowable assigned may
be revoked if payment for fee(s) submitted to
the Commission is not honored.
District Office Telephone No:

(806) 698-6509

LEASE NAME

RATTLESNAKE AGI

WELL NUMBER

1

LOCATION

7.3 miles NW direction from DENVER CITY

TOTAL DEPTH

12000

Section, Block and/or

SECTION 733 BLOCK D ABSTRACT 89
SURVEY GIBSON, J H

DISTANCE TO SURVEY LINES

200.0 ft NORTH 200.0 ft WEST

DISTANCE TO NEAREST LEASE LINE
200.0

DISTANCE TO LEASE LINES

200.0 ft NORTH 200.0 ft WEST

DISTANCE TO NEAREST WELL ON LEASE
See FIELD(s) Below

FIELD(s) and LIMITATIONS:

* SEE FIELD DISTRICT FOR REPORTING PURPOSES *

FIELDNAME	ACRES	DEPTH WELL#	DIST

LEASE NAME	NEAREST LEASE	NEAREST WELL

WASSON	"640!0	12000	1	8A

RATTLESNAKE AGI	200 0	0.0

This is a hydrogen sulfide field. This well shall be drilled in accordance with SWR 36.

Do not use this well for injection/disposal/hydrocarbon storage purposes without approval by the Environmental Services section of the Railroad Commission,
Austin, Texas office.

WASSON, NORTH (SAN ANDRES)	"64o!o	12000	1	8A

RATTLESNAKE AGI	200.0	0.0

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 3 of 5


-------
This is a hydrogen sulfide field. This well shall be drilled in accordance with SWR 36.

Do not use this well for injection/disposal/hydrocarbon storage purposes without approval by the Environmental Services section of the Railroad Commission,
Austin, Texas office.

THE FOLLOWING RESTRICTIONS APPLY TO ALL FIELDS
This well shall be completed and produced in compliance with applicable special field or statewide spacing and density rules. If this well is
to be used for brine mining, underground storage of liquid hydrocarbons in salt formations, or underground storage of gas in salt formations,
a permit for that specific purpose must be obtained from Environmental Services prior to construction, including drilling, of the well in
accordance with Statewide Rules 81, 95, and 97.

This well must comply to the new SWR 3.13 requirements concerning the isolation of any potential flow zones and zones with corrosive
formation fluids. See approved permit for those formations that have been identified for the county in which you are drilling the well in.

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 4 of 5


-------
Railroad Commission of Texas

Oil and Gas Division

SWR #13 Formation Data
YOAKUM (501) COUNTY

l-'oniiiilioii

Koniiirks

Order

I.ITcc(i\c
Diilo

RED BED-SANTA ROSA



1

01/01/2014

YATES



2

01/01/2014

SAN ANDRES

high flows, H2S, corrosive

3

01/01/2014

GLORIETA



4

01/01/2014

CLEARFORK

Active C02 Flood

5

01/01/2014

WICHITA



6

01/01/2014

LEONARD



7

01/01/2014

WOLFCAMP



8

01/01/2014

PENNSYLVANIAN



9

01/01/2014

STRAWN



10

01/01/2014

MISSISSIPPIAN



11

01/01/2014

DEVONIAN



12

01/01/2014

DEVONIAN-SILURIAN



13

01/01/2014

The above list may not be all inclusive, and may also include formations that do not intersect all wellbores. The listing order of the Formation
information reflects the general stratigraphic order and relative geologic age. This is a dynamic list subject to updates and revisions. It is the
operator's responsibility to make sure that at the time of spudding the well the most current list is being referenced. Refer to the RRC website
at the following address for the most recent information, http://www.rrc.texas.gov/oil-gas/compliance-enforcement/rule-13-geologic-
formation-info

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 5 of 5


-------
B-4

RAILROAD COMMISSION OF TEXAS	Form G-1

1701 N. Congress	Status:	Approved

P.O. Box 12967	Date:	07/25/2019

Austin, Texas 78701-2967	Tracking No.:	205926

GAS WELL BACK PRESSURE TEST, COMPLETION OR RECOMPLETION REPORT, AND LOG

OPERATOR INFORMATION

Operator Name: santa fe midstream permian llc	Operator No.: 748093

Operator Address: 5830 granite pkwy ste 1025 plano, tx 75024-0000

WELL INFORMATION

API No.: 42-501-36998

County: YOAKUM

Well No.: 1

RRC District No.: 8A

Lease Name: RATTLESNAKE AG I

Field Name: WASSON

RRC Gas ID No.: 286838

Field No.: 95397001

Location: Section: 733, Block: D, Survey: GIBSON, J H, Abstract: 89



Latitude:

Longitude:

This well is located 7.3 miles in a nw



direction from Denver city,



which is the nearest town in the county.



FILING INFORMATION

Purpose of filing: Well Record Only



Type of completion: New Well



Well Type: Active UIC

Completion or Recompletion Date: 08/31/2018

Type of Permit

Date Permit No.

Permit to Drill, Plug Back, or Deepen

04/27/2018 839303

Rule 37 Exception



Fluid Injection Permit



O&G Waste Disposal Permit

11/14/2018 15848

Other:



COMPLETION INFORMATION

ISpud date: 07/16/2018

Date of first production after rig released: 08/31/2018 I

Date plug back, deepening, recompletion, or Date plug back, deepening, recompletion, or

drilling operation commenced: 07/16/2018

drilling operation ended: 08/31/2018

Number of producing wells on this lease in

Distance to nearest well in lease &

this field (reservoir) including this well:

1 reservoir (ft.): 0.0

Total number of acres in lease: 640.00

Elevation (ft.): 3627 GR

Total depth TVD (ft.): 11980

Total depth MD (ft.):

Plug back depth TVD (ft.): 11980

Plug back depth MD (ft.):

Was directional survey made other than

Rotation time within surface casing (hours): 72.0

inclination (Form W-12)? Yes

Is Cementing Affidavit (Form W-15) attached? Yes

Recompletion or reclass? No

Multiple completion? No

Type(s) of electric or other log(s) run: Combo of Induction/Neutron/Density/Sonic

Electric Log Other Description:



Location of well, relative to nearest lease boundaries Off Lease: No

of lease on which this well is located:

200.0 Feet from the North Line and



200 0 Feet from the West Line of the



rattlesnake agi Lease.

FORMER FIELD (WITH RESERVOIR) & GAS ID OR OIL LEASE NO.

Field & Reservoir

Gas ID or Oil Lease No. Well No. Prior Service Type



Page 1 of4


-------
G1:	N/A

PACKET:	N/A

FOR NEW DRILL OR RE-ENTRY, SURFACE CASING DEPTH DETERMINED BY:
GAU Groundwater Protection Determination	Depth (ft.): 2025.0	Date: 01/12/2018

SWR 13 Exception	Depth (ft.):

GAS MEASUREMENT DATA

I Date of test: Gas measurement method(s):





Gas production during test (MCF):







Was the well preflowed for 48 hours? No







Orif. or 24 hr. Coeff.

Run Line Choke Orif. Or Choke Static Pm or Diff
No. size Size (in.) (in.) Choke (in.) (hw)

Flow

Temp Temp. Gravity
(°F) (l-tt) (hg)

Compress
(Fpv)

Volume
(MCF/day)

N/A







FIELD DATA AND PRESSURE CALCULATIONS

Gravity (dry gas):

Gas-Liquid Hydro Ratio (CF/Bbl):

Avg. shut in temp. (°F):

Gravity (liquid hydrocarbons) (Deg. API):

Gravity (mixture): Gmix=

Bottom hole temp, and depth: °F@ ft

Run No. Time of Run (Min.)

Choke Size (in.) Wellhead Pressure (PSIA) Wellhead Flow Temp (°F )

N/A



CASING RECORD

Casing Hole Setting Multi - Multi -	Cement Slurry Top of TOC

Type of

Size

Size

Depth Stage Tool Stage Shoe Cement Amount Volume Cement Determined

Row Casing

(in.)

(in.)

(ft.)

Depth (ft.) Depth (ft.)

Class

(sacks)

(cu. ft.)

(ft.)

By

1 Surface

13 3/8

17 1/2

504



c

510

687.5

0

Circulated to Surface

3 Intermediate

9 5/8

12 1/4

5498

5498

c

485

797.0

4275

Circulated to Surface

2 Intermediate

13 3/8

17 1/2

5498

4275

c

1650

3045.0

0

Circulated to Surface

6 Conventional Production

7

8 3/4

11023



WELL

60

337.0

9575

Calculation











LOCK









5 Conventional Production

7

8 3/4

11023

5591

PREM

380

906.5

0

Circulated to Surface











PLUS









4 Conventional Production

7

8 3/4

11023

9575

PREM

380

906.5

5591

Calculation











PLUS









LINER RECORD









Cement

Slurry

Top of

TOC

Liner Hole

Liner

Liner

Cement

Amount

Volume

Cement

Determined

Row Size (in.) Size (in.)

Top (ft.)

Bottom (ft.)

Class

(sacks)

(cu. ft.)

(ft.)

By

N/A















TUBING RECORD

Row

Size (in.)

Depth Size (ft.)

Packer Depth (ft.)/Type

1

3 1/2

10966

10966 / HALLIBURTON







BWD

PRODUCING/INJECTION/DISPOSAL INTERVAL

Row

Open hole?

From (ft.)

To (ft.)

1

Yes

L 11025

11980

Page 2 of4


-------
ACID, FRACTURE, CEMENT SQUEEZE,

CAST IRON BRIDGE PLUG, RETAINER, ETC.

Was hydraulic fracturing treatment performed? No

Is well equipped with a downhole actuation



sleeve? No

If yes, actuation pressure (PSIG):

Production casing test pressure (PSIG) prior to

Actual maximum pressure (PSIG) during hydraulic

hydraulic fracturing treatment:

fracturing:

Has the hydraulic fracturing fluid disclosure been



reported to FracFocus disclosure registry (SWR29)?

No

Row Type of Operation Amount and Kind of Material Used Depth Interval (ft.)

N/A



FORMATION RECORD

Is formation

Formations	Encountered Depth TVD (ft.) Depth MP (ft.) isolated? Remarks

YATES

Yes

3019.0

Yes



SAN ANDRES - HIGH FLOWS, H2S,

Yes

4465.0

Yes



CORROSIVE









GLORIETA

Yes

6316.0

Yes



CLEARFORK - ACTIVE C02 FLOOD

Yes

6492.0

Yes



WICHITA

Yes

8628.0

Yes



UPPER WOLFCAMP

Yes

9239.0

Yes



STRAWN

Yes

10030.0

Yes



ATOKA

Yes

10230.0

Yes



WOODFORD

Yes

10973.0

Yes



DEVONIAN

Yes

11036.0

No

DISPOSAL

WRISTEN

Yes

11268.0

No

DISPOSAL

FUSSELMAN

Yes

11538.0

No

DISPOSAL

MONTOYA

Yes

11974.0

No

DISPOSAL

RED BED-SANTA ROSA

No



No

NOT IN AREA

LEONARD

No



No

NOT IN AREA

WOLFCAMP

No



No

NOT IN AREA

PENNSYLVANIAN

No



No

NOT IN AREA

STRAWN

No



No

NOT IN AREA

MISSISSIPPIAN

No



No

NOT IN AREA

Do the producing interval of this well produce H2S with a concentration in excess of 100 ppm (SWR 36)?	No

s the completion being downhole commingled (SWR 10)?	No

REMARKS

NEW WELL PUTTING ON SCHEDULE.

Page 3 of4


-------
OPERATOR'S CERTIFICATION

Printed Name: Karen Zornes

Title:

Telephone No.: (281) 872-9300

Date Certified: 06/25/2019

Page 4 of4


-------
APPENDIX C - GAS COMPOSITION


-------
C-1

1 rv » n,,

natural Gas Analysis

www.permianls.com
575.397.3713 2609 W Marland HobbS NM 88240

11093G

30/30 Acid Gas

Sample Point Code

Sample Point Name

C6+ Gas Analysis Report

30/30 Acid Gas

Sample Point Location

Laboratory Services

Date Sampled

2021048523

1781

E Benavides - Spot

Source Laboratory



Lab File No

Container Identity

Sampler

USA

USA



USA

Texas

District

Area Name



Field Name

Facility Name

Nov 16, 2021



Nov 16, 2021

Nov 19, 2021 09:59

Nov 19, 2021

Date Effective

System Administrator

Ambient Temp (°F)

Flow Rate (Mcf)

Analyst

Date Received

21 @ 129

Press PSI @ Temp °F
Source Conditions

Date Reported

Stakeholder Midstream

30/30

Operator

Lab Source Description

Component

Normalized
Mol %

Un-Normalized
Mol %

GPM

H2S (H2S)

9.2000

9.2



Nitrogen (N2)

0.0000

0



C02 (C02)

89.6780

98.775



Methane (CI)

0.3030

0.331



Ethane (C2)

0.0580

0.063

0.0150

Propane (C3)

0.1080

0.118

0.0300

I-Butane (IC4)

0.0000

0

0.0000

N-Butane (NC4)

0.0250

0.027

0.0080

I-Pentane (IC5)

0.0000

0

0.0000

N-Pentane (NC5)

0.0000

0

0.0000

Hexanes Plus (C6+)

0.6280

0.686

0.2710

TOTAL

100.0000

109.2000

0.3240

Method(s): Gas C6+ - GPA 2261, Extended Gas - GPA 2286, Calculations - GPA 2172

Analyzer Information
Device Type: Gas Chromatograph Device Make: Shimadzu
Device Model: GC-2014	Last Cal Date: Nov 14, 2021

Gross Heating Values (Real, BTU/ft3)

14.696 PSI @ 60.00 A°F	14.65 PSI @ 60.00 A°F

Dry	Saturated	Dry	Saturated

98.7	98.00	98.4	97.7

Calculated Total Sample Properties

GPA2145-16 Calculated at Contract Conditions
Relative Density Real	Relative Density Ideal

1.5042	1.4956

Molecular Weight

43.3157

C6 - 60.000%

C6+ Group Properties

Assumed Composition

C7 - 30.000%

C8 - 10.000%

Field H2S

92000 PPM

PROTREND STATUS:	DATA SOURCE:

Passed By Validator on Nov 21, 2021 Imported

PASSED BY VALIDATOR REASON:

Close enough to be considered reasonable.

VALIDATOR:

Dustin Armstrong

VALIDATOR COMMENTS:

OK

Nov 22, 2021 7:57 a

Powered By ProTrend -www.criticalcontrol.com

Page 1 of 1


-------
APPENDIX D - MONITORING AREA MAPS

APPENDIX D-l: MMA MAP
APPENDIX D-2: AMA MAP


-------
A-1143

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& Stabilized Plume
with

1/2-Mile Maximum Monitoring Area (MMA)

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN • HOUSTON jfc CALGARY • WICHITA
DENVER • COLLEGE STATION T BATON ROUGE • EDMONTON

Rattlesnake AGI No. 1 SHL

I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

1560


-------
A-1143

A-1866
A-572

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& 19-Year Plume
with

1/2-Mile Active Monitoring Area (AMA)

Stakeholder Midstream
Yoakum Co., TX

A-545

A-1314

A-549

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN • HOUSTON jfc CALGARY • WICHITA
DENVER • COLLEGE STATION T BATON ROUGE • EDMONTON

+ Rattlesnake AGI No. 1 SHL

1 Active Monitoring Area Boundary

1 9-Year Plume

J Plume Boundary at End of Injection

1560


-------
APPENDIX E - FACILITY SAFETY PLOT PLANS


-------
PLANT NORTH

LEGEND

•

FIRE EXTINGUISHER

~

SCBA/ESCAPE PACK

~

WIND SOCK

®

LEL/H2S MONITOR



ESD BUTTON

H

STROBE LIGHTS



HORN

E-1



	r

i| 1 | |—1 l\ 71 1 k 1 A 1 \ W—1 / \ 1 1









—\

JKI 1 IMINAKY 1 ()l>











	pn/ic\A/	







0

NO.

05/11 / 22
DATE

INITIAL RELEASE K C V 1 C V V
REVISION DESCRIPTION

KLD
BY

BEC
FCE

JB
CLIENT

CHAR1S ENGINEERING. LLC
"IX ENG. FIRM NO. F-1B8B4
MIDLAND. IX

STAKEHOLDER
MIDSTREAM

CLIENT ;

PROJECT ;

TITLE :

STAKEHOLDER MIDSTREAM

30-30 GAS PLANT

SAFETY EQUIPMENT PLOT PLAN

1" = 50'—0"

DATE

5/11/22

ME—PLNP—AOOO—0004

A


-------
APPENDIX F - MMA/AMA REVIEW MAPS

APPENDIX F-l: PLUME BOUNDARY AT END OF INJECTION, STABILIZED PLUME BOUNDARY AND MAXIMUM
MONITORING AREA MAP

APPENDIX F-2: ACTIVE MONITORING AREA MAP

APPENDIX F-3: OIL AND GAS WELLS WITHIN THE MMA MAP

APPENDIX F-4: OIL AND GAS WELLS WITHIN THE MMA LIST

APPENDIX F-5: INJECTION INTERVAL PENETRATING WELLS WITHIN THE MMA MAP

APPENDIX F-6: GROUNDWATER WELLS WITHIN THE MMA

APPENDIX F-7: WELLBORE SCHEMATICS FOR INJECTION INTERVAL PENETRATING WELLS


-------
A-1143

A-545

A-1866
A-572

A-£ 58

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& Stabilized Plume
with

1/2-Mile Maximum Monitoring Area (MMA)

Stakeholder Midstream
Yoakum Co., TX

A-1314

A-549

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY

1



ENGINEERS

ADVISORS



AUSTIN • HOUSTON jj

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

Rattlesnake AGI No. 1 SHL

I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

J Plume Boundary at End of Injection

1560


-------
A-1143

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& 19-Year Plume
with

1/2-Mile Active Monitoring Area (AMA)

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY

1



ENGINEERS

ADVISORS



AUSTIN • HOUSTON jj

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

F-2

Rattlesnake AGI No. 1 SHL

1 Active Monitoring Area Boundary

1 9-Year Plume

J Plume Boundary at End of Injection

Abstract

Note: All coordinates shown are in NAD83 (DD).

MAP EXTENT

~


-------
A-1866



A-1314

iiiiiiiiij

36998 l\

RATTLESNAKE AGI NO

33.0513499,1

-102.90450576

00000

32541

00261

32531

00000

iiiiiiiiii

00000"

00000

00262

000

\ 00645 •

00050

00643s

00644

00000

33349.

33530

00057

33173

32702

34984\

32065

00059

33172

33531

A-1484

33531'

32703

33351

32064

,00061

00000

00060

00058

32704

33 no 3

00065

00068

00064

^067 ^

32945

32975

32077

32075

: 30600

32076

36156

00267

00266

00066 3271 i

00063

02992

02991

02990

02989 35820

A-1816

34878

32070

36155

36151 30604 35791 30602

30606

JO fyy

36152

35821

30630

32072

36153

30601

30605

35794

35793 30598

36150

30603

36048

36154

35180

35703

35701

35705

30000

=3058.4;

32270

33065

1:34099;

00755

30583

30629

35961'

34797

56428 00000

• °l

36098

-34023 •

00768J

34124

30580

36327

33843

LONQUIST & CO LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN • HOUSTON jfc CALGARY • WICHITA
DENVER • COLLEGE STATION T BATON ROUGE • EDMONTON

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

+ Rattlesnake AC I No. 1 SHL
| ~ ~ ™ 1/2-Mile Buffer from Max. Plume Extent (MMA)
I ~ Z Z Z Combined Maximum Plume Extent
1	Stabilized Plume

I ~ ~ ~ Z Plume Boundary at End of Injection
Abstract

	Lateral (21)

API (42-501-...) SHL Status - Type (Count)
O Horizontal Surface Location (21)

•	Active - Oil (93)

Active - Injection/Disposal (21)

•» Active - Injection/Disposal from Oil (22)
X Plugged - Oil (69)

^ Plugged - Gas (1)

Plugged- Injection/Disposal from Oil (1)

Shut-In - Oil (1)

TA - Injection/Disposal (3)

TA - Injection/Disposal from Oil (7)

"0" Dry Hole (6)
o Permitted Location (2)
0 Canceled/Abandoned Location (6)
X Expired Permit (7)

API (42-501-...) BHL Status - Type (Count)

•	Active - Oil (11)

•A Active - Injection/Disposal from Oil (1)

Shut-In - Oil (1)

TA - Injection/Disposal from Oil (1)

o Permitted Location (4)

X Expired Permit (3)

Sou rce:

1.)	Oil/Cas Well SHL Data: DI-2022

2.)	Oil/Cas Well BHL Data: DI-2022

3.)	Oil/Cas Well Directional Data: DI-2022

* Note: All coordinates shown are in NAD83 (DD). *

Rattlesnake AGI No. 1
Maximum Monitoring Area
with

1/2-Mile MMA Oil/Gas Well
Area of Review

Stakeholder Midstream
Yoakum Co., TX

1

A-1531

A-1064

A-87

A-1483

A-1641

A-499

VI55 !

i .-1777

A


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

F-4

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250101829

DENVER UNIT

2215W

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5300

5300

2215W

4250101835

DENVER UNIT

2207

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5185

5185

2207

4250130914

DENVER UNIT

2222

OCCIDENTAL PERMIAN LTD.

Active - Oil





2222

4250101832

DENVER UNIT

2201W

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5190

5190

2201W

4250101826

DENVER UNIT

2203

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5250

5250

2203

4250101319

ROBERTS UNIT

4532W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5200

5200

4532W

4250130629

ROBERTS UNIT

4535

APACHE CORPORATION

Active - Oil

5280

5280

4535

4250130583

ROBERTS UNIT

4525

APACHE CORPORATION

Active - Oil

5286

5286

4525

4250101318

ROBERTS UNIT

4541

APACHE CORPORATION

TA - Injection/Disposal from Oil

5240

5240

4541

4250101889

ROBERTS UNIT

3614

APACHE CORPORATION

Plugged - Oil

5180

5180

3614

4250130598

Roberts Unit

3647

APACHE CORPORATION

Plugged - Oil

5281

5281

3647

4250130603

ROBERTS UNIT

3626

APACHE CORPORATION

Plugged - Oil

5289

5289

3626

4250102992

ROBERTS UNIT

3612W

APACHE CORPORATION

Plugged - Oil

5226

5226

3612W

4250100066

ROBERTS UNIT

3532

APACHE CORPORATION

Plugged - Oil

5231

5231

3532

4250101886

ROBERTS UNIT

3631

APACHE CORPORATION

Plugged - Oil





3631

4250101885

ROBERTS UNIT

3641

APACHE CORPORATION

Plugged - Oil

5212

5212

3641

4250100068

ROBERTS UNIT

3521

APACHE CORPORATION

Plugged - Oil

5225

5225

3521

4250100064

ROBERTS UNIT

3541

APACHE CORPORATION

Plugged - Oil

5264

5264

3541

4250102014

ROBERTS UNIT

2443

APACHE CORPORATION

Plugged - Oil

5226

5226

2443

4250100050

ROBERTS UNIT

1654

APACHE CORPORATION

Plugged - Oil

5198

5198

1654

4250133531

ROBERTS UNIT

2443A



Active - Injection/Disposal

5325

5325

2443A

4250133502

ROBERTS UNIT

2527A



Plugged - Oil

5308

5308

2527A

4250100000

C. A. ELLIOTT

6

AMERICAN LIBERTY OIL CO

Plugged - Oil

5229

5229

6

4250100000

C. A. ELLIOTT

7

AMERICAN LIBERTY AND ATLANTIC

Active - Oil

5182

5182

7

4250100000

GEO CLEVELAND

1

DELFERN OIL CO

Dry Hole

5071

5071

1

4250100000

JAMES H. LYNN

1614

AMERICAN LIBERTY

Active - Oil

5169

5169

1614

4250100000

J. H. LYNN

1634

AMERICAN LIBERTY

Active - Oil

5160

5160

1634

4250100000

A. T. MORRIS

1

ATLANTIC

Active - Oil

5235

5235

1

4250100000

A. T. MORRIS

2

AMERICAN LIBERTY OIL CO

Plugged - Oil

5179

5179

2

4250100000

W.J. CARPENTER

1642

AMERICAN LIBERTY OIL COMPANY

Plugged - Oil

5183

5183

1642

4250100000

E.S.SMITH

1

CREAT WESTERN FROD

Dry Hole

5216

5216

1

4250130607

ROBERTS UNIT

3546



Active - Oil





3546

4250135958

DENVER UNIT

2247

OCCIDENTAL PERMIAN LTD.

Active - Oil

2333

2333

2247

4250131542

DENVER UNIT

2229

SHELL OIL COMPANY

Dry Hole

2409

2409

2229

4250101320

ROBERTS UNIT

4543

APACHE CORPORATION

Active - Injection/Disposal from Oil

5120

5120

4543

4250137301

MILLER

8H

AMTEX ENERGY, INC.

Active - Oil

5157

5157

8H

4250137304

MILLER 732 C

10H

AMTEX ENERGY, INC.

Permitted Location

5157

5157

10H

4250137305

MILLER 732 D

11H

AMTEX ENERGY, INC.

Permitted Location

5157

5157

11H

4250101888

ROBERTS UNIT

3634W

APACHE CORPORATION

Plugged - Oil

5160

5160

3634W


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250101031

ROBERTS UNIT

3534W

APACHE CORPORATION

Plugged - Oil

5164

5164

3534W

4250101828

DENVER UNIT

2208

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5170

5170

2208

4250101032

ROBERTS UNIT

3544

APACHE CORPORATION

Plugged - Oil

5170

5170

3544

4250101841

DENVER UNIT

2206

OCCIDENTAL PERMIAN LTD.

TA - Injection/Disposal from Oil

5177

5177

2206

4250101842

ROBERTS UNIT

3643W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5180

5180

3643W

4250101035

ROBERTS UNIT

3533W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5180

5180

3533W

4250132704

ROBERTS UNIT

2615

APACHE CORPORATION

Active - Oil

5180

5180

2615

4250100261

ROBERTS UNIT

1643W

APACHE CORPORATION

Plugged - Oil

5180

5180

1643W

4250101323

ROBERTS UNIT

4542W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5182

5182

4542W

4250102989

ROBERTS UNIT

3642W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5182

5182

3642W

4250102991

ROBERTS UNIT

3622W

APACHE CORPORATION

Plugged - Oil

5185

5185

3622W

4250132417

MILLER

3

AMTEX ENERGY, INC.

Active - Oil

5186

5186

3

4250101025

ROBERTS UNIT

2613W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5188

5188

2613W

4250101887

ROBERTS UNIT

3644

APACHE CORPORATION

Active - Injection/Disposal from Oil

5189

5189

3644

4250101830

DENVER UNIT

2214WC

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5190

5190

2214WC

4250101103

ROBERTS UNIT

3621

APACHE CORPORATION

Plugged - Oil

5190

5190

3621

4250101024

ROBERTS UNIT

2623

APACHE CORPORATION

Plugged - Oil

5190

5190

2623

4250101023

ROBERTS UNIT

2622W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5190

5190

2622W

4250101022

ROBERTS UNIT

2632

APACHE CORPORATION

Active - Oil

5190

5190

2632

4250101019

ROBERTS UNIT

2621

APACHE CORPORATION

Active - Oil

5190

5190

2621

4250101030

ROBERTS UNIT

3524W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5193

5193

3524W

4250101829

DENVER UNIT

2205

OCCIDENTAL PERMIAN LTD.

TA - Injection/Disposal from Oil

5195

5195

2205

4250101836

DENVER UNIT

2213WC

OCCIDENTAL PERMIAN LTD.

TA - Injection/Disposal from Oil

5200

5200

2213WC

4250101833

DENVER UNIT

2202WC

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5200

5200

2202WC

4250134099

DENVER UNIT

2239WC

OCCIDENTAL PERMIAN LTD.

Dry Hole

5200

5200

2239WC

4250132717

ROBERTS UNIT

3531A

APACHE CORPORATION

TA - Injection/Disposal

5200

5200

3531A

4250101014

ROBERTS UNIT

2624W

APACHE CORPORATION

Plugged - Oil

5200

5200

2624W

4250101028

ROBERTS UNIT

3523

APACHE CORPORATION

Plugged - Oil

5205

5205

3523

4250101102

ROBERTS UNIT

3611

APACHE CORPORATION

Plugged - Oil

5206

5206

3611

4250101827

DENVER UNIT

2209W

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5210

5210

2209W

4250101015



2643

TEXACO INCORPORATED

Active - Injection/Disposal from Oil

5210

5210

2643

4250100266

ROBERTS UNIT

3522W

APACHE CORPORATION

Plugged - Oil

5211

5211

3522W

4250132632

MILLER

5

AMTEX ENERGY, INC.

Active - Oil

5213

5213

5

4250100057

ROBERTS UNIT

2512W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5213

5213

2512W

4250101890

ROBERTS UNIT

3624W

APACHE CORPORATION

Plugged - Oil

5214

5214

3624W

4250101033

ROBERTS UNIT

3543W

APACHE CORPORATION

Plugged - Oil

5215

5215

3543W

4250101012

ROBERTS UNIT

2634W

APACHE CORPORATION

Plugged- Injection/Disposal from Oil

5215

5215

2634W

4250101734

ROBERTS UNIT

2442

APACHE CORPORATION

Plugged - Oil

5215

5215

2442

4250101020

ROBERTS UNIT

2611W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5215

5215

2611W


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250100067

ROBERTS UNIT

3531

APACHE CORPORATION

Plugged - Oil

5216

5216

3531

4250101013

ROBERTS UNIT

2614W

APACHE CORPORATION

Plugged - Oil

5216

5216

2614W

4250101844

ROBERTS UNIT

3623W

APACHE CORPORATION

Plugged - Oil

5217

5217

3623W

4250131869

ROBERTS UNIT

A3534W

APACHE CORPORATION

Plugged - Oil

5220

5220

A3534W

4250102990

ROBERTS UNIT

3632W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5220

5220

3632W

4250100262

ROBERTS UNIT

1644W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5220

5220

1644W

4250132858

DENVER UNIT

2235

OCCIDENTAL PERMIAN LTD.

Shut-In - Oil

5225

5225

2235

4250100058

ROBERTS UNIT

2544W

APACHE CORPORATION

Plugged - Oil

5225

5225

2544W

4250130584

ROBERTS UNIT

4520

APACHE CORPORATION

Active - Oil

5230

5230

4520

4250130630

ROBERTS UNIT

3535

APACHE CORPORATION

Active - Oil

5230

5230

3535

4250100063

ROBERTS UNIT

3542W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5230

5230

3542W

4250132076

ROBERTS UNIT

3627

APACHE CORPORATION

Active - Oil

5230

5230

3627

4250100267

ROBERTS UNIT

3512W

APACHE CORPORATION

Plugged - Oil

5233

5233

3512W

4250101016

ROBERTS UNIT

2642W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5234

5234

2642W

4250134716

DENVER UNIT

2242

OCCIDENTAL PERMIAN LTD.

Active - Oil

5236

5236

2242

4250100061

ROBERTS UNIT

2524W

APACHE CORPORATION

Plugged - Oil

5238

5238

2524W

4250101021

ROBERTS UNIT

2633

APACHE CORPORATION

Plugged - Oil

5240

5240

2633

4250101011

ROBERTS UNIT

2644W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5241

5241

2644W

4250132541

FUTCH

1

AMTEX ENERGY, INC.

Active - Oil

5244

5244

1

4250101026

ROBERTS UNIT

2612W

APACHE CORPORATION

Plugged - Oil

5245

5245

2612W

4250100059

ROBERTS UNIT

2513W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5246

5246

2513W

4250132531

MILLER

4

AMTEX ENERGY, INC.

Plugged - Oil

5248

5248

4

4250132687

ROBERTS UNIT

2635

APACHE CORPORATION

Plugged - Oil

5248

5248

2635

4250131656

DENVER UNIT

2232WC

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5250

5250

2232WC

4250131791

DENVER UNIT

2231

SHELL OIL COMPANY

Canceled/Abandoned Location

5250

5250

2231

4250134118

DENVER UNIT

2238

OCCIDENTAL PERMIAN LTD.

Active - Oil

5250

5250

2238

4250101342

ROBERTS UNIT



APACHE CORPORATION

Plugged - Gas

5250

5250



4250132269

ROBERTS UNIT

3601

APACHE CORPORATION

Plugged - Oil

5250

5250

3601

4250101843

ROBERTS UNIT

3633W

APACHE CORPORATION

Plugged - Oil

5250

5250

3633W

4250130608

ROBERTS UNIT

3545

APACHE CORPORATION

Active - Oil

5250

5250

3545

4250132077

ROBERTS UNIT

3617

APACHE CORPORATION

Active - Oil

5250

5250

3617

4250134963

DENVER UNIT

2244WC

OCCIDENTAL PERMIAN LTD.

TA- Injection/Disposal

5251

5251

2244WC

4250100060

ROBERTS UNIT

2514

APACHE CORPORATION

Plugged - Oil

5251

5251

2514

4250101459

DENVER UNIT

2211

OCCIDENTAL PERMIAN LTD.

Active - Oil

5252

5252

2211

4250132521

DENVER UNIT

2233W

OCCIDENTAL PERMIAN LTD.

TA- Injection/Disposal from Oil

5253

5253

2233W

4250135211

DENVER UNIT

2241

OCCIDENTAL PERMIAN LTD.

Active - Oil

5253

5253

2241

4250101837

DENVER UNIT

2212W

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5255

5255

2212W

4250132793

MILLER

6

AMTEX ENERGY, INC.

Active - Oil

5258

5258

6

4250132356

MILLER

1

AMTEX ENERGY, INC.

Active - Oil

5260

5260

1


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250101017

ROBERTS UNIT

2641

APACHE CORPORATION

Active - Oil

5260

5260

2641

4250101825

DENVER UNIT

2204W

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5264

5264

2204W

4250132416

MILLER

2

AMTEX ENERGY, INC.

Active - Oil

5269

5269

2

4250100065

ROBERTS UNIT

3511W

APACHE CORPORATION

Plugged - Oil

5270

5270

3511W

4250101018

ROBERTS UNIT

2631

APACHE CORPORATION

Active - Oil

5270

5270

2631

4250130600

ROBERTS UNIT

3645

APACHE CORPORATION

Active - Oil

5273

5273

3645

4250130580

ROBERTS UNIT

4536

APACHE CORPORATION

Active - Oil

5279

5279

4536

4250130599

ROBERTS UNIT

3646

APACHE CORPORATION

Active - Oil

5279

5279

3646

4250130602

ROBERTS UNIT

3635

APACHE CORPORATION

Active - Oil

5283

5283

3635

4250132997

DENVER UNIT

2208WC

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5284

5284

2208WC

4250130601

ROBERTS UNIT

3636

APACHE CORPORATION

Active - Oil

5286

5286

3636

4250132174

SHEPHERD

1

YOUNG, MARSHALL R., OIL CO.

Dry Hole

5286

5286

1

4250130604

ROBERTS UNIT

3625

APACHE CORPORATION

Active - Oil

5287

5287

3625

4250130912

DENVER UNIT

2224

OCCIDENTAL PERMIAN LTD.

Active - Oil

5288

5288

2224

4250130911

DENVER UNIT

2225

OCCIDENTAL PERMIAN LTD.

Active - Oil

5290

5290

2225

4250130609

ROBERTS UNIT

4530

APACHE CORPORATION

Active - Oil

5291

5291

4530

4250130605

ROBERTS UNIT

3616

APACHE CORPORATION

Plugged - Oil

5291

5291

3616

4250130606

ROBERTS UNIT

3615

APACHE CORPORATION

Active - Oil

5293

5293

3615

4250133172

ROBERTS UNIT

2523

CONOCOPHILLIPS COMPANY

Plugged - Oil

5295

5295

2523

4250132739

CLEVELAND

1

HIGHLAND PRODUCTION COMPANY

Plugged - Oil

5300

5300

1

4250133064

DENVER UNIT

2238

SHELL WESTERN E&P INC.

Canceled/Abandoned Location

5300

5300

2238

4250132927

DENVER UNIT

2236

OCCIDENTAL PERMIAN LTD.

Active - Oil

5300

5300

2236

4250133065

DENVER UNIT

2237

SHELL WESTERN E&P INC.

Expired Permit

5300

5300

2237

4250132270

ROBERTS UNIT

4540

APACHE CORPORATION

Active - Oil

5300

5300

4540

4250132414

ROBERTS UNIT

3523A

APACHE CORPORATION

Active - Injection/Disposal

5300

5300

3523A

4250132712

ROBERTS UNIT

3537

APACHE CORPORATION

Plugged - Oil

5300

5300

3537

4250132722

ROBERTS UNIT

3547

APACHE CORPORATION

Active - Oil

5300

5300

3547

4250132945

ROBERTS UNIT

3541A

TEXACO PRODUCING INC.

Expired Permit

5300

5300

3541A

4250132975

ROBERTS UNIT

3641A

TEXACO PRODUCING INC.

Expired Permit

5300

5300

3641A

4250132711

ROBERTS UNIT

3620

APACHE CORPORATION

Active - Oil

5300

5300

3620

4250133527

ROBERTS UNIT

2518

APACHE CORPORATION

Active - Oil

5300

5300

2518

4250132714

ROBERTS UNIT

2637

APACHE CORPORATION

Plugged - Oil

5300

5300

2637

4250133351

ROBERTS UNIT

2526

TEXACO PRODUCING INC.

Expired Permit

5300

5300

2526

4250132703

ROBERTS UNIT

2516

APACHE CORPORATION

Plugged - Oil

5300

5300

2516

4250133348

ROBERTS UNIT

2533

TEXACO PRODUCING INC.

Expired Permit

5300

5300

2533

4250132702

ROBERTS UNIT

2515

APACHE CORPORATION

Active - Oil

5300

5300

2515

4250133350

ROBERTS UNIT

2525

APACHE CORPORATION

Active - Oil

5300

5300

2525

4250133498

ROBERTS UNIT

2532

TEXACO PRODUCING INC.

Expired Permit

5300

5300

2532

4250133173

ROBERTS UNIT

2522

APACHE CORPORATION

Active - Oil

5300

5300

2522


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250133499

ROBERTS UNIT

2527

TEXACO PRODUCING INC.

Dry Hole

5300

5300

2527

4250133530

ROBERTS UNIT

2507

APACHE CORPORATION

Active - Oil

5300

5300

2507

4250132685

ROBERTS UNIT

2638

APACHE CORPORATION

Plugged - Oil

5302

5302

2638

4250133349

ROBERTS UNIT

2517

APACHE CORPORATION

Active - Oil

5302

5302

2517

4250132718

ROBERTS UNIT

3532A

APACHE CORPORATION

Active - Injection/Disposal

5304

5304

3532A

4250132713

ROBERTS UNIT

2625

APACHE CORPORATION

Active - Oil

5308

5308

2625

4250133502

ROBERTS UNIT

2527A

APACHE CORPORATION

Plugged - Oil

5308

5308

2527A

4250132716

ROBERTS UNIT

3526

APACHE CORPORATION

Active - Oil

5309

5309

3526

4250100645

ROBERTS UNIT

1624W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5309

5309

1624W

4250130913

DENVER UNIT

2223

OCCIDENTAL PERMIAN LTD.

Active - Oil

5310

5310

2223

4250132686

ROBERTS UNIT

2636

APACHE CORPORATION

Active - Oil

5310

5310

2636

4250101457

DENVER UNIT

2210

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5325

5325

2210

4250133529

ROBERTS UNIT

2508

APACHE CORPORATION

Plugged - Oil

5325

5325

2508

4250133531

ROBERTS UNIT

2443A

APACHE CORPORATION

Active - Injection/Disposal

5325

5325

2443A

4250133528

ROBERTS UNIT

2511

APACHE CORPORATION

Active - Oil

5325

5325

2511

4250135912

ROBERTS UNIT

3771W

APACHE CORPORATION

Active - Injection/Disposal

5330

5330

3771W

4250132075

ROBERTS UNIT

3637

APACHE CORPORATION

Active - Oil

5330

5330

3637

4250132063

ROBERTS UNIT

2705

APACHE CORPORATION

Active - Oil

5330

5330

2705

4250135793

ROBERTS UNIT

3672

APACHE CORPORATION

Active - Oil

5334

5334

3672

4250135819

ROBERTS UNIT

3674W

APACHE CORPORATION

Active - Injection/Disposal

5336

5336

3674W

4250135792

ROBERTS UNIT

3671

APACHE CORPORATION

Active - Oil

5339

5339

3671

4250135820

ROBERTS UNIT

3675W

APACHE CORPORATION

Active - Injection/Disposal

5341

5341

3675W

4250135818

ROBERTS UNIT

3633RW

APACHE CORPORATION

Active - Injection/Disposal

5344

5344

3633RW

4250135790

ROBERTS UNIT

3647R

APACHE CORPORATION

Active - Oil

5345

5345

3647R

4250100768

CORNELL UNIT

3107W

XTO ENERGY INC.

Active - Injection/Disposal from Oil

5350

5350

3107W

4250130915

DENVER UNIT

2221

OCCIDENTAL PERMIAN LTD.

Active - Oil

5350

5350

2221

4250136048

ROBERTS UNIT

3634RW

APACHE CORPORATION

Active - Injection/Disposal

5350

5350

3634RW

4250135908

ROBERTS UNIT

3678W

APACHE CORPORATION

Active - Injection/Disposal

5350

5350

3678W

4250132072

ROBERTS UNIT

3525

APACHE CORPORATION

Active - Oil

5350

5350

3525

4250135915

ROBERTS UNIT

3626R

APACHE CORPORATION

Active - Oil

5350

5350

3626R

4250132281

ROBERTS UNIT

2446

APACHE CORPORATION

Active - Oil

5350

5350

2446

4250132064

ROBERTS UNIT

2704

APACHE CORPORATION

Active - Oil

5350

5350

2704

4250132280

ROBERTS UNIT

2445

APACHE CORPORATION

Plugged - Oil

5350

5350

2445

4250135791

ROBERTS UNIT

3670

APACHE CORPORATION

Active - Oil

5351

5351

3670

4250135794

ROBERTS UNIT

3673

APACHE CORPORATION

Active - Oil

5352

5352

3673

4250135821

ROBERTS UNIT

3676W

APACHE CORPORATION

Active - Injection/Disposal

5352

5352

3676W

4250135914

ROBERTS UNIT

3681W

APACHE CORPORATION

Active - Injection/Disposal

5352

5352

3681W

4250100643

ROBERTS UNIT

1634W

APACHE CORPORATION

Plugged - Oil

5353

5353

1634W

4250135796

ROBERTS UNIT

3669

APACHE CORPORATION

Active - Oil

5356

5356

3669


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250100644

ROBERTS UNIT

1614

APACHE CORPORATION

Plugged - Oil

5356

5356

1614

4250135913

ROBERTS UNIT

3680W

APACHE CORPORATION

Active - Injection/Disposal

5357

5357

3680W

4250135705

ROBERTS UNIT

3752

APACHE CORPORATION

Active - Oil

5360

5360

3752

4250135822

ROBERTS UNIT

3677W

APACHE CORPORATION

Active - Injection/Disposal

5362

5362

3677W

4250134984

ROBERTS UNIT

2626W

APACHE CORPORATION

Active - Injection/Disposal

5364

5364

2626W

4250135701

ROBERTS UNIT

3667

APACHE CORPORATION

Active - Oil

5365

5365

3667

4250132070

ROBERTS UNIT

3536

APACHE CORPORATION

Active - Oil

5370

5370

3536

4250132065

ROBERTS UNIT

2703

APACHE CORPORATION

Active - Oil

5370

5370

2703

4250100755

CORNELL UNIT

3101W

XTO ENERGY INC.

Active - Injection/Disposal from Oil

5373

5373

3101W

4250135703

ROBERTS UNIT

3668

APACHE CORPORATION

Active - Oil

5380

5380

3668

4250135229

DENVER UNIT

2240

OCCIDENTAL PERMIAN LTD.

Active - Oil

5388

5388

2240

4250136152

ROBERTS UNIT

3682W

APACHE CORPORATION

Active - Injection/Disposal

5397

5397

3682W

4250131539

DENVER UNIT

2230

SHELL OIL COMPANY

Canceled/Abandoned Location

5400

5400

2230

4250136327

ROBERTS UNIT

4547

APACHE CORPORATION

Active - Oil

5400

5400

4547

4250136154

ROBERTS UNIT

3624RW

APACHE CORPORATION

Active - Injection/Disposal

5400

5400

3624RW

4250136155

ROBERTS UNIT

3683W

APACHE CORPORATION

Active - Injection/Disposal

5402

5402

3683W

4250136156

ROBERTS UNIT

3686

APACHE CORPORATION

Active - Oil

5404

5404

3686

4250134797

CORNELL UNIT

3194

XTO ENERGY INC.

Active - Oil

5405

5405

3194

4250135696

CORNELL UNIT

113

XTO ENERGY INC.

Active - Oil

5406

5406

113

4250136150

ROBERTS UNIT

3684

APACHE CORPORATION

Active - Oil

5421

5421

3684

4250133629

CORNELL UNIT

3156

XTO ENERGY INC.

Active - Oil

5425

5425

3156

4250135961

DENVER UNIT

2246

OCCIDENTAL PERMIAN LTD.

Active - Oil

5425

5425

2246

4250135960

DENVER UNIT

2249

OCCIDENTAL PERMIAN LTD.

Active - Oil

5431

5431

2249

4250136153

ROBERTS UNIT

3623RW

APACHE CORPORATION

Active - Injection/Disposal

5439

5439

3623RW

4250135353

CORNELL UNIT

107

XTO ENERGY INC.

Active - Oil

5450

5450

107

4250135528

ROBERTS UNIT

3549

APACHE CORPORATION

Active - Oil

5452

5452

3549

4250136151

ROBERTS UNIT

3685

APACHE CORPORATION

Active - Oil

5463

5463

3685

4250135963

DENVER UNIT

2252

OCCIDENTAL PERMIAN LTD.

Active - Oil

5476

5476

2252

4250136434

ROBERTS UNIT

263H

APACHE CORPORATION

Expired Permit

5500

5500

263H

4250136433

ROBERTS UNIT

262H

APACHE CORPORATION

Expired Permit

5500

5500

262H

4250136098

CORNELL UNIT

110

XTO ENERGY INC.

Active - Injection/Disposal

5510

5510

110

4250133615

ROBERTS UNIT

2442A

APACHE CORPORATION

TA - Injection/Disposal

5516

5516

2442A

4250135180

ROBERTS UNIT

3534B

APACHE CORPORATION

Active - Injection/Disposal

5517

5517

3534B

4250136428

CORNELL UNIT

124

XTO ENERGY INC.

Active - Oil

5532

5532

124

4250134878

ROBERTS UNIT

3548

APACHE CORPORATION

Active - Oil

5550

5550

3548

4250135966

DENVER UNIT

2251

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2251

4250135962

DENVER UNIT

2250

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2250

4250135356

DENVER UNIT

2246

OCCIDENTAL PERMIAN LTD.

Expired Permit

5600

5600

2246

4250135959

DENVER UNIT

2248

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2248


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250135210

DENVER UNIT

2240

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2240

4250135211



2241

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2241

4250134710



2240

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2240

4250101845

ROBERTS UNIT

3613

APACHE CORPORATION

Active - Oil

7000

7000

3613

4250110083

RANDALL, E.

36

EXXON CORP.

Plugged - Oil

8595

8595

36

4250110046

ELLIOTT, C.A.

2

MCCLURE OIL COMPANY, INC.

Plugged - Oil

9000

9000

2

4250136692

MISS KITTY 704-669

3XH

RILEY EXPLORATION OPG CO, LLC

Expired Permit

9000

9000

3XH

4250133793

RANDALL, E.

39

XTO ENERGY INC.

Active - Oil

9000

9000

39

4250137375

RIP WHEELER 705-668

5XH

RILEY PERMIAN OPERATING CO, LLC

Permitted Location

9000

9000

5XH

4250137358

RIP WHEELER 705-668

1XH

RILEY PERMIAN OPERATING CO, LLC

Permitted Location

9000

9000

1XH

4250133843

ELLIOTT

1

DELTA C02, LLC

Plugged - Oil

9050

9050

1

4250134124

RANDALL, E

46

EXXON CORP.

Canceled/Abandoned Location

9100

9100

46

4250133792

RANDALL, E.

40

XTO ENERGY INC.

Plugged - Oil

9591

9591

40

4250110079

RANDALL, E.

32

EXXON CORP.

Plugged - Oil

9615

9615

32

4250135418

RANDALL, E.

46

XTO ENERGY INC.

Active - Oil

9650

9650

46

4250134023

RANDALL, E.

42

XTO ENERGY INC.

Active - Oil

9660

9660

42

4250134016

RANDALL, E.

43

XTO ENERGY INC.

Active - Oil

9740

9740

43

4250132388

RANDALL, E.

38

EXXON CORP.

Canceled/Abandoned Location

10300

10300

38

4250137302

MILLER 732 B

9H

AMTEX ENERGY, INC.

Active - Oil

5183

10662

9H

4250136432

ROBERTS UNIT

261 H

APACHE CORPORATION

Active - Oil

5151

11117

261 H

4250136998

RATTLESNAKE AGI

1

SANTA FE MIDSTREAM PERMIAN LLC

Active - Injection/Disposal

11980

11980

1

4250137252

MILLER SWD

7

AMTEX ENERGY, INC.

Permitted Location

13000

13000

7

4250136984

MADCAP 731-706

1XH

RILEY PERMIAN OPERATING CO, LLC

Active - Oil

5261

13274

1XH

4250137127

MISS KITTY A 669-704

25XH

RILEY PERMIAN OPERATING CO, LLC

Active - Oil

5321

13428

25XH

4250137287

MISS KITTY A 669-704

4XH

RILEY PERMIAN OPERATING CO, LLC

Shut-In - Oil

5340

13452

4XH

4250137236

MISS KITTY 669-704

2XH

RILEY PERMIAN OPERATING CO, LLC

Active - Oil

5317

13622

2XH


-------
A-1143

Rattlesnake AGI No. 1
Maximum Monitoring Area
with

1/2-Mile MMA Oil/Gas Well Penetrators
Area of Review

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 6/1/2022

Approved by: RH

LONQUIST & CO. LLC



PETROLEUM

ENERGY





ENGINEERS

ADVISORS

1

AUSTIN • HOUSTON jj

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

F-5

+ Rattlesnake AGI No. 1 SHL

I	'

I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

Stabilized Plume

J Plume Boundary at End of Injection

Abstract

API (42-501-...) SHL Status - Type (Count)

• Active - Oil (4)

Active - Injection/Disposal (1)

Plugged - Oil (4)

® Permitted Location (1)

Sou rce:

1.)	Oil/Gas Well SHL Data: DI-2022

2.)	Oil/Gas Well BHL Data: DI-2022

3.)	Oil/Gas Well Directional Data: DI-2022

* Note: All coordinates shown are in NAD83 (DD).

1560


-------
A-1143

Rattlesnake AGI No. 1
Maximum Monitoring Area
with

1/2-Mile MMA Groundwater Well
Area of Review

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY

F-6



ENGINEERS

ADVISORS

| AUSTIN • HOUSTON J

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

+ Rattlesnake AGI No. 1 SHL

|	I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

Stabilized Plume

J Plume Boundary at End of Injection

Abstract

SDRDB Groundwater Wells [TWDB-2022]

Proposed Use (Labeled with Well Report No.)
A Industrial (1)

Irrigation (5)

TWDB Groundwater Wells [TWDB-2022]

Well Type (Labeled with State Well No.)
¦ Withdrawal of Water (1)

Sou rce:

1.)	SDRDB Groundwater Well SHL Data: TWDB-2022

2.)	TWDB Groundwater Well SHL Data: TWDB-2022

3.)	Brackish Groundwater Well SHL Data: TWDB-2022
* Note: All coordinates shown are in NAD83 (DD). *

1560


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Cement Plug #9
@7'-1,013'

Cement Plug #8
@ 1,730'- 1,800'

Cement Plug #7
@ 2,031' - 2,100

Cement Plug #6
@2,430'-2,500'

Cement Plug #5
@2,660'-2,719'

Cement Plug #4
@2,790'-2,860'

Cement Plug #3
@3,172'-3,239'

Cement Plug #2
@3,765'-3,831'

Cement Plug #1
@ 3,900'-3,960'

Perfs @ 8,231
8,396', 8,420'
8,447', 8,462'

Casing Information

Label

1

2

Type

Surface

Production

OD

8-5/8"

4-1/2"

Depth Set

2,134'

9,601'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-10079

RRC District No: 8-A

Drawn: KAS

E. Randall No. 32

State/Province: Texas

Spud Date: 05/10/1965

Field: Wasson (Wichita Albany)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 18231

Date: 05/31/2022

Approved: SLP


-------
Cement Plug #5
@ 0' - 458'

Cement Plug #4
@2,070'-2,295'

Cement Plug #3
@2,780'- 3,009'

Cement Plug #2
@4,450'-4,870'

Cement Plug #1
@5,184'-5,266'

Perfs@ 9,496'-9,516'

TD@ 9,591'
PBTD @ 9,560'



DV Tool ® 4,522'

DV Tool @ 5,676'

Casing Information

Label

1

3

Type

Surface

Production

OD

9-5/8"

5-1/2"

Weight

36 lb/ft

UNK

Depth Set

2,162'

9,569'

Hole Size

12-1/4"

7-7/8"

TOC

Surface

2,350'

Volume

880 sks

5,450 sks

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

XTO Energy Inc.

Country: USA

Location: Section 833, Block D

API No: 42-501-337932

RRC District No: 8-A

Drawn: KAS

E. Randall No. 40

State/Province: Texas

Spud Date: 12/04/1992

Field: Wasson (Wichita Albany)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—





A

Perfs (5) 9,536' - 9,540'

SI

[S

: . I





DV Tool @ 5,968'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54 lb/ft

36 lb/ft
40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,129'

5,606'

9,699'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

Surface

Volume

1,790 sks

2,910 sks

1,590 sks

2-3/8" Tubing & Packer Set @ 9,331'

TD @ 9,700'
PBTD @ 9,654'

MD

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN • HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 832, Block D

API No: 42-501-33885

RRC District No: 8-A

Drawn: KAS

E. Randall No. 41L

State/Province: Texas

Spud Date: 02/05/1994

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Perfs (5) 9,533' - 9,553'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,167'

5,830'

9,658'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

440'

1,800'

Volume

1,530 sks

3,500 sks

1,050 sks

DV Tool ® 7,414'

2-3/8" Tubing & Packer Set @ 8,970'

TD @ 9,660' \-(3)
PBTD @ 9,623' W

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-34023

RRC District No: 8-A

Drawn: KAS

E. Randall No. 42L

State/Province: Texas

Spud Date: 07/01/1995

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—



Li;.

Perfs @ 9,550' - 9,538'
9,603'-9,610'

sf.

.... «¦
*'¦ •-

4/?

¦A ¦







" B ¦'





" ¦ /





?







, 4' i

,

"4

t" '

'*¦ ?r









. v.







> .¦







"A



' 'i



;



¦ 'v



„ .: '



4* •"

/











CIBP ® 8,917'

CIBP @ 9,590'

TD @ 9,740'
PBTD @ 8,917'

rv@

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,166'

5,902'

9,735'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

2,000'

Volume

1,530 sks

3,505 sks

967 sks

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 832, Block D

API No: 42-501-34016

RRC District No: 8-A

Drawn: KAS

E. Randall No. 43L

State/Province: Texas

Spud Date: 04/08/1995

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Perfs @ 8,762' - 8,782'

(Sqz w/100 sx)

Perfs @8,822'-8,831'

(Sqz w/ 75 sx)

Perfs @ 9,562' - 9,570'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft
29 lb/ft

Depth Set

2,158'

5,904'

9,620'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

1,600'

Volume

1,450 sks

5,190 sks

1,100 sks

DV Tool ® 7,482'

2-3/8" Tubing & Packer Set @ 9,552'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-34024

RRC District No: 8-A

Drawn: KAS

E. Randall No. 44

State/Province: Texas

Spud Date: 08/09/1995

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Perfs (5) 9,565' - 9,575'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,175'

5,898'

9,615'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

1,500'

Volume

1,530 sks

3,525 sks

1,170 sks

DV Tool ® 7,508'

2-3/8" Tubing Set @ 9,580'

Packer Set (5) 9,394'

TD @ 9,684'

PBTD @ 9,593'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-34017

RRC District No: 8-A

Drawn: KAS

E. Randall No. 45L

State/Province: Texas

Spud Date: 02/05/1994

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
Perfs (5) 9,504' - 9,512'

TD @ 9,650'
PBTD @ 9,594'

Casing/Tubing
Information

Label

1

2

Type

Surface

Production

OD

8-5/8"

5-1/2"

Weight

24 lb/ft

17 lb/ft

Depth Set

2,120'

9,650'

Hole Size

11"

7-7/8"

TOC

Surface

Surface

Volume

900 sks

3,400 sks

DV Tool ® 8,656' & 8,674'

2-7/8" Tubing & Packer Set @ 9,184'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

XTO Energy, Inc.

Country: USA

Location: Section 833, Block D

API No: 42-501-35418

RRC District No: 8-A

Drawn: KAS

E. Randall No. 46

State/Province: Texas

Spud Date: 05/23/2007

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
u

Cement Plug #4
@48'-60'

Cement Plug #3
@ 270' - 450'

Cement Plug #1
@7,549'-8,000'

Perfs @ 8,292' - 8,428'

Cement Plug #2
@3,273'-3,439'

Top of Cut @ 750'
Top of Cut @ 1,439'

TD ® 9,645'

v@

Casing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

5-1/2"

Depth Set

300'

3,200'

9,610'

TOC

Surface

Surface

Surface

Volume

400 sks

300 sks

425 sks

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Bonanza Oil Corp.

Country: USA

Location: Section 832, Block D

API No: 42-501-10046

RRC District No: 8-A

Drawn: KAS

C.A. Elliott No. 2

State/Province: Texas

Spud Date: 05/10/1965

Field: Wasson (Wichita Albany)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 18875

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

w

if.

II

: .



Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

48 lb/ft

40 lb/ft

26 lb/ft
28 lb/ft

Depth Set

500'

5,500'

10,695'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

Surface

Volume

350 sks

1,705 sks

1,635 sks

3-1/2" Tubing & Packer Set @ 10,650'

MD

TD @ 13,000'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Amtex Energy, Inc.

Country: USA

Location: Section 732, Block D

API No: 42-501-37252

RRC District No: 7-C

Drawn: KAS

Miller SWD No. 7 (Permitted)

State/Province: Texas

Spud Date: 08/09/1995

Field: Wasson

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

Permit Number: 16637

Date: 05/31/2022

Approved: SLP


-------
Request for Additional Information: 30-30 Gas Plant
August 31, 2022

Instructions: Please enter responses into this table and make corresponding revisions to the MRV Plan as necessary. Any long responses, references,
or supplemental information may be attached to the end of the table as an appendix. This table may be uploaded to the Electronic Greenhouse Gas
Reporting Tool (e-GGRT) in addition to any MRV Plan resubmissions.

No.

MRV Plan

EPA Questions

Responses

Section

Page

1

4

42

•	Leakage from surface equipment

•	Leakage through existing wells within MMA

•	Leakage through faults and fractures

•	Natural or induced seismicity

•	Drilling through the MMA

•	Leakage through the confining layer

Is this bullet list intended to represent the upcoming subsections within
section 3 of the MRV plan? If so, EPA recommends that 30-30 revise so
that this list matches the sub-section headings. There are some slight
differences between the two.

List and Subsection headings synchronized (pg 42-51)

2

5

54

"This section discusses the strategy that Stakeholder will employ for
detecting and quantifying surface leakage of C02 through the
pathways..."

40 CFR 98.448(a)(3) requires that the MRV plan contain "A strategy for
detecting and quantifying any surface leakage of C02." While the above
sentence references quantification, the subsequent section does not
appear to identify quantification strategies for the identified leakage
pathways. In the MRV plan, please ensure that you have provided a
strategy for quantifying surface leakage of C02.

Added paragraph "Pressures and flowrates through the surface
equipment are continuously monitored during operations. If a
release occurred from surface equipment, the amount of C02
released would be quantified based on the operating conditions
at the time, including pressure, flow rate, size of the leak point
opening, and duration of the leak." (pg 55)


-------
No.

MRV
Section

Plan
Page

EPA Questions

Responses

3

6

57

"H2S will be initially injected into the AGI well at a concentration of
approximately ten (10) percent or 100,000 ppm. The concentration will
drop to approximately six (6) percent as additional volumes are added."

Page 33 states that, "...It is expected that a larger portion of the gas
added is carbon dioxide, changing the composition to "93% C02 and

~7% H2S."

These statements potentially conflict with each other. Please clarify.

Concentration of BBS corrected to "seven (7) percent" (pg 57)





54



List and Subsection headings synchronized (pg 54-56)

5


-------
STAKEHOLDER

I!MIDSTREAM

Subpart RR Monitoring, Reporting, and
Verification (MRV) Plan
Rattlesnake AGI #1

Yoakum County, Texas

Prepared for Stakeholder Gas Services, LLC
San Antonio, TX

By

Lonquist Sequestration, LLC
Austin, TX

Version 2
August 2022

LONQUIST

SEQUESTRATION LLC

Hi


-------
INTRODUCTION

Stakeholder Gas Services, LLC ("Stakeholder") currently has a Class II acid gas injection ("AGI") permit, issued
by the Texas Railroad Commission ("TRRC") in November 2018, for the Rattlesnake AGI #1 well, API No. 42-
501-36998. This permit was originally issued to Santa Fe Midstream Permian, LLC, in 2018 and the asset was
subsequently acquired by Stakeholder in December of 2020. This permit currently authorizes Stakeholder to
inject up to 4,500 barrels per day ("bbls/d") of treated acid gas ("TAG") into the Devonian formation at a
depth of 11,000' to 12,000' with a maximum allowable surface pressure of 2,200 psi. Since being permitted,
injection has proceeded without incident. This AGI well is associated with Stakeholder's 30-30 gas treating
and processing plant ("30-30") located in a rural, sparsely populated area of Yoakum County, Texas,
approximately seven miles northwest of the town of Plains, as shown in Figure 1.

I t

H-



Ula

homa















STAKEHOLDER
MIDSTREAM



Mexlip

TT
:

1

t

L

Y



I











H

iti































l^vas

J L















riV





r\ fV















WES

T OIL F

IELD

















































Yoakum

ink Bas.n



















Rattlesnake
AGI(RS#1)



























¦





























WASSON OIL

FIELD



° *





9
"S













W























i
|















Four Mi



	 | 1

Ji|—k s ¦/- 1 i
§



YbAKUM





GAINrS

^ Gaines







0 0.5 1 2 Miles

GEOROi

ALLEN

OIL

FIELD

# Stakeholder AGI Well

Figure 1 - Location of Rattlesnake AGI #3 Well

1


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Stakeholder is submitting this Monitoring, Reporting, and Verification ("MRV") plan to the EPA for approval
under 40 CFR §98.440(a), Subpart RR, of the Greenhouse Gas Reporting Program ("GHGRP"). In addition to
submitting this MRV plan to the EPA, Stakeholder is also applying to the TRRC for an amendment to the
Rattlesnake AGI #1 well's Class II permit to increase its authorized injection volume and maximum allowable
surface injection pressure ("MASIP"). Approval of the permit amendment will allow Stakeholder to increase
the capacity of its existing 30-30 Facility, which removes H2S and C02 from natural gas production using amine
treating, as well as increase the injection well capacity for a future gas processing facility which is currently
under development by Stakeholder. Additionally, expanded capacity allows Stakeholder to potentially
provide future disposal in its AGI well for oil and gas waste derived TAG from similar third-party gas processing
facilities. Increased disposal capacity will allow for greater gas processing capacity in the region, ultimately
helping to reduce flaring and its associated emissions. Throughout this document, both in written reference
and in modeling inputs, Stakeholder has used the applied-for expanded permit capacity of 16 million standard
cubic feet per day ("MMSCF/d"). Stakeholder plans to inject C02 for approximately 14 more years.

2


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ACRONYMS AND ABBREVIATIONS

%

°c

°F

AMA

BCF

CH4

CMG

C02

E

EOS

EPA

ESD

FG

ft

GAU

GEM

GHGs

GHGRP

H2S

md

mi

MIT

MM

MMA

MCF

MMCF

MMSCF

Feet

Percent(Percentage)

Degrees Celsius
Degrees Fahrenheit
Active Monitoring Area
Billion Cubic Feet
Methane

Computer Modelling Group

Carbon Dioxide (may also refer to other Carbon Oxides)
East

Equation of State

U.S. Environmental Protection Agency
Emergency Shutdown
Fracture Gradient
Foot (Feet)

Groundwater Advisory Unit

Computer Modelling Group's GEM 2020.11

Greenhouse Gases

Greenhouse Gas Reporting Program

Hydrogen Sulfide

Millidarcy(ies)

Mile(s)

Mechanical Integrity Test
Million

Maximum Monitoring Area
Thousand Cubic Feet
Million Cubic Feet
Million Standard Cubic Feet


-------
MSCF/D	Thousand Cubic Feet per Day

MMSCF/d	Million Standard Cubic Feet per Day

MRV	Monitoring, Reporting and Verification

v	Poisson's Ratio

N	North

NW	Northwest

OBG	Overburden Gradient

PG	Pore Gradient

pH	Scale of Acidity

ppm	Parts per Million

psi	Pounds per Square Inch

psig	Pounds per Square Inch Gauge

S	South

SE	Southeast

SF	Safety Factor

SWD	Saltwater Disposal

TAC	Texas Administrative Code

TAG	Treated Acid Gas

TOC	Total Organic Carbon

TRRC	Texas Railroad Commission

UIC	Underground Injection Control

USDW	Underground Source of Drinking Water

W	West

4


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TABLE OF CONTENTS

INTRODUCTION	1

ACRONYMS AND ABBREVIATIONS	3

SECTION 1 - FACILITY INFORMATION	8

Reporter number	8

Underground Injection Control (UIC) Class II Permit	8

UIC Well Identification Number	8

SECTION 2- PROJECT DESCRIPTION	9

Regional Geology	10

Regional Faulting	15

Site Characterization	15

Stratigraphy and Lithologic Characteristics	15

Upper Confining Interval - Woodford Shale	16

Injection Interval - Fasken Formation	17

Lower Confining Zone - Fusselman Formation	21

Local Structure	21

Injection and Confinement Summary	26

Groundwater Hydrology	26

Description of the Injection Process	31

Current Operations	31

Planned Operations	32

Reservoir Characterization Modeling	32

Simulation Modeling	35

SECTION 3 - DELI NATION OF MONITORING AREA	39

Maximum Monitoring Area	39

Active Monitoring Area	40

SECTION 4 - POTENTIAL PATHWAYS FOR LEAKAGE	42

Leakage from Surface Equipment	42

Leakage from Wells in the Monitoring Area	44

Oil and Gas Operations within Monitoring Area	44

Groundwater wells	48

Leakage Through Faults or Fractures	50

Leakage Through Confining Layers	51

Leakage from Natural or Induced Seismicity	51

SECTION 5 - MONITORING FOR LEAKAGE	54

Leakage from Surface Equipment	54

Leakage from Existing and Future Wells within Monitoring Area	55

Leakage through Faults, Fractures or Confining Seals	56

Leakage through Natural or Induced Seismicity	56

SECTION 6 - BASELINE DETERMINATIONS	57

Visual Inspections	57

H2S Detection	57

C02 Detection	57

Operational Data	57

Continuous Monitoring	57

Groundwater Monitoring	58

SECTION 7 - SITE SPECIFIC CONSIDERATIONS FOR MASS BALANCE EQUATION	59

5


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Mass of C02 Received	59

Mass of C02 Injected	59

Mass of C02 Produced	61

Mass of C02 Emitted by Surface Leakage	61

Mass of C02 Sequestered	61

SECTION 8- IMPLEMENTATION SCHEDULE FOR MRV PLAN	63

SECTION 9 - QUALITY ASSURANCE	64

Monitoring QA/QC	64

Missing Data	64

MRV Plan Revisions	65

SECTION 10- RECORDS RETENTION	66

References	67

APPENDICES	68

LIST OF FIGURES

Figure 1 - Location of Rattlesnake AGI #1 well	1

Figure 2 - Illustrative overview of Rattlesnake AGI #1 and 30-30 Facility	9

Figure 3 - Regional Map of the Permian Basin	10

Figure 4 - Stratigraphic column of the Northwest Shelf	11

Figure 5 - Stratigraphic column depicting the composition of the Silurian group	12

Figure 6 - Thickness map of the Silurian system which composes the Fusselman and Wristen group	14

Figure 7 - Type Log (42-501-10238) with tops, confining and injection zones depicted	15

Figure 8 - Core description of the Woodford Shale and Upper Silurian (Ruppel and Holtz, 1994)	16

Figure 9 - Table of reservoir properties found within the Wristen buildups and platform plays	18

Figure 10 - Rattlesnake AGI #1 open hole log (42-501-36998)	19

Figure 11 - Offset wells used for Formation Fluid Characterization	20

Figure 12 - Silurian Structure Map (subsea depths)	23

Figure 13 - Structural Northeast-Southwest Cross Section	24

Figure 14 - Structural Northwest-Southeast Cross Section	25

Figure 15 - Northwest-Southeast Cross Section of aquifers in the Rattlesnake AGI #1 well area 	27

Figure 16 - Potentiometric surfaces from wells completed in A Ogallala aquifer, B the Edwards-Trinity aquifer

and Cthe Dockum aquifer	28

Figure 17 - Regional extent of the Dockum freshwater aquifer (TWDB)	29

Figure 18 -Total dissolved solids in groundwater from the Dockum Aquifer	29

Figure 19-Regional extent of the Edwards-Trinity freshwater aquifer	30

Figure 20 - Regional extent of the Ogallala freshwater aquifer 	31

Figure 21 - 30-30 Facility Process Flow Diagram	32

Figure 22 - Permeability Distribution of Karst Limestone	34

Figure 23 - Areal View Gas Saturation Plume, 2036 (End of Injection)	37

Figure 24 - Areal View Gas Saturation Plume, 2779 (End of Density Drift)	38

Figure 25 - Well Injection Rate and Bottomhole Pressure over Time	38

Figure 26 - Plume Boundary at End of Injection, Stabilized Plume, and Maximum Monitoring Area	40

Figure 27 - Active Monitoring Area	41

Figure 28 - Site Plan, 30-30 Facility	43

Figure 29 - Rattlesnake AGI #1 Wellbore Schematic	45

Figure 30 - Oil and Gas Wells within the MMA	46

6


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Figure 31 - Penetrating Oil and Gas Wells within the MMA	47

Figure 32 - Groundwater Wells within MMA	49

Figure 33 - Seismicity Review (TexNet - 06/01/2022)	52

Figure 34 - Probabilistic Fault Slip Potential Analysis with Rattlesnake AGI #1 location	53

LIST OF TABLES

Table 1 - Analysis of Silurian-Devonian age formation fluids from nearby oil-field brine samples	20

Table 2 - Fracture Gradient Assumptions	21

Table 3 - Geologic and hydrogeologic units with accompanying lithologic descriptions near Gaines, Terry and

Yoakum Counties, Texas	26

Table 4 - Gas Composition of 30-30 Facility outlet	31

Table 5 - Modeled Initial Gas Composition	33

Table 6 - CMG Model Layer Properties	34

Table 7 - All Offset SWDs included in the model	36

Table 8 - All Offset Producers included in the model	36

Table 9 - Groundwater Well Summary	50

Table 10 - Summary of Leakage Monitoring Methods	54

7


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SECTION 1 - FACILITY INFORMATION

This section contains key information regarding the Acid Gas and C02 injection facility.

Reporter number:

•	Gas Plant Facility Name: 30-30 Gas Plant

•	Greenhouse Gas Reporting Program ID: 574501

o Currently reporting under Subpart UU

•	Operator: Stakeholder Gas Services, LLC

Underground Injection Control (UIC) Permit Class: Class II

The TRRC regulates oil and gas activities in Texas and has primacy to implement the Underground Injection
Control ("UIC") Class II program. TRRC classifies the Rattlesnake AGI #1 well as a UIC Class II well. A Class II
permit was issued to Stakeholder under TRRC Rule 9 (entitled "Disposal into Non-Productive Formations")
and Rule 36 (entitled "Oil, Gas, or Geothermal Resource Operation in Hydrogen Sulfide Areas").

UIC Well Identification Number:

Rattlesnake AGI #1, API No. 42-501-36998, UIC #000117143.

8


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SECTION 2 - PROJECT DESCRIPTION

This Project Description discusses the geologic setting, planned injection volumes and process, and the
reservoir modeling performed for the Rattlesnake AGI #1 well. The Class II UIC permit was initially applied
for and received by Santa Fe Midstream Permian, LLC. The asset was acquired in 2020 by Stakeholder and
has been in operation since that time. Since the original application, Lonquist has revised and updated the
geology and the plume modeling within the reservoir in preparing this MRV Plan.

The Rattlesnake AGI #1 well is located and designed to protect against migration of C02 out of the injection
interval and to prevent surface releases. The injection interval for Rattlesnake AGI #1 is located over 4,720'
below the primary producing formation, the San Andres, in the area and 8,593' below the base of the lowest
useable quality water table, as shown in Figure 2. This well injects both H2S and C02, therefore the well and
the facility are designed to minimize any leakage to the surface.

STAKEHOLDER
TREATING & PROCESSING
PLANT

2,450'

LOWEST
WATER TABLE
DEPTH

5,500'

CASING DEPTH

Casing consists of
reinforced steel
and concrete

11,000'

INJECTION WELL
DEPTH

>8,500'

BELOW THE
WATER TABLE

Figure 2 - Illustrative overview of Rattlesnake AGI tt1 and 30-30 Facility

9


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Regional Geology

The Rattlesnake AGI #1 well is located on the southern portion of the Northwestern Shelf within the larger
Permian Basin as seen in Figure 3. The Northwestern Shelf is a broad marine shelf located in the northern
portion of the Permian Basin,

Basin

Matador Arch

Eastern
Shelf

f..	NEW MEXICO

Jtexas |
Delaware'^
Basin \

Ozona
, Arch

>Val Verde
' Basin

.Ouach/h
NJ

NEW
MEXICO

		WO ml

100 Km

I I Permian Basin

Figure 3 - Regional Map of the Permian Basin. Red Star is approximate location of Rattlesnake AGI #1 well

Figure 4 depicts the stratigraphic column found at the Rattlesnake AGI #1 well location with red stars
referencing the injection formation and green stars indicating the productive intervals in the area. The
primary injection interval is found within the Wristen group, of Silurian-age, as seen in Figure 5. The TRRC
refers to this sequence under the general terms "Devonian", "Silurian-Devonian" or "Siluro-Devonian".

10


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Period

Epoch

Formation

General Lithology

Permian

Ochoan

Dewey Lake

Redbeds/Anhydrite

Rustler

Halite

Salado

Halite/Anhydrite

Guadalupian

Tansil

Anhydrite/Dolomite

Yates

Anhydrite/Dolomite

Seven Rivers

Dolomite/Anhydrite

Queen

Sandy Dolomite/Anhydrite/Sandstone

Grayburg

Dolomite/Anhydrite/Shale/Sandstone

Leonardian

~ San Andres

Dolomite/Anhydrite

Glorieta

Sandy Dolomite

Yeso

Paddock

Dolomite/Anhydrite/Sandstone

Blinebry

Tubb

Drinkard

Abo

Dolomite/Anhydrite/Shale

Wolfcampian

^ Wolfcamp

Limestone/Dolomite

Pennsylvanian

Virgilian

Cisco

Limestone/Dolomite

Missourian

Canyon

Limestone/Shale

Des Moinesian

Strawn

Limestone/Sandstone

Atokan

Bend

Limestone/Sandstone/Shale

Morrowan

Morrow

Mississippian



Mississippian Lime

Limestone

Devonian



Woodford

Shale

Silurian



-^Wristen Group

Dolomite/Limestone



^ Fusselman

Dolomite/Chert

Ordovician

Upper

Montoya

Dolomite/Chert

Middle

Simspson Gp

Limestone/Sandstone/Shale

Lower

Ellenburger

Dolomite

Figure 4 - Stratigraphic column of the North west Shelf. Red stars indicate injection interval. Green stars indicate productive

intervals.


-------
Mississippian

Chesterian

undivided

Meramecian

Osagian



Kinderhookian

Devonian

Upper

Woodford Shale



Middle

Lower

Thirtyone Fm.

Silurian

Pridolian

Wristen Gp.

~

Fasken
Fm.

Frame Fm.

Ludlovian

Wink Fm.

Wenlockian

Llandoverian



Fusselman Fm.

Ordovician

Upper

Montoya Fm.

Simpson Gp.

Middle

Lower

Ellenburger Fm.

Figure 5 - Stratigraphic column depicting the composition of the Silurian group. Red star indicates injection interval (Broadhead,

2005)

The Wristeri group was deposited in a basin platform setting across the northern half of the Permian Basin.
The depositional environment over Yoakum County during the Silurian period was a shallow inner platform,
the margin of which exists to the south, in southern Andrews County, Texas. The Silurian-age lithology on
the inner platform is dominated by grain-rich skeletal carbonates. Carbonate buildups are common within
the shallow inner platform, mainly skeletal wackestone, indicating a lower-energy deposition on the inner
platform. The carbonate shelf margin to the south acted as a barrier from basin-ward wave energy (Ruppel
and Holtz, 1994).

Depositional cycles within the inner platform indicate it was controlled by episodic sea level rise and fail,
resulting in sub-areal exposure and diagenesis. The diagenesis of the Silurian-age carbonate rocks initiated

12


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secondary porosity development and increased permeability. Dolomite and solution-related features are the
most prominent diagenetic characteristics found within the Silurian. The Wristen Group is composed of three
formations: Fasken, Frame, and Wink formations. The Frame and Wink formations are found near the ramp
boundary to the south, while the Fasken formation is found predominantly in the inner platform, where the
Rattlesnake AGI #1 well is located. The Fasken formation is predominately dolomite grading to limestone,
occurring as cycles, down section. This dolomitization is due in part to sub-areal exposure, during which
karsts and secondary porosity developed. Additional dolomitization was possible during successive sea level
fluctuations via movement of magnesium-rich solution through karsts and vugs, which acted as channels for
fluid flow (Ruppel and Holtz, 1994).

Figure 6 shows a regional isopach map of the Silurian (combined Fasken and Fusselman formations) with a
red star depicting the Rattlesnake AGI #1 well location. Thickness of the Silurian-age rock is approximately
1,000' at the Rattlesnake AGI #1 well location.

North of Andrews County there is little differentiation between the Fasken and Fusselman formations which
are both carbonate deposits with the potential for sub-areal exposure and porosity development. For
purposes of this MRV Plan, the combined Fasken and Fusselman formations are defined as the injection
interval, and the underlying Montoya formation serves as the lower confining unit.

13


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ThjChMSJ (ft)

W'Uin plait ttf iM'tm

M«l$COC« |4?t«U«IS

wiOtAI

4.0*1*4

Ttm

S kM>M

c«o«rTT

Figure 6- Thickness map of the Silurian system which composes the Fusselman and Wristen group

14


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Regional Faulting

A major uplift that began during the Pennsylvanian Period to the south, the Central Basin Platform, ceased
in the Early Permian (Wolfcampian), which caused a regional unconformity of the underlying formations
(Hoak, Sundberg, and Ortoleva). Faulting on the Northwest Shelf can be seen through high angle basement
faults that tend to die within the Pennsylvanian strata. These faults predominately represent contractional
(thrust) faults that were initiated during the Pennsylvanian as a result of regional tectonics. Hydrocarbon
traps within the Wristen group are primarily anticlinal structures dependent upon reservoir development
(Broadhead, 2005).

Site Characterization

The Rattlesnake AGI #1 well is located in Section 733, Block D, John H. Gibson Survey, in Yoakum County,
Texas. Stakeholder owns the 82.42-acre surface tract where the plant and Rattlesnake AGI #1 well are
located. The following discusses the geological character of this site.

Stratigraphy and Lithologic Characteristics

Figure 7 depicts an open hole log from an offset well (API No. 42-501-10238) to the Rattlesnake AGI #1 well
indicating the injection and primary upper confining zone. This well is approximately 1.8 miles to the
northwest of the Rattlesnake AGI #1 well, An offset well log was used to depict the upper confining intervals
as electric logs were only run in the Rattlesnake AGI #1 well across the injection zone.

15


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Upper Confining Interval - Woodford Shale

The Woodford is a late Devonian-age organic-rich shale deposited as a result of a widespread marine
transgression. The flooding event occurred over the majority of the Permian basin, which produced a low-
relief blanket-like shale deposit of the Woodford. Two major lithofacies found within the Woodford are black
shale and siltstone. Nutrient-rich surface waters promoted the decay of abundant organic matter within the
Woodford, resulting in a high total organic carbon ("TOC") percentage. The Woodford shale acts as the
primary source and sealant rock for the Wristen Group (Comer, 1991).

Figure 8 is a description of a core sample taken in Lea County, New Mexico just southwest of the Rattlesnake
AGI #1 well location. This sample is referenced as C9 in the reference map with the blue star representing
the Rattlesnake AGI #1 well. In the core description, black shale with abundant illitic clays is observed in the
upper section, and medium gray dolomitic siltstone found in the basal section. The mineralogic and lithologic
properties recorded in this description serve as excellent sealant characteristics to prohibit any injected fluids
from migrating above the injection interval.

The Woodford at the Rattlesnake AGI #1 well location is encountered at 10,973 ft and is approximately 63 ft
thick.

C9

Shell No. 5 Pacific Royalty
Lea County, New Mexico
Section 10.T15S-R37E
		Elevation 3814 ft

X

Q

TOC

Weight
percent

1 2 3 4 5
—I	I	I	I	L_

GR i

C9 5

cs s

C9 7

Description

(ft)

35+
-12.200

Medium* to dark-gray limestone Lime mudstone with a few thin beds of brachiopod
wackestone and skeletal and pellet grainstone Some intervals highly fractured; all
fractures are filled, some with calcite, some with silica. Lowor contact not
preserved, probably conformable.	

Green limestone. Clay rich. Lower contact not preserved, probably disconformablo.

Black shale. Parallel laminae Abundant fllitic clay; pyritic. Scattered grains of sift*
sized quartz, dolomite, and mica. Spores scattered or concentrated in thin laminae,
some spores replaced by pyrite, some by carbonate; sparse laminao of Radiolana;
rare burrows filled by chert, carbonate, and anhydrite Scarce veinlets filled with
calcite. Lower contact not preserved, probably conformable and abruptly gradatiorial.

I

| Boii»y	

•Cochron

JRqCtMT

Medium-gray dolomitic siltstone. Abundant silt-sized anhedral and subnedral dolomite;
s»lt-sized quartz common Interbedded and interlaminated dark-gray shate and
medium-gray line-grained catcite grainstone, packs tone, and lime mudstone Wavy to
discontinuous bods near top; becomes more discontinuous, contorted, and mottled
downward; shales have parallel to wavy laminae. Pyritjc; micacoous. Sparse burrows;
rare Lmgula and wood fragments. Grades downward into lighter gray dolomitic
siltstone with fewer shale inter bods Lower contact not preserved, probably
disconfonrtablo.

Pale brownish pink crystalline dolostone. Vuggy.

^Medium-gray shale. Dolomitic; silty.

69+

Pale brownish-pink crystalline dolostone Vuggy.

»-12,400

l£	

| Y00hum

I

I

I ~

' Coirct

Figure 8- Core description of the Woodford Shale and Upper Silurian (Ruppel and Holtz, 1994)

16


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Injection Interval - Fasken Formation

The Rattlesnake AGI #1 well reaches total depth in the Fasken/Fusselman formation (Silurian in age), directly
below the Woodford formation. Dolomites at the top of the Fasken formation underwent multiple leaching
and diagenetic episodes which developed secondary porosity. This is evidenced in offset wells by the practice
of only drilling through the top 30' of the Fasken, in anticipation of encountering the best reservoir quality.
In Figure 8, the uppermost Silurian section is described as 'vuggy dolostone' in the core description. Beds
below the top of the Fasken section may also have similar petrophysical attributes if exposed to multiple
diagenetic events. Solution-collapse and karst breccia horizons can be found within inner platform deposits,
some occurring as much as 100 ft below the Fasken top (Ruppel and Holtz, 1994).

Porositv/Permeabilitv Development

Porosity in the Fasken formation at the Rattlesnake AGI #1 well location is typically moldic and intercrystalline
associated with leaching of allochem-rich intervals. Porosity is directly related to these leaching events which
occurred during and post-deposition, resulting in vugs and karst-like features. Figure 9 provides reservoir
information from core data within fields in the Wristen buildup and platform carbonate play. The average
porosity of these cores is 7.1% with an average permeability of 45.28 millidarcies (Ruppel and Holtz, 1994).
The porosity and permeability described in the offset core data indicate the Fasken formation provides
sufficient accessible pore space for the amount of fluid injection proposed.

Using the above values as reference points, the Rattlesnake AGI #1 porosity log (API No. 42-501-36998) was
evaluated. Figure 10 is the product of the petrophysical analysis performed on the open hole logs run within
the injection interval at the Rattlesnake AGI #1 well. A permeability curve was generated from the effective
porosity curve using the table in Figure 9 to establish the porosity-permeability relationship. In Figure 10,
the majority of the injection interval's porosity and permeability is found at the top of the Fasken formation,
which correlates with the diagenetic processes described above. These curves are extrapolated to the
injection site and used to establish reservoir characteristics in the plume model.

17


-------














Wristen







Fusselman

Buildups and

Thirtyone

Thirtyone



Shallow Platform

Platform

Ramp

Deep-Water



Carbonate play

Carbonate play

Carbonate play

Chert play



Porosity (%>





Numbe/ o' data points

33

30

16

35

Mean

7,93

7. to

e.4i

14,85

Mnimum

1.00

2.70

3.50

2.00

Maximum

17,70

14.00

0.50

30.00

Standard devation

4.01

2.67

1.75

6.76



Permeability (md)





dumber ot (Jala points

21

24

12

33

Mean

11.61

45.28

1.51

9.56

Minimum

0.60

2.90

0.40

1.00

Maximum

84.80

400.00

30.00

100.00

Standard deviation

22.48

99.17

8.36

22.23



Initial water saturation {%)





Number oi data points

24

28

10

31

Mean

26.96

31.55

24.70

31.46

Mmmnum

10.00

20.00

16.00

10.00

Maximum

50.00

55.00

40.00

45.00

Standard deviation

9.31

10.4b

7.39

8.33



Residua) oil saturation {%)





Number a', data points

8

13

5

22

Mean

34.06

30.54

21.30

29.17

Minimum

30.00

20.00

9.00

14.00

Maximum

50.00

35.00

35.00

48.20

Standard devation

6.99

4.61

11.66

9.76



Oil viscosity (op)





Number oi data points

11

12

5

21

Mean

0.69

1.10

0.33

0.68

Mrnmum

0.13

0.32

0.04

0.07

Maximum

1.08

2.00

1.00

1.03

Standard devation

0.81

0.75

0.40

0.42



Oil formation volume factor





Number oi data points

21

22

6

32

Mean

1.57

1.22

1.65

1.50

Mnirnum

1.05

1.05

1.31

1.30

Maximum

1.91

1.55

1.66

1.73

Standard deviation

0.28

0.14

0.48

0.16



Bubble-point pressure (psi)





Number of data points

9

9

5

19

Mean

2.272

1,055

3.750

2.752

Minimum

798

450

2.660

1.755

Maximum

4.C50

2,600

4,440

4.655

Standard devation

1.300

689

756

667











Figure 9 - Table of reservoir properties found within the Wristen buildups and platform plays (Ruppel and Holtz, 1994)


-------
Low Perm

42501369980000
RATTLESNAKE AG I
1

STAKEHOLDER GAS SERVICES

0

[PLJ]=11036.9

Figure 10- Rattlesnake AG I #1 open hole log (42-501-36998) with effective porosity (green) and permeability (black)

Formation Fluid

Four wells were identified through a review of chemical analyses of oil-field brines from the U.S. Geological
Survey National Produced Waters Geochemical Database v2.1 within the Devonian, Silurian-Devonian, or
Fusselman formations within 20 miles of the Rattlesnake AGI #1 well. The location of these wells is shown in
Figure 11. Water chemistry analyses conducted on oil-field brines in Gaines County, as reported to the Texas

19


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Water Development Board, provided additional data on Devonian and Silurian reservoir fluids. Results from
the synthesis of these two sources are provided in Table 1. The fluids have greater than 20,000 parts per
million ("ppm") total dissolved solids, therefore these aquifers are considered saline. These analyses indicate
the in-situ reservoir fluid of the Devonian, Silurian, and Fusselman formations are compatible with the
proposed injection fluids.

Figure 11 - Offset wells used for Formation Fluid Characterization

Table 1 - Analysis of Silurian-Devonian age formation fluids from nearby oil-field brine samples



Average

Low

High

Total Dissolved Solids (ppm)

41,428

23,100

55,953

pH

7,2

7.0

7.3

Sodium (ppm)

12,458

7,426

15,948

Calcium (ppm)

1,759

1,010

2,320

Chlorides (ppm)

23,423

12,810

31,930

Fracture Pressure Gradient

Fracture pressure gradient was estimated using Eaton's equation. Eaton's equation is commonly accepted
as the standard practice for the determination of fracture gradients. Poisson's ratio ("v"), overburden
gradient ("OBG"), and pore gradient ("PG") are all variables that can be changed to match the site-specific
injection zone. Through literature review and industry standards, we are able to determine the expected

20


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fracture gradient. First, 1.05 psi/ft and 0.465 psi/ft were assumed for both the overburden and pore
gradients, respectively. These values are considered best practice values when there are no site-specific
numbers available. For limestone/dolomite rock, the Poisson's ratio to be assumed to be 0.3 through
literature review (Molina, Vilarras, Zeidouni 2016). Using these values in the equation below, a fracture
gradient of 0.72 psi/ft was calculated. A 10% safety factor was then applied to this number resulting in
maximum allowed bottom hole pressure of 0.64 psi/ft. This was done to ensure that the injection pressure
would never exceed the fracture pressure of the injection zone.

For the upper confining interval, a similar fracture gradient as the limestone was calculated. Shale has an
increased chance to vertically fracture if the injection interval is fractured (Molina, Vilarras, Zeidouni 2016),
so assuming a Poisson's ratio equal to the injection interval was used as a conservative estimate. The lower
confining zone was assumed to be of a similar matrix to that of the injection interval, with the key difference
being that the formation is much tighter (lower porosity/permeability). The Poisson's ratio was assumed to
be slightly higher in this rock. As seen in Table 2, the fracture gradient is slightly higher than the upper zones.

Table 2 - Fracture Gradient Assumptions



Injection Interval

Upper Confining

Lower Confining

Overburden Gradient (psi/ft)

1.05

1.05

1.05

Pore Gradient (psi/ft)

0.465

0.465

0.465

Poisson's Ratio

0.30

0.30

0.31

Fracture Gradient psi/ft

0.72

0.72

0.73

FG +10% Safety Factor (psi/ft)

0.64

0.64

0.66

The following steps were taken to calculate fracture gradient:

FG = —-—(OBG - PG) + PG
1 — v

0.3

FG = 1_Q3(1-05 - °-465) + °-465 = °-72
FG with SF = 0.72 x (1 - 0.1) = 0.64

Lower Confining Zone - Montoya Formation

The low-permeability Montoya Formation is a tight limestone/dolomite that will act as the lower confining
unit for the injection interval. Figure 10 shows the decreasing trend in porosity of the limestone rock in the
lower section that was not exposed to leaching diagenesis. Porosity in the lower section can range from 2-
3% with permeabilities below 1 millidarcy. The Rattlesnake AGI #1 well drilled 6' into the Montoya formation,
but the section was not logged. The Montoya is anticipated to be roughly 250' thick. These petrophysical
characteristics represent ideal sealing properties to prohibit any migration of injected fluid outside of the
injection interval.

Local Structure

Regional structure in the area of the Rattlesnake AGI #1 well is dictated by carbonate buildups and structural
events causing anticlinal to synclinal features throughout the area. The Rattlesnake AGI #1 well is specifically
located at the base of a syncline with anticlinal features to the northeast, south, and east. Figure 12 is a

21


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structure map of the Silurian formation of subsea depths with the star representing the location of the
Rattlesnake AGI #1 well. The red and blue lines represent the cross-section reference lines.

Faulting can be seen to the south and east of the Rattlesnake AGI #1 well location. These faults were
interpreted from roughly 9 square miles of 3D seismic indicated by the purple outline in Figure 12. Many of
these faults are minor, with offsets less than 50'. The nearest large fault is found southeast of the Rattlesnake
AGI #1 well and has an offset of roughly 120'. None of these faults project above the Wolfcamp formation,
rather, they appear to terminate between the Strawn and base of the Wolfcamp formation. Production is
associated with a hydrocarbon trap set up by the larger fault to the southeast, indicating the fault is vertically
sealing in nature. If, in the unlikely event the faults' sealing properties are compromised post-injection,
secondary confinement is provided by the tight limestones found within the overlying Mississippian Lime
formation along with shale layers found in the Atoka and Wolfcamp formations. As seen in Figure 14, the
largest fault found southeast of the Rattlesnake AGI #1 well, terminates within the Atoka formation. Though
it crosses the Silurian section, this fault thrusts the Mississippian Lime upward against the Atoka shales. The
tight reservoir characteristics of the Mississippian Lime and shaley section of the Atoka create a confining
environment vertically and laterally to contain potential upward migration of buoyant fluids. Shales within
the Wolfcamp formation provide additional confining beds between overlying USDWs and the fault plane.
Figures 13 and 14 are north-south and west-east structural cross sections showing the structural dips. As
seen in these figures, the Woodford formation is laterally present above the injection interval, alleviating risk
of erosion of the upper sealant formation.

Larger versions of Figures 11, 12, 13 and 14 are provided in Appendix A.

22


-------

-------

-------
NW

3T?w'

42501105700000
1-667

TEXAS CRUDE OIL CO
+

<14,201 FT>

42501369980000
RATTLESNAKE AG I
1

STAKEHOLDER GAS SERVICES



42501358340000
ROBERTS UNIT
2

APACHE



42501335110000
CORNELL UNIT

3019D
EXXON MOBIL

SE

asr

MONTOYA [PUJ

25


-------
Injection and Confinement Summary

The lithologic and petrophysical characteristics of the Faskeri and Fusseiman formations at the Rattlesnake
AGI #1 well location indicate the formations have sufficient thickness, porosity, permeability, and lateral
continuity to accept the proposed injection fluids. The Woodford formation shale at the Rattlesnake AGI #1
well has low permeability and is of sufficient thickness and lateral continuity to serve as the upper confining
zone. Beneath the injection interval, the low permeability, low porosity Montoya formation is unsuitable for
fluid migration and serves as the lower confining zone. Deeper, laterally continuous formations, including the
Simpson Group, provide additional confinement.

Groundwater Hydrology

Yoakum County falls within the boundary of the Sandy Land Underground Water Conservation District. Three
aquifers are identified by the Texas Water Development Board's Aquifers of Texas report in the vicinity of the
proposed Rattlesnake AGI #1 well: the Dockum Aquifer, Edwards-Trinity Aquifer, and Ogallala Aquifer
(George, Mace and Petrossian, 2011). Table 3 references the aquifers' positions in geologic time and the
associated geologic formations. A schematic cross section in Figure 15, near the proposed Rattlesnake AGI
#1 well, illustrates the structure and stratigraphy of these water-bearing formations. Groundwater flow
direction is the same for the three aquifers, generally from northwest to southeast, Figure 16 (Teeple, et al.,
2021).

Table 3 - Geologic and hydrogeologic units with accompanying lithologic descriptions near Gaines, Terry and Yoakum Counties, Texas
(Teeple, et al. 2021)

Era

Period

Epoch or series

Geologic unit group
or formation

Lithologic descriptions

Hydrogeologic unit

Cenozoic

Tertiary

Pliocene

Ogallala Formation

Gravel, sand, silt,
and clay

High Plains
aquifer system
(Ogallala aquifer)

Miocene

Mesozoic

Cretaceous'

Comanchean
Series

Washita Group2

Shale and limestone

Edwards-T rinity
(High Plains)
aquifer system

Fredericksburg Group

Clay, shale, and
limestone

Trinity Group

Sand and gravel

Triassic

Upper

Dockum Group

Sillstone, mudstone,
shale, and sandstone

Dockum aquifer

26


-------
Figure 15- NW-SE Cross Section of aquifers in the Rattlesnake AG! #1 well area (George, Mac and Petrossian, 2011)

27


-------
IOCKLEV COI NTY 8 103°0'
/ •

HOC KLEV COl.Vn

"J	\^J! In* • •• •Hv4. •

V , " •. A " *

r I J ' *1 nnvaJ^Sil'

/ • • t / • 'I** *	i» 1

K.-.'- l\i^\\s>* I

lY\ 3| ~7	. 1

/ ' <8 jX • /• *> / ~**. i' >!

[ <. OTvKsl ,. • ,

icuiNfu" fr;—7

i	if _ \ »V*^r"

C 1Q3°D'	,K

rrir

33°20' I

I ~
L-'

Y0AKUM
»v \ | x COUNTY

©#xr /

/ fMiu \ ~'

y .<

l«s

f Mjch

\ / n*L"IMkt jif

v^'	(

ftpy ' ' v x liruu^lfcUi x

~ ' j

artr'

32"4G'

-HOCKLEY COUNTY

0	5 10 (SMILES

1	. 1 r i1	1

0 5 tO T5 KILOMETERS

Base modified tram U S Geological Survey 1 250 000-scale to 1 2,000.000-scale digital data.
Universal Transverse Mercator projection, ione 13
North American Datum of 15&3

Groundwater-level altitude, in
leal above North American
Vertical Oatum of 1988

|^m" >3,750

Hj- 3,500

3,250

3,000

<2,750

EXPLANATION

Study area boundary

Edwards-Trinity I High Plains} nquilor downdip enfant
Underground water conservation district boundary

Llano Estacado Underground Water Conservation District
Sandy Land Underground Water Conservation District
South Plains Underground Water Conservation District

Potenriometric contour Shows altitude at
which water level would have stood in
tightly cased wells. Contour interval is
100 feel Datum it North American
Vertical Datum of 1988 Dashed where
mlerred.

Groundwater How pallia Dashed where
interred

• Groundwater tevol measurement (Payne
and others. 2020)

Figure 16 - Potentiometric surfaces from wells completed in A, Ogallala aquifer, B, the Edwards-Trinity aquifer and C, the Dockum
aquifer (George, Mace and Petrossian, 2011).

The Dockum Aquifer is the oldest of the three aquifers, formed from Triassic-age Dockum Group sediments,
and underlies the Cretaceous Trinity and Fredericksburg Groups (Teeple, et al., 2021). Figure 17 shows the
subsurface and outcrop extent of the Dockum Aquifer. As shown in Figure 18, the total dissolved solids in
western Yoakum County exceed 5,000 milligrams per liter ("mg/L"), therefore the aquifer is considered
brackish.

28


-------
Dockum

Aquifer

Figure 17 - Regional extent of the Dockum freshwater aquifer (TWDBj

Figure 18 - Total dissolved solids in groundwater from the Dockum Aquifer (Ewing et at, 2008)

The Edwards-Trinity Aquifer is a collection of Cretaceous age sediments - primarily the Trinity Group Antlers
formation sandstone and limestones of the Fredericksburg Group, specifically the Comanche Peak and
Edwards formations. Figure 19 shows the subsurface and outcrop extent of the Edwards-Trinity Aquifer.
Freshwater infiltration to this aquifer is primarily from the overlying Ogallala Aquifer (George, Mace and
Petrossian, 2011).

29


-------
The Ogallala aquifer consists of sand, gravel, clay and silt sediments (George, Mace and Petrossian, 2011) and
produces the majority of the freshwater for Yoakum County. Figure 20 shows the subsurface and outcrop
extent of the Ogallala Aquifer.

The base of the deepest aquifer is separated from the injection interval by approximately 8,600' of rock,
including 576' of Salado salt. Though unlikely for reasons outlined in the confinement and potential leaks
sections, if migration of injected fluid did occur above the Woodford Shale, thousands of feet of tight
sandstone, limestone, shale, salt and anhydrite beds occur between the injection interval and the lowest
water-bearing aquifer.

30


-------
The TRRC's Groundwater Advisory Unit ("GAU") identified the base of Underground Sources of Drinking
Water ("USDW") at 375' at the location of the Rattlesnake AGI #1 well. Therefore, there is approximately
10,661' separating the base of the USDW and the injection interval. A copy of the GAU's Groundwater
Protection Determination letter issued by the TRRC as part of the Class II permitting process for the
Rattlesnake AGI #1 well is provided in Appendix B.

Description of the Injection Process
Current Operations

The 30-30 Facility and its associated Rattlesnake AGI #1 well began operating in March of 2019. Since
operations began, 258 million cubic feet ("MMCF") of treated acid gas ("TAG") has been injected, which
equates to 12,316 metric tons of C02. Over the life of the injection period, the average daily injection rate
has been 223 MSCF/d. The approximate current composition of the TAG stream is as follows;

Table 4 - Gas Composition of 30-30 Facility outlet

Component

Mol %

C02

89.68%

H2S

9.20%

Other

1.12%

31


-------
The 30-30 Facility is designed to compress, treat, and process natural gas produced from the surrounding
counties in Texas and New Mexico. The gas is dehydrated to remove the water content, then processed to
separate natural gas liquids which are then sold, along with the pipeline quality natural gas, to various
customers. TAG is then directly routed from the plant amine regen system to the Rattlesnake AGI #1 well.
The facility is manned 24 hours per day, 7 days per week.

Planned Operations

Stakeholder anticipates increasing the amount of CO2 injected into Rattlesnake AGI #1 well from the current
rate up to 16 MMSCF/d. Additional growth is expected both at Stakeholder facilities and regionally as rising
sour gas production and flaring reduction mandates create the need for additional CO2 and H2S disposal
capacity. Stakeholder plans to inject into this AGI well for another 14 years for a total of 17 years from the
start of injection in 2019.

Figure 21 shows a high-level view of the current process flow plus the prospective additional operations over
time.

Amine Regen
System

>96% C02
1,090-1,150 psig

CO, Offta ke

13% H2S, 87% COj
1,400-2,200 psig

AGI
Compression

Prospective Facilities

Meter

er XV

Meter

&

XV

A

l_
"l
I

-L

596-13% HjS, 87%-

95% C02
1,400-2,500 psig

Injection
Pumps

XV

Current Operation

AGI
Well

Figure 21 - 30-30 Facility Process Flow Diagram

Reservoir Characterization Modeling

The modeling software used to evaluate this project was Computer Modelling Group's GEM 2020.11 ("GEM")
simulator. Computer Modelling Group ("CMG") has put together one of the most accurate and technically
sound reservoir simulation software packages for conventional, unconventional, and secondary recovery.
GEM utilizes equation-of-state ("EOS") algorithms along with some of the most advanced computational
methods to evaluate compositional, chemical, and geochemical processes and characteristics to produce
highly accurate and reliable simulation models for carbon injection and storage. The GEM model is
recognized by the EPA for use in area of review delineation modeling as listed in the Class VI Well Area of
Review Evaluation and Corrective Action Guidance document.

The Silurian (Fasken/Fusselman) formation is the target formation for Rattlesnake AGI #1 well. The Petra
software package was used to create the geologic model of the target formation. The faulting and geologic
structure was then imported into GEM and used to create contours for the model grid.

Porosity and permeability estimates were determined using the porosity log from the Rattlesnake AGI #1
well and a petrophysical analysis was performed to correlate porosity values by depth with core porosities

32


-------
as shown in the Holtz paper. The Coates permeability equation was then used to calculate permeability with
depth. Both porosity and permeability are assumed to be laterally homogeneous in the reservoir.

The reservoir is assumed to be at hydrostatic equilibrium and initially saturated with 100% brine. An infinite
acting reservoir was created to simulate boundary conditions. The gas injectate is composed of H2S, CO2,
CH4, and other components as shown in Table 5. Core data from literature review was used to determine
residual gas saturation (Ruppel and Holtz, 1994). The modeled composition only takes into consideration the
carbon dioxide and hydrogen sulfide as they comprise nearly 99% of total stream. For the initial injection
period, these compositions are normalized up to 100%. For the proposed additional injection period, it is
expected that a larger portion of the gas added is carbon dioxide, changing the composition to ~93% CO2 and
~7% H2S.

Table 5 - Modeled Initial Gas Composition



Measured Current

2019-2024 Model

2024-2036 Model

Component

Composition (mol%)

Composition (mol%)

Composition (mol%)

Carbon Dioxide (C02)

89.678

90.696

92.921

Hydrogen Sulfide (H2S)

9.200

9.304

7.079

Methane (CI)

0.303

0

0

Ethane (C2)

0.058

0

0

Propane (C3)

0.108

0

0

N-Butane (NC4)

0.025

0

0

Hexane Plus (C6+)

0.628

0

0

Core data from literature review was used to determine relative permeability curves between carbon dioxide
and the connate brine within the Silurian-Devonian carbonates (Ruppel and Holtz, 1994). The key inputs
used in the model include an irreducible water saturation of 25% and a maximum residual gas saturation of
21%.

The grid contains 141 blocks in the x-direction (E-W) and 201 blocks in the y-direction (N-S), totaling 28,341
grid blocks per layer. The grid blocks are each 150' by 150' by layer thickness as specified in Table 6. This
results in the grid being 21,150' by 30,150' totaling just over a 23-square mile area (14,640 acres). Each layer
in the model was determined by identifying higher permeability zones as targets for injection from the logs
and assigning each high permeability and intermediary low permeability zone its own layer. One zone was
identified as being a karst limestone (layers 2-7). Due to the "karsted" nature of this rock, it was determined
that most of the injectate would flow into this zone. Therefore, the karst limestone was further split into
layers by permeability to provide higher resolution and more accurately simulate which layer will have more
gas flow into it. Figure 22 provides a detailed breakdown of the "karsted" rock.

33


-------
Permeability Distribution of Karst Zone

2

3

4

l—

(D
_l

5

6

7

1	10	100	1000

Permeability (mD)

Figure 22 - Permeability Distribution of Karst Limestone

In total, there are sixteen (16) layers in the model, representing ten (10) layers of pay and six (6) layers of
intermediary low permeability zones. The properties of each of these layers are summarized in Table 6
below.

Table 6 - CMG Model Layer Properties

Layer #

Top (ft)

Thickness (ft)

Permeability (mD)

Porosity

1

11,037

71

1

2.8%

2

11,108

57

47

8.0%

3

11,165

19

223

11.9%

4

11,184

16

15

6.3%

5

11,200

39

70

9.2%

6

11,238

11

228

12.3%

7

11,249

21

49

8.3%

8

11,270

251

2

3.7%

9

11,520

46

9

5.6%

10

11,566

13

3

4.3%

11

11,579

19

17

6.5%

12

11,597

14

2

3.9%

13

11,611

103

13

6.0%

14

11,714

46

2

3.7%

15

11,759

67

23

6.1%

16

11,826

125

2

3.6%

34


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Simulation Modeling

The primary objectives of the model simulation were to:

1)	Estimate the maximum areal extent and density drift of the acid gas plume after injection

2)	Assess the impact of offset saltwater disposal ("SWD") well injection on density drift of the plume

3)	Assess the impact of offset producing wells on the density drift of the plume

4)	Determine the ability of the target formation to handle the required injection rate without
fracturing the injection zone

5)	Assess the likelihood of the acid gas plume migrating into potential leak pathways

The reservoir is assumed to be an aquifer filled with 100% brine. The salinity of the formation is estimated
to be 53,000 ppm (Texas Water Development Board, 1972). The acid gas stream is primarily composed of
C02 and H2S as stated previously. Core data was used to help generate relative permeability curves. Cores,
from the literature reviews previously discussed, that most closely represent the vuggy carbonate seen in
this region were identified and the Corey-Brooks equations were used to develop the curves. The lowest
residual gas saturation found in the cores was then used for a conservative estimate of plume size. From
offset injection well analysis, the initial reservoir pressure was determined to be 5,132 psi which is equivalent
to a 0.465 psi/ft pressure gradient. The fracture gradient of the injection zone was estimated to be 0.72
psi/ft, which was determined using Eaton's equation. A 10% safety factor was then applied to this number,
putting the maximum bottom-hole pressure allowed in the model at 0.64 psi/ft which is equivalent to 7,064
psi.

The model also takes into account offset saltwater disposal ("SWD") injection volumes within five (5) miles
of the Rattlesnake AGI #1 well. These SWDs create a pressure front that push the plume further up-dip of
the formation. A total of twenty (20) offset wells currently injecting into the target formation were identified.
Eleven (11) of these offset SWDs were out of the confines of the grid, but were still accounted for in the
model. Nine (9) salt-water disposals were modeled within the boundaries of the 23-square-mile grid. Two
(2) of these offset injectors are currently only permitted (not drilled) but were assumed to start active
injection within the first year of the model. Both permits were simulated at the forecasted injection rate
schedule for 30 years. These forecasts were provided by the operators of these wells. Historical injection
rates of each of the other existing wells were analyzed and projected into the model. This simulation includes
the effect of water injection on the density drift of the plume and bottom hole pressure.

Further review of the area revealed production wells in the Silurian-Devonian formation that could impact
the density drift of the plume by creating a "pressure sink". A "pressure sink" is an area of lower pressure
caused by the production of formation fluids. To simulate this effect, nine (9) production wells were grouped
together and their respective production rates combined into a single well to add more conservatism into
the model. These producers were forecasted an additional 15 years to simulate their potential economic
lifespan. This simulation includes the effect of fluid production on the density drift of the plume and bottom
hole pressure. Overall, the "pressure sink" has little effect on the density drift and, as discussed below, the
plume never reaches the producing wells.

The model runs for a total of 814 years, starting in 1965 with the beginning of offset production until the
calculated stabilization of the plume in 2779. The injection of TAG from Rattlesnake AGI #1 is modeled from
the beginning of injection in 2019 through the planned 14 years of future injection. The model also includes
the 57 years of historical plus 15 years of forecasted future oil and gas production.

Additionally, historical monthly injection rates of all nearby SWDs were incorporated into the model to
simulate any additional near-wellbore pressure increase that may occur due to offset injection. The

35


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modelling of the saltwater injection begins in 1984 when the first offset SWD well became operational. The
SWDs to the North were grouped into four (4) separate groups to simulate their combined effect on the
density drift of the plume. All offset injection wells and their groupings are included in Table 7. All offset
production wells are listed in Table 8.

Table 7 - All Offset SI/l/Ds included in the model

Grouping

API

Well Name

Well#



42-501-32511

SAWYER, DESSIE

1



42-501-02068

WEST, M. M.

2

Group 1

42-501-02053

NORTH CENTRAL OIL CO. "A"

1



42-501-01453

SMITH, EDS. HEIRS "B"

1



42-501-02059

SMITH, ED "C"

1W

Group 2

42-501-30051

JOHNSON

2

42-501-30001

JOHNSON

ID

Group 3

42-501-37066

MISS KITTY SWD 669

1W

42-501-36650

RUSTY CRANE 604

1W

Group 4

42-501-36745

SUNDANCE 642

1

42-501-33887

WINFREY 602

3WD



42-501-37252

Miller SWD

7



42-501-37367

BLONDIE 704

1W



42-501-37206

BRUSHY BILL 707

1WD



42-501-36622

WISHBONE FARMS 710

1W

Standalone

42-501-35834

ROBERTS UNIT

2



42-501-33297

STATE ELMORE

1



42-501-10238

SHEPHERD SWD

1



42-501-33511

CORNELL UNIT

3019D



42-501-32868

WILLARD UNIT

1WD

Table 8 - All Offset Producers included in the model

API

Well Name

Well #

42-501-10046

ELLIOTT, C.A.

2

42-501-10079

RANDALL, E

32

42-501-337932

RANDALL, E

40

42-501-33885

RANDALL, E

41L

42-501-34016

RANDALL, E

43 L

42-501-34017

RANDALL, E.

45 L

42-501-34023

RANDALL, E

42L

42-501-34024

RANDALL, E

44

42-501-35418

RANDALL, E

46

Rattlesnake AGI #1 came online in 2019 and the model simulated its historical monthly injection rates until
2024. After this initial period, it is conservatively assumed that the injection rate increases to the maximum
permitted rate of 16 MMSCF/d for the remainder of the active injection period in 2036. At this point, the

36


-------
Rattlesnake AGI #1 well stops injection while the offset SWD injectors continue operations for thirty more
years. Density drift then occurs until plume stabilizes, which was determined to be 814 years from the start
of the model in 1965. Stabilization of the plume is determined to occur when the model shows no further
lateral movement horizontally or vertically. The plume boundary is then defined by a weighted average gas
saturation in the aquifer of 3%.

The maximum plume extent during the 17-year Rattlesnake injection period is shown in Figure 23. The final
extent after 743 years of density drift after injection ceases is shown in Figure 24. The extensive time of the
modeled density drift of the plume is driven by the buoyant forces of the gas, the permeability/porosity of
the rock, and the residual gas saturation. Initially, the karsted region takes on most of the injection, but due
to the buoyant forces, it is slowly pushed up higher into the less permeable layers of the injection interval.
These lower permeable layers, increase the amount of time it takes for the plume to reach its maximum areal
extent. As all the inputs to the model were based on the most conservative approach, the maximum extent
of the plume will likely be smaller and the effective impact on reaching potential leakage pathways will be
minimal as the amount of CO2 at those far extents will be small.

State Elmore

Brushy Bills 707

Shepherd SWD

Rattlesnake AGI Plume
Global Mote froction(CQ2) 2036-Jqn-Ol K Plone: 2 of 16

-0.70
¦ -060

1050
o.
-
0.20

Group 2 Group 4 Group 3 Group 1

Blondie 704

Mi ter SWD

Rattlesnake AGI

Willard Unit

Roberts Unit

Production Wells

Cornell Unit

Figure 23 - AreaI View Gas Saturation Plume, 2036 (End of Injection)

37


-------
Brushy Bills 707

19,215'

Miller SWD

6,900'

Blondie 704

Production Wells

Rattlesnake AGI

Willard Unit

Roberts Unit

Cornell Unit

Group 2 Group 4 Group 3 Group 1

State Elmore

Shepherd SWD

1.00-—
!¦

090
080
-070
-060

-

t

-030
020

Rattlesnake AGI Plume
Global Mole Fractlon{C02) 2779-Doc-OI K Plane: 2 of 16

Figure 24- Area! View Gas Saturation Plume, 2779 (End of Density Drift)

Figure 25 shows the surface injection rate and bottom hole pressure over the injection period and the period
of density drift after injection ceases. The bottomhole pressure increases the most as the injection rate
reaches its peak, reaching a maximum pressure of 5,413 psi. This buildup of 280 psi keeps the bottomhole
pressure well below the fracture pressure of 7,064 psi. The maximum surface pressure associated with the
maximum bottomhole pressure reached is 2,494 psi.

16.000,000

I" 14.000,000

£ 12,000,000

= 10,000,000
o

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—	Rattlesnake AGI, Well Bottom-hole Pressure

Figure 25 - Well Injection Rate and Bottomhole Pressure over Time

38


-------
SECTION 3 - DELINATION OF MONITORING AREA

This section discusses the delineation of Maximum Monitoring Area ("MMA") and Active Monitoring Area
("AMA") as described in EPA 40 CFR §98.448(a)(l).

Maximum Monitoring Area

The MMA is defined as equal to or greater than the area expected to contain the free-phase C02 plume until
the C02 plume has stabilized plus an all-around buffer zone of at least one-half mile. Numerical simulation
was used to predict the size and drift of the plume. With CMG's GEM software package, reservoir modeling
was used to determine the areal extent and density drift of the plume. The model takes into account the
following considerations:

•	Offset well logs to estimate geologic properties

•	Petrophysical analysis to calculate the heterogeneity of the rock

•	Geological interpretations to determine faulting and geologic structure

•	Offset injection history to adequately predict the density drift of the plume

Acid gas injectate was analyzed by a third-party vendor to determine the initial composition used in the
model. The report is provided in Appendix C. The molar composition of the gas is primarily C02 with some
H2S and CH4. The change in molar composition was also incorporated into the model as future predominantly
C02 streams are added for injection. As discussed in Section 2, the gas was injected into the Silurian
formation, specifically, the Fasken/Fusselman formation. The geomodel was created based off the rock
properties seen in the Fasken/Fusselman.

The plume boundary was defined by the weighted average gas saturation in the aquifer. A value of 3% gas
saturation was used to determine the boundary of the plume. When injection ceases in 2036, the areal
expanse of the plume will be 1,052 acres. The maximum distance between the wellbore and the edge of the
plume is approximately 0.87 miles to the southeast. After 743 additional years of density drift, the areal
extent of the plume is 2,177 acres with a maximum distance to the edge of the plume of approximately 1.35
miles to the southeast.

Figure 26 shows the plume boundary at the end of injection, the stabilized plume boundary and the MMA.

39


-------
f















Rattlesnake ACI No. 1
PI use Boundary at End of Injection
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Active Monitoring Area

The initial AMA will cover a 14-year monitoring period. This period equates to the time of expected future
injection. The AMA will be established by superimposing the area based on a half-mile buffer around the
anticipated plume location at the end of injection (2036) with the area of the projected free-phase C02 plume
at five additional years (2041). In this case, the plume boundary in 2041 is within the plume at 2036 plus a
half-mile buffer. By 2036 at the latest, a revised MRV plan will be submitted to define a new AMA. Figure 27
shows the area covered by the AMA.

Larger size versions of Figures 26 and 27 are provided in Appendix D.

40


-------
ID

1 Inch = 0.51 Mile
1:32,000 m



&

Rattlesnake ACI No. 1
PI use Boundary at End of Injection
& 19-Year Plume
wi th

1/Z-Hile Active Monitoring Area (AHA)
Stakeholder Midstream

	Yoakum Co.. TX	

PCS: NADB3 TX-NC FIPS 4202 
-------
SECTION 4 - POTENTIAL PATHWAYS FOR LEAKAGE

This section identifies the potential pathways for C02 to leak to the surface within the MMA and the
likelihood, magnitude and timing of such leakage. The potential leakage pathways are:

•	Leakage from surface equipment

•	Leakage through existing wells within MMA

•	Leakage through faults and fractures

•	Natural or Induced Seismicity

•	Drilling through the MMA

•	Leakage through the confining layer

Leakage from Surface Equipment

The surface facilities at the 30-30 Facility are designed for injecting acid gas containing H2S, and therefore
minimize leakage points such as valves and flanges following industry standards and best practices. H2S gas
detectors are located around the facility and the well site. These gas detectors trigger alarms at 10 parts per
million ("ppm"). Additionally, all Stakeholder field personnel are required to wear H2S monitors which are
triggered at 5 ppm of H2S. A shut-in valve is located at the wellhead and is locally controlled by pressure,
with a high pressure and low pressure shut-off.

The facilities have been designed and constructed with additional safety systems to provide for safe
operations. These systems include Emergency Shutdown ("ESD") valves to isolate portions of the plant and
pipeline, pressure relief valves along the pipeline to prevent over pressurization, and flares to allow piping
and equipment to be de-pressured rapidly under safe and controlled operating conditions in the event of a
leak. Figures 28 and 29 display the facility safety plot plan, taken from the 30-30 H2S Contingency Plan, and
show the location of the H2S monitors in the vicinity of the plant and the Rattlesnake AGI #1 well. Should
Stakeholder construct additional C02 facilities, as indicated in Figure 21, a separate meter will be installed for
the additional stream in order to comply with the 40 CFR §98.448(a)(5) measurement. As this meter will be
in close proximity to the existing facilities, it will utilize the existing monitoring programs discussed previously.
Additionally, C02 monitors will be installed near the new meter and tied into the facility monitoring systems.

42


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Figure 28 - Site Plan, 30-30 Facility

43


-------
With the level of monitoring at the 30-30 Facility and the Rattlesnake AGI #1 well, any release of H2S and C02
would be quickly identified, and the safety systems would quickly minimize the volume of the release. The
C02 injected into the Rattlesnake AGI #1 is injected with H2S at a concentration of 10% (100,000 ppm). At
this high level of H2S concentration, even a small leakage would trigger personal and facility H2S monitors set
to alarm at 5 ppm and 10 ppm respectively. If any leakage were to be detected, the volume of C02 released
will be quantified based on the operating conditions at the time of release, as stated in Section 7 in
accordance with 40 CFR §98.448(a)(5).

A larger scale version of Figure 28 is provided in Appendix E.

Leakage from Wells in the Monitoring Area
Oil and Gas Operations within Monitoring Area

A significant number of wells have historically been drilled within the area of the Rattlesnake AGI #1 well,
however production has primarily been from the shallower San Andres formation in the Wasson Field. The
San Andres is separated from the Silurian-Devonian interval by 4,720' in this area. In addition to the primary
San Andres production, a few wells have produced from the Wolfcamp. The Wolfcamp is separated from the
Siluro-Devonian interval by is 1,800'. Within the projected plume area of the Rattlesnake AGI #1 well, there
are no penetrations of the injection interval. There are ten wells within the MMA that penetrate the
injection interval.

A review of the TRRC records for all of the wells which penetrate the injection interval within the MMA,
shows the wells were properly cased and cemented to prevent annular leakage of C02 to the surface. The
plugged wells are also adequately protected against migration from the Devonian by the placement of the
plugs within the wellbores. Additionally, the Rattlesnake AGI #1 well was designed to prevent migration from
the injection interval to the surface through the casing and cement placed in the well, as shown in Figure 29.
Mechanical integrity tests ("MIT") required under TRRC rules are run annually to verify the well and wellhead
can hold the appropriate amount of pressure. If the MIT were to indicate a leak, the well would be isolated
and the leak mitigated quickly to prevent leakage to the atmosphere.

A map of all wells within the MMA is shown in Figure 30. Figure 31 shows only those wells which penetrate
the injection interval within the MMA. The MMA review maps, a summary of all the wells in the MMA and
detailed wellbore schematics for those wells which penetrate the injection interval are provided in Appendix
F.

44


-------
Base of USDW@375'

Rustler @ 2,345'

Salado @ 2,443'

Yates @ 3,019'

Seven Rivers @ 3,440'

dH

Grayburg @ 4; 190'
San Andres @ 4,465'

DV Tool @ 4,275'

DV Tool @5,591'

Glorieta @ 6,316'
Clearfork @ 6,492'

Wichita @ 8,628'

12,500' -
13,000' -
15,500' -

GK

Upper Wolfcamp @ 9,239'

Strawn @ 10,030'

Atoka @ 10,230'

Woodford @ 10,973'
Devonian @ 11,036'
Wristen@ 11,268'
Fusselman@ 11,538' Ci)
Montoya @ 11,974'

¦

ir

DV Tool @9,575'
Packer @ 10,966'

TD@ 11,980'

KB:

N/A

BHF:

NA

GL:

3,627'

Spud:

5/27/2018

Casing/Tubing Information

Label

1

2

3

4

Type

Surface

Intermediate

Production

Tubing

OD

13-3/8"

9-5/8"

7"

3-1/2"

Weight

48

40

29

9,2

WT

.330

.395

.408

NA

Grade

H40/J55 STC

L- 80 BTC

L80 LTC
2535 Vam Top

L80 Vam Top:
G3 Vam Top'

Hole Size

17-1/2"

12-1/4"

8 3/4

6"

Depth Set

504'

5.498'

11,014'

10,966'

TOC

Surface

Surface

Surface

NA

Volume

510 sks

2,135 sks

760 sks

NA

LONQUIST & CO. LLC

PETROLEUM

ENER6Y

ENGINEERS

ADVISORS

HOUSTON'CALGARY
AUSTIN I WICHITA I DENVER

Stakeholder Midstream

Country: USA

Location: 33.07884, -103.904514

API No: 42-501-36998

Rattlesnake No. 1

State/Province: Texas

Site:

County/Parish: Yoakum

Survey:

Well Type/Status: AG I

Texas License F-9147

RRC District No:

Project No: LS 128

Date: 5/27/2022

12912 Hill Country Blvd Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Reviewed: SLP

Approved: SLP

Figure 29 - Rattlesnake AG! #1 Well bore Schematic

45


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46


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Figure 31 - Penetrating Oil and Gas Wells within the MMA

47


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Future Drilling

Potential leak pathways caused by future drilling in the area are not expected to occur. The deeper
formations, such as the Devonian, have proven to-date to be less productive or non-productive in this area,
which is why the location was selected for injection. Furthermore, any drilling permits issued by the TRRC in
the area of the Rattlesnake AGI #1 well include a list of formations for which oil and gas operators are
required to comply with TRRC Rule 13 (entitled "Casing, Cementing, Drilling, Well Control, and Completion
Requirements"). 16 TAC § 3.13. By way of example, see the Rattlesnake AGI #1 well drilling permit provided
in Appendix B. The Devonian is among the formations listed for which operators in Yoakum County (where
the Rattlesnake #1 is located) are required to comply with TRCC Rule 13 (Appendix B, pg. 5). TRRC Rule 13
requires oil and gas operators to set steel casing and cement across and above all formations permitted for
injection under TRRC Rule 9 or immediately above all formations permitted for injection under Rule 46 for
any well proposed within a one-quarter mile radius of an injection well. In this instance, any new well
permitted and drilled to the Rattlesnake AGI #1 well's injection zone, and located within a one-quarter mile
radius of the Rattlesnake AGI #1 well, will be required under TRRC Rule 13 to set steel casing and cement
above the Rattlesnake AGI #1 well injection zone. Additionally, Rule 13 requires operators to case and
cement across and above all potential flow zones and/or zones with corrosive formation fluids. The TRRC
maintains a list of such known zones by TRRC district and county and provides that list with each drilling
permit issued, which is also shown in the above-mentioned permit in Appendix B.

If any leakage were to be detected, the volume of C02 released will be quantified based on the operating
conditions at the time of release.

Groundwater wells

There are seven groundwater wells located within the MMA, as identified by the Texas Water Development
Board. All of the identified groundwater wells in the area have total depths less than or equal to 265', as
shown in Figure 32 and Table 9. One of the wells is located on the 30-30 facility property with a total depth
of 119'and is operated by Stakeholder.

The surface and intermediate casings of the Rattlesnake AGI #1 well, as shown in Figure 29, are designed to
protect the shallow freshwater aquifers consistent with applicable TRRC regulations and the GAU letter
issued for this location. See GAU letter included within Appendix B. The wellbore casings and cements also
serve to prevent C02 leakage to the surface along the borehole.

A larger scale version of Figure 32 is provided in Appendix F.

48


-------


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Yoakum Co., TX

PCS: NAD 83 TX-NC FIPS 4202 
-------
Table 9 - Groundwater Well Summary

State Well ID

Owner Name

Primary Use Well Depth Data Source

370449

Frances Barbini

Irrigation

237

SDRDB

443840

Frances Jean Barbini

Irrigation

250

SDRDB

482963

Santa Fe Midstream Permian

Industrial

119

SDRDB

510854

FRANCIS BARNINI

Irrigation

255

SDRDB

520249

Thomas Durham

Irrigation

264

SDRDB

543433

FRANCIS BARBIDI

Irrigation

240

SDRDB

84760

TEXACO PRODUCING INC





TWDB BW

Leakage Through Faults or Fractures

Faults were interpreted from roughly 9 square miles of 3D seismic indicated by the purple outline in Figure
12. Faulting in this region terminates vertically below the Pennsylvanian-age rock. Secondary confining
shales within the Wolfcampian and younger strata provide additional, redundant confining layers that would
prevent C02from migrating into freshwater aquifers. None of the mapped faults project above the Wolfcamp
formation; rather, they appear to terminate between the Strawn and base of the Wolfcamp formation. If, in
the unlikely event the faults' sealing properties are compromised post-injection, secondary confinement is
provided by the tight limestones found within the overlying Mississippianan Lime formation and the shale
layers found in the Atoka and Wolfcamp formations. As seen in Figure 14, the largest fault found SE of the
Rattlesnake AGI #1 well, terminates within the Atoka formation. Though it crosses the Silurian section, this
fault thrusts the Mississippian Lime upward against the Atoka shales. The tight reservoir characteristics of
the Mississippian Lime and shaley section of the Atoka create a confining environment vertically and laterally
to contain potential upward migration of buoyant fluids. Shales within the Wolfcamp formation provide
additional confining beds between overlying USDWs and the fault plane.

Should an unmapped fault exist within the plume boundary, the offset would be below 3D seismic resolution.
The offset would be less than the thickness of the Woodford shale, juxtaposing the Woodford against itself,
preventing vertical migration.

Fractures and subsequent subaerial exposure are responsible for porosity development within the injection
intervals. Open hole logs show little to no porosity development indicating the Woodford or Mississippian
Lime were not exposed at this location. Upward migration of injected gas through confining bed fractures is
unlikely.

50


-------
Leakage Through Confining Layers

The Silurian-Devonian injection zones have competent sealing rocks above and below the porous sub-aerially
exposed carbonate. The properties of the overlying transgressive Woodford shale (widespread deposition,
high illite clay and organic matter composition, and low porosity and permeability) make an excellent sealing
rock to the underlying Silurian formation. Tight Mississippian Lime of roughly 660 ft, lay between Atoka and
Woodford shale formations, forming an impermeable upper seal to the injection interval. Above this
confining unit, correlative shales of the Wolfcamp, Abo and Tubb formations will prevent any upper fluid
migration. These impermeable shales are capped by hundreds of feet of the regionally present Salado
formation evaporites. The USDW lies above the sealing properties of the formations outlined above, making
stratigraphic migration of fluids into the USDW highly unlikely. The underlying low porosity and permeability
Montoya carbonate minimizes the likelihood of downward migration of injected fluids. The relative
buoyancy of injected gas to the in-situ reservoir fluid makes migration below the lower confining layer
unlikely.

Leakage from Natural or Induced Seismicitv

The location of Rattlesnake AGI #1 is in an area of the Permian Basin that is inactive from a seismicity
perspective, whether induced or natural. A review of historical seismic events on the USGS's Advanced
National Seismic System site (from 1971 to present) and the Bureau of Economic Geology's TexNet catalog
(from 2017 to present), as shown in Figure 33, indicates the nearest seismic event occurred more than 60
miles away.

A regional analysis of the probabilistic fault slip potential across the Permian Basin (Snee & Zoback 2016), as
seen in Figure 34, further demonstrates that the Rattlesnake AGI #1 well is located in a seismically inactive
area and confirms that this area has little to no potential for an induced seismicity event.

Therefore, there is no indication that seismic activity poses a risk for loss of C02 to the surface within the
MMA.

Pressures will be kept significantly below the fracture gradient of the injection and confining intervals.
Additionally, continuous well monitoring combined with seismic monitoring will identify any operational
anomalies associated with a seismicity event.

51


-------
LLANO E S TAC A DO
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52


-------
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Figure 34 - Probabilistic Fault Slip Potential Analysis with Rattlesnake AGI ft1 location (Snee & Zobak 2016)

53


-------
SECTION 5 - MONITORING FOR LEAKAGE

This section discusses the strategy that Stakeholder will employ for detecting and quantifying surface leakage
of C02 through the pathways identified in Section 4 to meet the requirements of 40 CFR §98.448(a)(3). As
the injectate stream contains both H2S and C02, the H2S will be a proxy for C02 leakage and therefore the
monitoring systems in place to detect H2S will also indicate a release of C02. Table 10 summarizes the
monitoring of potential leakage pathways to the surface. Monitoring will occur during the planned 17-year
injection period, or cessation of injection operations, plus a proposed 5-year post-injection period.

•	Leakage from surface equipment

•	Leakage through existing and future wells within MMA

•	Leakage through faults and fractures

•	Leakage through the confining layer

•	Leakage through natural or induced seismicity

Because the acid gas injection stream also contains H2S, any leakage would be detected by the H2S alarms
located around the facility and would be quickly addressed which would minimize the release of C02 into the
atmosphere.

Table 10- Summary of Leakage Monitoring Methods

Leakage Pathway

Monitoring Method

Leakage from surface equipment

Fixed H2S monitors throughout the AGI facility

Daily visual inspections

Personal H2S monitors

Distributed Control System Monitoring (Volumes and Pressures)

Leakage through existing wells

Fixed H2S monitor at the AGI well

SCADA Continuous Monitoring at the AGI Well

Annual Mechanical Integrity Tests ("MIT") of the AGI Well

Visual Inspections

Quarterly C02 Measurements within AMA

Leakage through groundwater wells

Annual GroundwaterSamples on Property

Leakage from future wells

H2S Monitoring during offset drilling operations

Leakage through faults and fractures

SCADA Continuous Monitoring at the AGI Well (volumes and pressures)

Fixed In-field H2S monitors

Leakage through confining layer

SCADA Continuous Monitoring at the AGI Well (volumes and pressures)

Fixed In-field H2S monitors

Leakage from natural or induced
seismicity

Seismic monitoring station to be installed

54


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Leakage from Surface Equipment

As the 30-30 Facility and the Rattlesnake AGI #1 well are designed to handle H2S, leakage from surface
equipment is unlikely to occur and would be quickly detected and addressed. The facility design minimizes
leak points through the equipment used and the type of connections are designed to minimize corrosion
points. The H2S in the injectate serves as a proxy for the release of C02. The facility and well site contain a
number of H2S alarms, set with a high alarm setpoint of 10 ppm of H2S, which are shown in Figure 28 above.
Additionally, all Stakeholder field personnel are required to wear H2S monitors, which trigger the alarm at 5
ppm H2S.

The AGI facility is continuously monitored through automated systems. In addition, field personnel conduct
daily visual field inspections of gauges, monitors and leak indicators such as vapor plumes. The effectiveness
of the internal and external corrosion control program is monitored through the periodic inspection of the
system, analysis of liquids collected from the line, and inspection of the cathodic protection system. These
inspections, in addition to the automated systems, allow Stakeholder to quickly respond to any leakage
situation. Monitoring will occur for the duration of injection and the post-injection period. Should leakage
be detected during active injection operations, the volume of C02 released will be calculated based on
operating conditions at the time of the event, per 40 CFR §98.448(a)(5).

Leakage from Existing and Future Wells within Monitoring Area

Stakeholder continuously monitors and collects injection volumes, pressures, temperatures and gas
composition data, through their SCADA systems, for the Rattlesnake AGI #1 well. This data is reviewed by
qualified personnel and will follow response and reporting procedures when data is outside acceptable
performance limits. Rattlesnake AGI #1 has a pressure and temperature gauge placed in the injection stream
at its wellhead, and a pressure gauge on the casing annulus. A change of pressure on the annulus would
indicate the presence of a possible leak. Mechanical integrity tests ("MITs") performed annually would also
indicate the presence of a leak. Upon a negative MIT, the well would immediately be isolated and the leak
mitigated.

The ten offset penetrating wells within the MMA are adequately cased and cemented to prevent potential
leakage of C02 from the Rattlesnake AGI #1 well plume. Additionally, the plugged wells were done so in a
way to prevent migration of C02 as provided in Appendix E. As discussed previously, Rule 13 would ensure
that new wells in the field would be constructed in a manner to prevent migration from the injection interval.

In addition to the fixed and personal monitors described previously, Stakeholder will also establish and
operate an in-field monitoring program to detect any C02 leakage within the AMA. The scope of work will
include H2S and C02 monitoring at the AGI well site as well as minimum, quarterly atmospheric monitoring
near identified penetrations within the AMA. Upon approval of the MRV and through the post-injection
monitoring period, Stakeholder will have these monitoring systems in place. Additional monitoring will be
added as the AMA is updated over time.

At the well site, H2S and C02 concentrations will be monitored continuously with fixed monitors that detect
atmospheric concentrations of H2S and C02. At penetrating well sites, Stakeholder will similarly measure
atmospheric concentrations of C02 and H2S using mobile gas monitors. This data will be recorded at least
quarterly.

55


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Groundwater Quality Monitoring

Stakeholder will monitor the groundwater quality in fluids above the confining interval by sampling the well
on the facility property and analyzing the sample with a third-party laboratory on an annual basis. Any
significant changes to the water analysis would be investigated to determine if such change was a result of
leakage from the Rattlesnake AGI #1 well. The parameters to be measured will include pH, total dissolved
solids, total inorganic and organic carbons, density, temperature and other standard laboratory
measurements. Any significant differences in these parameters from the baseline sample will be evaluated
to determine if leakage of C02 to the USDW may have occurred.

Leakage through Faults, Fractures or Confining Seals

Stakeholder continuously monitors the operations of the Rattlesnake AGI #1 well through automated
systems. Any deviation from normal operating conditions indicating movement into a potential pathway
such as a fault or breakthrough of the confining seal would trigger an alert. Any such alert would be reviewed
by field personnel and action taken to shut in the well, if necessary. Field H2S monitoring systems would alert
field personnel for any release of H2S/CO2 caused by such leakage.

Leakage through Natural or Induced Seismicitv

While the likelihood of a natural or induced seismicity event is extremely low, Stakeholder plans to install a
seismic monitoring station in the general area of the Rattlesnake AGI #1 well. The installation of this station
would start upon approval of the MRV plan, with an expected in-service data within six months after the
commencement of the installation project. This monitoring station will be tied in to the Bureau of Economic
Geology's TexNet Seismic Monitoring system. If a seismic event of 3.0 magnitude or greater is detected,
Stakeholder will review the injection volumes and pressures at the Rattlesnake AGI #1 well to determine if
any significant changes occur that would indicate potential leakage.

56


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SECTION 6 - BASELINE DETERMINATIONS

This section identifies the strategies Stakeholder will undertake to establish the expected baselines for
monitoring C02 surface leakage per 40 CFR §98.448(a)(4). Stakeholder will use the existing SCADA monitoring
systems to identify changes from expected performance that may indicate leakage of C02.

Visual Inspections

Daily inspections will be conducted by field personnel at the 30-30 Facility and the Rattlesnake AGI #1 well.
These inspections will aid with identifying and addressing issues timely to minimize the possibility of leakage.
If any issues are identified, such as vapor clouds or ice formations, corrective actions would be taken to
address such issues.

H2S Detection

H2S will be initially injected into the AGI well at a concentration of approximately ten (10) percent or 100,000
ppm. The concentration will drop to approximately six (6) percent as additional volumes are added. H2S gas
detectors are located throughout the AGI facility and well site and are set to trigger the alarm at 10 ppm.
Additionally, all field personnel are required to wear personal H2S monitors, which are set to trigger the alarm
at 5 ppm. Any alarm would trigger an immediate response to protect personnel and verify that the monitors
are working properly. If monitors are working correctly, immediate actions would be taken to secure the
facility and mitigate potential leaks.

CO2 Detection

Any C02 release would be accompanied by H2S and therefore the H2S monitors at the facility would also serve
as a C02 release warning system. In addition to the fixed and personal monitors described previously,
Stakeholder will also establish and operate an in-field monitoring program to detect any C02 leakage within
the AMA. The scope of work will include H2S and C02 monitoring at the AGI well site as well as atmospheric
monitoring near identified penetrations within the AMA.

Operational Data

Upon starting injection operations, baseline measurements of injection volumes and pressures will be taken.
Any significant deviations over time will be analyzed for indication of leakage of C02.

Continuous Monitoring

Mass of C02 emitted by surface leakage and equipment leaks will not be measured directly as the injection
stream for this well contains H2S which would be extremely dangerous for personnel to perform a direct leak
survey. Any leakage would be detected and managed as per Texas regulations and Stakeholder's TRRC-
approved H2S Contingency Plan. Gas detectors and continuous monitoring systems would trigger an alarm
upon a release. The mass of the C02 released would be calculated for the operating conditions at the time,
including pressure, flow rate, size of the leak point opening, and duration of the leak. This method is
consistent with 40 CFR §98.448(a)(5), allowing the operator to calculate site-specific variables used in the
mass balance equation.

57


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No C02 emissions will occur from venting because of the high H2S concentrations. Blowdown emissions are
sent to flares and would be reported as part of the required reporting for the gas plant.

Groundwater Monitoring

An initial sample will be taken from the groundwater well on Stakeholder's property, identified as Well #
482963 in Table 9 above, upon approval of Stakeholder's MRV and prior to increasing injection. The sample
will be analyzed by a third-party laboratory to establish the baseline properties of the groundwater.

58


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SECTION 7 - SITE SPECIFIC CONSIDERATIONS FOR MASS BALANCE

EQUATION

This section identifies how Stakeholder will calculate the mass of C02 injected, emitted, and sequestered.
This also includes site-specific variables for calculating the C02 emissions from equipment leaks and vented
emissions of C02 between the injection flow meter and the injection well, per 40 CFR §98.448(a)(5).

Mass of CO2 Received

Per 40 CFR §98.443, the mass of C02 received must be calculated using the specified C02 received equations
"unless you follow the procedures in 40 CFR §98.444(a)(4)." 40 CFR §98.444(a)(4) states that "if the C02 you
receive is wholly injected and is not mixed with any other supply of C02, you may report the annual mass of
C02 injected that you determined following the requirements under paragraph (b) of this section as the total
annual mass of C02 received instead of using Equation RR-1 or RR-2 of this subpart to calculate C02 received."
The C02 received for this injection well is wholly injected and not mixed with any other supply and the annual
mass of C02 injected will equal the amount received. Any future streams would be metered separately before
being combined into the calculated stream.

Mass of CO2 Injected

Per 40 CFR §98.444(b), since the flow rate of C02 injected will be measured with a volumetric flow meter, the
total annual mass of C02, in metric tons, will be calculated by multiplying the mass flow by the C02
concentration in the flow according to Equation RR-5:

C02,u = Annual C02 mass injected (metric tons) as measured by flow meter u

QP,u = Quarterly volumetric flow rate measurement for flow meter u in quarter p (metric tons per

D = Density of C02 at standard conditions (metric tons per standard cubic meter): 0.0018682

Cco2,P,u = Quarterly C02 concentration measurement in flow for flow meter u in quarter p (wt. percent
C02, expressed as a decimal fraction)

p = Quarter of the year

u = Flow meter

4

p = 1

where:

quarter)

59


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60


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Mass of CO2 Produced

The Rattlesnake AGI #1 well is not part of an enhanced oil recovery project; therefore, no C02 will be
produced.

Mass of CO2 Emitted by Surface Leakage

Mass of C02 emitted by surface leakage and equipment leaks will not be measured directly as the injection
stream for this well contains H2S which would be extremely dangerous for personnel to perform a direct leak
survey. Any leakage would be detected and managed as a major upset event. Gas detectors and continuous
monitoring systems would trigger an alarm upon a release. The mass of the C02 released would be calculated
for the operating conditions at the time, including pressure, flow rate, size of the leak point opening, and
duration of the leak. This method is consistent with 40 CFR §98.448(a)(5), allowing the operator to calculate
site-specific variables used in the mass balance equation.

In the unlikely event that C02 was released as a result of surface leakage, the mass emitted would be
calculated for each surface pathway according to methods outlined in the plan and totaled using Equation
RR-10 as follows:

C02 = Total annual C02 mass emitted by surface leakage (metric tons) in the reporting year
C02,x= Annual C02 mass emitted (metric tons) at leakage pathway x in the reporting year
X = Leakage pathway

Calculation methods from subpart W will be used to calculate C02 emissions from equipment located on
the surface between the flow meter used to measure injection quantity and the injection wellhead

Mass of CO2 Sequestered

The mass of C02 sequestered in subsurface geologic formations will be calculated based off Equation RR-12,
as this well will not actively produce oil or natural gas or any other fluids, as follows:

X

X=1

Where:

CO 2 — C02i C02e C02fi

Where:

61


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C02 = Total annual C02 mass sequestered in subsurface geologic formations (metric tons) at the
facility in the reporting year

CO21 = Total annual C02 mass injected (metric tons) in the well or group of wells covered by this source
category in the reporting year

C02E = Total annual C02 mass emitted (metric tons) by surface leakage in the reporting year

CO 2fi - Total annual C02 mass emitted (metric tons) from equipment leaks and vented emissions of
C02 from equipment located on the surface between the flow meter used to measure injection
quantity and the injection wellhead

CO 2fi will be calculated in accordance with Subpart W reporting of GHGs. Because no venting would occur
due to the high H2S concentrations of the injectate stream, the calculations would be based on the blowdown
emissions that would be sent to flares and would be reported as part of the required GHG reporting for the
gas plant.

• Calculation methods from subpart W will be used to calculate C02 emissions from equipment located
on the surface between the flow meter used to measure injection quantity and the injection
wellhead.

62


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SECTION 8 - IMPLEMENTATION SCHEDULE FOR MRV PLAN

The Rattlesnake AGI #1 well currently reports GHGs under Subpart UU, but Stakeholder has elected to submit
an MRV plan under, and otherwise comply with, Subpart RR. The MRV plan will be implemented upon
receiving EPA approval. The Annual Subpart RR Report will be filed on March 31st of the year following the
reporting year.

63


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SECTION 9 - QUALITY ASSURANCE

This section identifies how Stakeholder plans to manage quality assurance and control, to meet the

requirements of 40 CFR §98.444.

Monitoring QA/QC

C02 Injected

•	The flow rate of the C02 being injected will be measured with a volumetric flow meter, consistent
with industry best practices. These flow rates will be compiled quarterly.

•	The composition of the C02 stream will be measured upstream of the volumetric flow meter with a
continuous gas composition analyzer or representative sampling consistent with industry best
practices.

•	The gas composition measurements of the injected stream will be averaged quarterly.

•	The C02 measurement equipment will be calibrated according to manufacturer recommendations.

C02 Emissions from Leaks and Vented Emissions

•	Gas detectors will be operated continuously, except for maintenance and calibration.

•	Gas detectors will be calibrated according to manufacturer recommendations and API standards.

•	Calculation methods from subpart W will be used to calculate C02 emissions from equipment located
on the surface between the flow meter used to measure injection quantity and the injection
wellhead.

Measurement Devices

•	Flow meters will be continuously operated except for maintenance and calibration.

•	Flow meters will be calibrated according to the requirements in 40 CFR §98.3(i).

•	Flow meters will be operated per an appropriate standard method as published by a consensus-
based standards organization.

•	Flow meter calibrations will be traceable to the National Institute of Standards and Technology
(NIST).

All measured volumes of C02 will be converted to standard cubic meters at a temperature of 60 degrees

Fahrenheit and an absolute pressure of 1 atmosphere.

Missing Data

In accordance with 40 CFR §98.445, Stakeholder will use the following procedures to estimate missing data

if unable to collect the data needed for the mass balance calculations:

•	If a quarterly quantity of C02 injected is missing, the amount will be estimated using a representative
quantity of C02 injected from the nearest previous period of time at a similar injection pressure.

•	Fugitive C02 emissions from equipment leaks from facility surface equipment will be estimated and
reported per the procedures specified in subpart W of 40 CFR §98.

64


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MRV Plan Revisions

If any of the changes outlined in 40 CFR §98.448(d) occur, Stakeholder will revise and submit an amended
MRV plan within 180 days to the Administrator for approval.

65


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SECTION 10 - RECORDS RETENTION

Stakeholder will retain records as required by 40 CFR §98.3(g). These records will be retained for at least
three years and include:

•	Quarterly records of the C02 injected

o Volumetric flow at standard conditions
o Volumetric flow at operating conditions
o Operating temperature and pressure
o Concentration of the C02 stream

•	Annual records of the information used to calculate the C02 emitted by surface leakage from leakage
pathways.

•	Annual records of information used to calculate C02 emitted from equipment leaks and vented
emissions of C02 from equipment located on the surface between the flow meter used to measure
injection quantity and the injection wellhead.

66


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References

Broadhead, Ronald E., 2005. Regional Aspects of the Wristen petroleum system, southeastern New Mexico:
New Mexico Bureau of Geology and Mineral Resources Open File Report, no. 485.

Comer, John B., 1991. Stratigraphic Analysis of the Upper Devonian Woodford Formation, Permian Basin,
West Texas and Southeastern New Mexico: Bureau of Economic Geology Report of Investigations, no. 201.

George, Peter G., Mace, Robert E., and Petrossian, Rima, 2011. Aquifers of Texas: Texas Water Development
Board Report, no 380.

Hoak, T., Sundberg, K., and Ortoleva, P. Overview of the Structural Geology and Tectonics of the Central Basin
Platform, Delaware Basin, and Midland Basin, West Texas and New Mexico: Department of Energy Open File
Report.

Molina, Oscar, Vilarras, Victor, and Zeidouni, Mehdi, 2016. Geologic carbon storage for shale gas recovery:
13th International Conference on Greenhouse Gas Control Technologies, GHGT-13, 14-18.

Ruppel, Stephen C. and Holtz, Mark H., 1994. Depositional and Diagenetic Facies Patterns and Reservoir
Development in Silurian and Devonian Rocks of the Permian Basin: Bureau of Economic Geology Report of
Investigations, no. 216.

Snee, Jens-Erik Lund and Zoback, Mark D., 2016. State of stress in the Permian Basin, Texas and New Mexico:
Implications for induced seismicity.

Teeple, Andrew P., Ging, Patricia B., Thomas, Jonathan V., Wallace, David S., and Payne, Jason D., 2021.
Hydrogeologic Framework, Geochemistry, Groundwater-Flow System, and Aquifer Hydraulic Properties Used
in the Development of a Conceptual Model of the Ogallala, Edwards-Trinity (High Plains), and Dockum
Aquifers In and Near Gaines, Terry, and Yoakum Counties, Texas: USGS Scientific Investigations Report 2021-
5009.

67


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APPENDICES


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APPENDIX A-GEOLOGY

APPENDIX A-l: SILURIAN STRUCTURE MAP
APPENDIX A-2: NE-SW CROSS SECTION
APPENDIX A-3: NW-SE CROSS SECTION
APPENDIX A-4: FORMATION FLUID SAMPLE WELL MAP


-------

-------
mi

LONQU 1ST

SEQUESTRATION L

Stakeholder Midstream


-------
42501105700000
1-667

TEXAS CRUDE OIL CO

42501358340000
ROBERTS UNIT
2

APACHE

<14,201 FT>

42501369980000
RATTLESNAKE AG I
1

STAKEHOLDER GAS SERVICES


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Rattlesnake AGI No. 1
Maximum Monitoring Area
with

Formation Fluid Sample Wells

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 6/1/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY





ENGINEERS

ADVISORS



| AUSTIN • HOUSTON J

I CALGARY-WICHITA

| DENVER

• COLLEGE STATION |

[ BATON ROUGE • EDMONTON

-J- Rattlesnake AGI No. 1 SHL
|	I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent


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APPENDIX B - TRRC FORMS Rattlesnake AG I #1

APPENDIX B-l: UIC CLASS II ORDER

APPENDIX B-2: GAU GROUNDWATER PROTECTION DETERMINATION
APPENDIX B-3: DRILLING PERMIT
APPENDIX B-4: COMPLETION REPORT


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Christi Craddick, Chairman
Ryan Sitton, Commissioner
Wayne Christian, Commissioner

B-1

Danny Sorrells
Assistant Executive Director
Director, Oil and Gas Division
Leslie Savage

Assistant Director, Technical Permitting

Railroad Commission of Texas

OIL AND GAS DIVISION

PERMIT TO DISPOSE OF NON-HAZARDOUS OIL AND GAS WASTE BY INJECTION INTO A
POROUS FORMATION NOT PRODUCTIVE OF OIL AND GAS

PERMIT NO. 15848

SANTA FE MIDSTREAM PERMIAN LLC
5830 GRANITE PKWY STE 1025
PLANO, TX 75024

DOCKET NO. 8A-0312019

Authority is granted to inject Non-Hazardous Oil and Gas waste into the well identified herein in accordance
with Statewide Rule 9 of the Railroad Commission of Texas and based on information contained in the
application (Form W-14) dated March 12, 2018 for the permitted interval of the DEVONIAN formation and
subject to the following terms and special conditions:

RATTLESNAKE AGI (000000) LEASE

WASSON FIELD

YOAKUM COUNTY, DISTRICT 8A

WELL II

DENTIFIC ATION AND P]

ERMIT PA]

RAMET]

ERS:

Well No.

API No.

UIC Number

Permitted
Fluids

Top
Interval
(feet)

Bottom
Interval
(feet)

Maximum
Liquid
Daily
Injection
Volume
(BBL/day)

Maximum
Gas Daily
Injection
Volume
(MCF/day)

Maximum
Surface
Injection
Pressure
for Liquid
(PSIG)

Maximum
Surface
Injection
Pressure
for Gas
(PSIG)

1

50136998

000117143

C02, and
H2S

11,000

12,000

4,500

N/A

N/A

2,200

SPECIAL CONDITIONS:

Well No.

API No.

Special Conditions

1

50136998

1.	Open hole completions shall have a plug back depth no deeper than the bottom of the
permitted injection interval.

2.	The operator shall provide to the UIC section an annotated electric log, and a mud log if
available, of the subject well with the top(s) and bottom(s) of the permitted formation
indicated on the log. Top and bottom of the authorized injection interval may be modified
based on electric log or mud log indications of the top and bottom of the permitted
formations.

1701 NORTH CONGRESS AVENUE * POST OFFICE BOX 12967 * AUSTIN. TEXAS 78711-2967 * PHONE: 512/463-6792* FAX: 512/463-6780
TDD 800/735-2989 OR TDY 512/463-7284 * AN EQUAL OPPORTUNITY EMPLOYER* http://www.rrc.texas.gov


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STANDARD CONDITIONS:

1.	Injection must be through tubing set on a packer. The packer must be set no higher than 100 feet above the
top of the permitted interval.

2.	The District Office must be notified 48 hours prior to:

a.	running tubing and setting packer;

b.	beginning any work over or remedial operation;

c.	conducting any required pressure tests or surveys.

3.	The wellhead must be equipped with a pressure observation valve on the tubing and for each annulus.

4.	Prior to beginning injection and subsequently after any work over, an annulus pressure test must be
performed. The test pressure must equal the maximum authorized injection pressure or 500 psig, whichever
is less, but must be at least 200 psig. The test must be performed, and the results submitted in accordance
with the instructions of Form H-5.

5.	The injection pressure and injection volume must be monitored at least monthly and reported annually on
Form H-10 to the Commission's Austin office.

6.	Within 30 days after completion, conversion to disposal, or any work over which results in a change in well
completion, a new Form W-2 or G-l must be filed to show the current completion status of the well. The
date of the disposal well permit, and the permit number must be included on the new Form W-2 or G-l.

7.	Written notice of intent to transfer the permit to another operator by filing Form P-4 must be submitted to
the Commission at least 15 days prior to the date of the transfer.

8.	This permit will expire when the Form W-3, Plugging Record, is filed with the Commission. Furthermore,
permits issued for wells to be drilled will expire three (3) years from the date of the permit unless drilling
operations have commenced.

Provided further that, should it be determined that such injection fluid is not confined to the approved interval, then
the permission given herein is suspended and the disposal operation must be stopped until the fluid migration from
such interval is eliminated. Failure to comply with all of the conditions of this permit may result in the operator
being referred to enforcement to consider assessment of administrative penalties and/or the cancellation of the
permit.

APPROVED AND ISSUED ON November 14. 2018.

Injection-Storage Permits Unit

IN-HOUSE AMENDMENT TO CORRECT THE RATE.

Note: This document will only be distributed electronically.

PERMIT NO. 15848
Page 2 of 2


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GROUNDWATER PROTECTION DETERMINATION
Groundwater Advisory Unit

Form GW-2

B-2

Date Issued:

31 August 2017

GAU Number:

179154

Attention:

SANTA FE MIDSTREAM

API Number:





5700 GRANITE PARKWAY

County:

YOAKUM



PLANO, TX 75024

Lease Name:

Roberts Unit

Operator No.:

748093

Lease Number:

Well Number:

Total Vertical Depth:
Latitude:

Longitude:

Datum:

019212
1

11000
33.049990
-102.903464
NAD27

Purpose:

New Drill





Location:

Survey-Gibson, J H/Poole, J T; Block-D; Section-733



To protect usable-quality groundwater at this location, the Groundwater Advisory Unit of the Railroad Commission of
Texas recommends:

The interval from the land surface to a depth of 375 feet must be protected.

Note: Unless stated otherwise, this recommendation is intended to apply only to the subject well and not for area-wide use.
This recommendation is for normal drilling, production, and plugging operations only. It does not apply to saltwater disposal
operation into a nonproductive zone (RRC Form W-14).

This determination is based on information provided when the application was submitted on 08/30/2017. If the location
information has changed, you must contact the Groundwater Advisory Unit, and submit a new application if necessary.
If you have questions, please contact us at 512-463-2741 orgau@rrc.texas.gov.

Groundwater Advisory Unit, Oil and Gas Division

Form GW-2 P.O. Box 12967 Austin, Texas 78771-2967 512-463-2741 Internet address: www.rrc.texas.gov
Rev. 02/2014


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APINa 42-501-36998

RAILROAD COMMISSION OF TEXAS
OIL & GAS DIVISION

APPLICATION FOR PERMIT TO DRILL, RECOMPLETE, OR RE-ENTER

This facsimile W-l was generated electronically from data submitted to the RRC.

A certification of the automated data is available in the RRC's Austin office.

FORM W-l 07/2004

Drilling Permit #

839303

SWR Exception Case/Docket No.

Permit Status: Approved

B-3

1. RRC Operator No.

748093

2. Operator's Name (as shown on form P-5, Organization Report)

SANTA FE MIDSTREAM PERMIAN LLC

3. Operator Address (include street, city, state, zip):

5830 GRANITE PKWY STE 1025
PLANO, TX 75024-0000

4. Lease Name

RATTLESNAKE AGI

5. Well No.

1

GENERAL INFORMATION

6. Purpose of filing (mark ALL appropriate boxes): Ix] New Drill EH Recompletion EH Reclass EH Field Transfer EH Re-Enter

EH Amended EH Amended as Drilled (BHL) (Also File Form W-1D)

7. Wellbore Profile (mark ALL appropriate boxes): 0 Vertical EH Horizontal (Also File Form W-1H) EH Directional (Also File Form W-1D) EH Sidetrack

8. Total Depth

12000

9. Do you have the right to develop the [x] - | |
minerals under any right-of-way ?

10. Is this well subject to Statewide Rule 36 (hydrogen sulfide area)? IS Yes EH \0

SURFACE LOCATION AND ACREAGE INFORMATION

11. RRC District No.

8A

12. County I—, ,—, ,—, ,—¦

YOAKUM 13. Surface Location LXI Land 1—1 Bay/Estuary 1—1 Inland Waterway 1—1 Offshore

14. This well is to be located miles in a NW direction from DENVER CITY which is the nearest town in the county of the well site.

15. Section 16. Block 17. Survey 18. Abstract No.

733 D GIBSON, J H A-89

19. Distance to nearest lease line:

200 ft-

20. Number of contiguous acres in

lease, pooled unit, or unitized tract: 640

21.	Lease ]

22.	Survey

'erpendiculars: 200 ft from the NORTH line and 200 ft froi

nt
nt

ie WEST line.



PprppiiHii^iilars" 200 ft from the NORTH line and 200 ft froi

le WEST line.

23. Is this a pooled unit? EH Yes B No 24. Unitization Docket No:

25. Are you applying for Substandard Acreage Field? EH Yes (attach Form W-1A) S No

FIELD INFORMATION List all fields of anticipated completion including Wildcat. List one zone per line.

26. RRC
District No.

27. Field No.

28. Field Name (exactly as shown in RRC records)

29. Well Type

30. Completion Depth

31. Distance to Nearest
Well in this Reservoir

32. Number of Wells on
this lease in this
Reservoir

8A

95397001

WASSON

Injection Well

12000

0.00

1

8A

95399400

WASSON, NORTH (SAN ANDRES)

Injection Well

12000

0.00

1





























BOTTOMHOLE LOCATION INFORMATION is required for DIRECTIONAL, HORIZONTAL, AND AMENDED AS DRILLED PERMIT APPLICATIONS

Remarks

[FILER Apr 16, 2018 5:16 PM]: Filing for an acid gas injection well.

Certificate:

I certify that information stated in this application is true and complete, to the
best of my knowledge.

Jessica Risien, Regulatory Compliance

Specialist Apr 25, 2018

Name of filer Date submitted

(281)8729300 jrisien@ntglobal.com

Phone E-mail Address (OPTIONAL)

RRC Use Only Data Validation Time Stamp: Apr 27, 2018 10:36 AM( As Approved' Version )

Page 1 of 1


-------
NOTE: Acreages shown hereon ere based on Information provided by others.

This plat represents a staked well location and does not represent a boundary survey.
The Information shown does not meet the current TBPLS minimum standards for boundary
surveys. Limited field measurements were acquired. Lease and tract line Information is
compiled from record information and additional sources.

NOTES:

1)

2)

3-J

ALL BEARINGS. DISTANCES ANO COORDINATES SHOWN
HEREON WERE DERIVED FROM <3. P S. OBSERVATIONS
CONVERTED TO THE TEXAS COORDINATE SYSTEM,
NORTH CENTRAL ZONE (NAD 1993). US FOOT AND ARE
REFERENCED TO THE LOCAL GNSS RTK NETWORK.
THE PROPOSED WELL LOCATION IS SITUATED N 37~W -
7.3 MILES FROM DENVER CITY, TX.

THE PROPOSED WELL LOCATION IS SITUATED SOW FROM
THE NSL AND 200 FROM THE WSL.

6

5°X'

rC-< liw



SECTION 704. BLOCK D
J. H. GIBSON SURVEY-
ABSTRACT NO. 1144
YOAKUM COUNTY. TX

704

733

RA TTLESMAKE AGf No.
(PROPOSED)

.0^

SURFACE L OCA T/ON
NAD 83, TX-NC, U.S. FT.
NORTH/NG/Y; 7093713.4ST
EASTING/X 619409-13"

LATITUDE (DDJ- 33.05134722°
LONGITUDE (DO)- -102.90450555*

NAD 27, TX-NC, US- FT,
NORTHfNG/Y: 546285.34*
EAST/NG/X; 344968.61'

LA TTTUDE (DO)- 33.05124473"
LONGITUDE (DO)- -102.90401331°
SURFACEELEVA T/ON- 3627.05-

732

*

83^8

2

5>^0
S



Af /=>&?AfMA/LLG
rtATTL£SA/j4/C£-s4G/A/o. 7
*/.M. G/&SOA/ SURWEK
SEGT/OA/ 733, &LOC/C0
yOAKt/AS GCHSA/TX TjEXAS

m	Y aHcmws80i*a,7x:7B>

IhtebkityRk

i ] Positions, llc


-------
Railroad Commission of Texas

PERMIT TO DRILL, RE-COMPLETE, OR RE-ENTER ON REGULAR OR ADMINISTRATIVE EXCEPTION LOCATION

CONDITIONS AND INSTRUCTIONS

Permit Invalidation. It is the operator's responsibility to make sure that the permitted location complies with Commission density and
spacing rules in effect on the spud date. The permit becomes invalid automatically if, because of a field rule change or the drilling of another
well, the stated location is not in compliance with Commission field rules on the spud date. If this occurs, application for an exception to
Statewide Rules 37 and 38 must be made and a special permit granted prior to spudding. Failure to do so may result in an allowable not being
assigned and/or enforcement procedures being initiated.

Notice Requirements. Per H.B 630, signed May 8,2007, the operator is required to provide notice to the surface owner no later than the
15th business day after the Commission issues a permit to drill. Please refer to subchapter Q Sec. 91.751-91.755 of the Texas Natural
Resources Code for applicability.

Permit expiration. This permit expires two (2) years from the date of issuance shown on the original permit. The permit period will not
be extended.

Drilling Permit Number. The drilling permit number shown on the permit MUST be given as a reference with any notification to the
district (see below), correspondence, or application concerning this permit.

Rule 37 Exception Permits. This Statewide Rule 37 exception permit is granted under either provision Rule 37 (h)(2)(A) or 37(h)(2)(B).
Be advised that a permit granted under Rule 37(h)(2)(A), notice of application, is subject to the General Rules of Practice and Procedures
and if a protest is received under Section 1.3, "Filing of Documents," and/or Section 1.4, "Computation of Time," the permit may be deemed
invalid.

Before Drilling

Fresh Water Sand Protection. The operator must set and cement sufficient surface casing to protect all usable-quality water, as defined by
the Railroad Commission of Texas (RRC) Groundwater Advisory Unit (GWAU). Before drilling a well, the operator must obtain a letter from
the Railroad Commission of Texas stating the depth to which water needs protection, Write: Railroad Commission of Texas, Groundwater
Advisory Unit (GWAU), P.O. Box 12967, Austin, TX 78711-3087. File a copy of the letter with the appropriate district office.

Accessing the Well Site. If an OPERATOR, well equipment TRANSPORTER or WELL service provider must access the well site from a
roadway on the state highway system (Interstate, U.S. Highway, State Highway, Farm-to-Market Road, Ranch-to-Market Road, etc.), an
access permit is required from TxDOT. Permit applications are submitted to the respective TxDOT Area Office serving the county where the
well is located.

Water Transport to Well Site. If an operator intends to transport water to the well site through a temporary pipeline laid above
ground on the state's right-of-way, an additional TxDOT permit is required. Permit applications are submitted to the respective
TxDOT Area Office serving the county where the well is located.

^NOTIFICATION

The operator is REQUIRED to notify the district office when setting surface casing, intermediate casing, and production casing, or when
plugging a dry hole. The district office MUST also be notified if the operator intends to re-enter a plugged well or re-complete a well into a
different regulatory field. Time requirements are given below. The drilling permit number MUST be given with such notifications.

During Drilling

Permit at Drilling Site : A copy of the Form W-l Drilling Permit Application, the location plat, a copy of Statewide Rule 13
alternate surface casing setting depth approval from the district office, if applicable, and this drilling permit must be kept at the
permitted well site throughout drilling operations.

*Notification of Setting Casing : The operator MUST call in notification to the appropriate district office (phone number shown the
on permit) a minimum of eight (8) hours prior to the setting of surface casing, intermediate casing, AND production casing. The
individual giving notification MUST be able to advise the district office of the drilling permit number.

*Notification of Re-completion/Re-entry : The operator MUST call in notification to the appropriate district office (phone number
shown on permit) a minimum of eight (8) hours prior to the initiation of drilling or re-completion operations. The individual giving
notification MUST be able to advise the district office of the drilling permit number.

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 1 of 5


-------
Completion and Plugging Reports

Hydraulic Fracture Stimulation using Diesel Fuel: Most operators in Texas do not use diesel fuel in hydraulic fracturing fluids.

Section 322 of the Energy Policy Act of 2005 amended the Underground Injection Control (UIC) portion of the federal Safe Drinking Water
Act (42 USC 300h(d)) to define "underground Injection" to EXCLUDE " ...the underground injection of fluids or propping agents (other
than dieselfluels) pursuant to hydraulic fracturing operations related to oil, gas, or geothermal production activities." (italic and underlining
added.) Therefore, hydraulic fracturing may be subject to regulation under the federal UIC regulations if diesel fuel is injected or used as a
propping agent. EPA defined "diesel fuel" using the following five (5) Chemical Abstract Service numbers: 68334-30-5 Primary Name: Fuels,
diesel; 68476-34-6 Primary Name: Fuels, diesel, No. 2; 68476-30-2 Primary Name: Fuel oil No. 2; 68476-31-3 Primary Nmae: Fuel oil, No.
4; and 8008-20-6 Primary Name: Kerosene. As a result, an injection well permit would be required before performing hydraulic fracture
stimulation using diesel fuel as defined by EPA on any well in Texas. Hydraulic fracture stimulation using diesel fuel as defined by EPA on a
well in Texas without an injection well permit could result in enforcement action.

Producing Well: Statewide Rule 16 states that the operator of a well shall file with the Commission the appropriate completion report
within thirty (30) days after completion of the well or within ninety (90) days after the date on which the drilling operation is completed,
whichever is earlier. Completion of the well in a field authorized by this permit voids the permit for all other fields included in the permit
unless the operator indicates on the initial completion report that the well is to be a dual or multiple completion and promptly submits an
application for multiple completion. All zones are required to be completed before the expiration date on the existing permit. Statewide Rule
40(d) requires that upon successful completion of a well in the same reservoir as any other well previously assigned the same acreage,
proration plats and P-15s (if required) must be submitted with no double assignment of acreage.

Dry or Noncommercial Hole : Statewide Rule 14(b)(2) prohibits suspension of operations on each dry or non-commercial well without
plugging unless the hole is cased and the casing is cemented in compliance with Commission rules. If properly cased, Statewide Rule 14(b)(2)
requires that plugging operations must begin within a period of one (1) year after drilling or operations have ceased. Plugging operations must
proceed with due diligence until completed. An extension to the one-year plugging requirement may be granted under the provisions stated in
Statewide Rule 14(b)(2).

Intention to Plug : The operator must file a Form W-3 A (Notice of Intention to Plug and Abandon) with the district office at least five (5)
days prior to beginning plugging operations. If, however, a drilling rig is already at work on location and ready to begin plugging operations,
the district director or the director's delegate may waive this requirement upon request, and verbally approve the proposed plugging
procedures.

*Notification of Plugging a Dry Hole : The operator MUST call in notification to the appropriate district office (phone number shown on
permit) a minimum of four (4) hours prior to beginning plugging operations. The individual giving the notification MUST be able to advise
the district office of the drilling permit number and all water protection depths for that location as stated in the Texas Commission on
Environmental Quality letter.

DIRECT INQUIRIES TO: DRILLING PERMIT SECTION, OIL AND GAS DIVISION

PHONE
(512) 463-6751

MAIL:

PO Box 12967
Austin, Texas, 78711-2967

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 2 of 5


-------
RAILROAD COMMISSION OF TEXAS
OIL & GAS DIVISION

PERMIT TO DRILL, DEEPEN, PLUG BACK, OR RE-ENTER ON A REGULAR OR ADMINISTRATIVE EXCEPTION LOCATION

PERMIT NUMBER

839303

DATE PERMIT ISSUED OR AMENDED
04/27/2018

DISTRICT

8A

API NUMBER

42-501-36998

FORM W-l RECEIVED

04/25/2018

COUNTY

YOAKUM

TYPE OF OPERATION

New Drill

WELLBORE PROFILE(S)

Vertical

ACRES

640.0

OPERATOR 748093
SANTA FE MIDSTREAM PERMIAN LLC

5830 GRANITE PKWY STE 1025
PLANO, TX 75024-0000

NOTICE

This permit and any allowable assigned may
be revoked if payment for fee(s) submitted to
the Commission is not honored.
District Office Telephone No:

(806) 698-6509

LEASE NAME

RATTLESNAKE AGI

WELL NUMBER

1

LOCATION

7.3 miles NW direction from DENVER CITY

TOTAL DEPTH

12000

Section, Block and/or

SECTION 733 BLOCK D ABSTRACT 89
SURVEY GIBSON, J H

DISTANCE TO SURVEY LINES

200.0 ft NORTH 200.0 ft WEST

DISTANCE TO NEAREST LEASE LINE
200.0

DISTANCE TO LEASE LINES

200.0 ft NORTH 200.0 ft WEST

DISTANCE TO NEAREST WELL ON LEASE
See FIELD(s) Below

FIELD(s) and LIMITATIONS:

* SEE FIELD DISTRICT FOR REPORTING PURPOSES *

FIELDNAME	ACRES	DEPTH WELL#	DIST

LEASE NAME	NEAREST LEASE	NEAREST WELL

WASSON	"640!0	12000	1	8A

RATTLESNAKE AGI	200 0	0.0

This is a hydrogen sulfide field. This well shall be drilled in accordance with SWR 36.

Do not use this well for injection/disposal/hydrocarbon storage purposes without approval by the Environmental Services section of the Railroad Commission,
Austin, Texas office.

WASSON, NORTH (SAN ANDRES)	"64o!o	12000	1	8A

RATTLESNAKE AGI	200.0	0.0

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 3 of 5


-------
This is a hydrogen sulfide field. This well shall be drilled in accordance with SWR 36.

Do not use this well for injection/disposal/hydrocarbon storage purposes without approval by the Environmental Services section of the Railroad Commission,
Austin, Texas office.

THE FOLLOWING RESTRICTIONS APPLY TO ALL FIELDS
This well shall be completed and produced in compliance with applicable special field or statewide spacing and density rules. If this well is
to be used for brine mining, underground storage of liquid hydrocarbons in salt formations, or underground storage of gas in salt formations,
a permit for that specific purpose must be obtained from Environmental Services prior to construction, including drilling, of the well in
accordance with Statewide Rules 81, 95, and 97.

This well must comply to the new SWR 3.13 requirements concerning the isolation of any potential flow zones and zones with corrosive
formation fluids. See approved permit for those formations that have been identified for the county in which you are drilling the well in.

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 4 of 5


-------
Railroad Commission of Texas

Oil and Gas Division

SWR #13 Formation Data
YOAKUM (501) COUNTY

l-'oniiiilioii

Koniiirks

Order

I.ITcc(i\c
Diilo

RED BED-SANTA ROSA



1

01/01/2014

YATES



2

01/01/2014

SAN ANDRES

high flows, H2S, corrosive

3

01/01/2014

GLORIETA



4

01/01/2014

CLEARFORK

Active C02 Flood

5

01/01/2014

WICHITA



6

01/01/2014

LEONARD



7

01/01/2014

WOLFCAMP



8

01/01/2014

PENNSYLVANIAN



9

01/01/2014

STRAWN



10

01/01/2014

MISSISSIPPIAN



11

01/01/2014

DEVONIAN



12

01/01/2014

DEVONIAN-SILURIAN



13

01/01/2014

The above list may not be all inclusive, and may also include formations that do not intersect all wellbores. The listing order of the Formation
information reflects the general stratigraphic order and relative geologic age. This is a dynamic list subject to updates and revisions. It is the
operator's responsibility to make sure that at the time of spudding the well the most current list is being referenced. Refer to the RRC website
at the following address for the most recent information, http://www.rrc.texas.gov/oil-gas/compliance-enforcement/rule-13-geologic-
formation-info

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 5 of 5


-------
B-4

RAILROAD COMMISSION OF TEXAS	Form G-1

1701 N. Congress	Status:	Approved

P.O. Box 12967	Date:	07/25/2019

Austin, Texas 78701-2967	Tracking No.:	205926

GAS WELL BACK PRESSURE TEST, COMPLETION OR RECOMPLETION REPORT, AND LOG

OPERATOR INFORMATION

Operator Name: santa fe midstream permian llc	Operator No.: 748093

Operator Address: 5830 granite pkwy ste 1025 plano, tx 75024-0000

WELL INFORMATION

API No.: 42-501-36998

County: YOAKUM

Well No.: 1

RRC District No.: 8A

Lease Name: RATTLESNAKE AG I

Field Name: WASSON

RRC Gas ID No.: 286838

Field No.: 95397001

Location: Section: 733, Block: D, Survey: GIBSON, J H, Abstract: 89



Latitude:

Longitude:

This well is located 7.3 miles in a nw



direction from Denver city,



which is the nearest town in the county.



FILING INFORMATION

Purpose of filing: Well Record Only



Type of completion: New Well



Well Type: Active UIC

Completion or Recompletion Date: 08/31/2018

Type of Permit

Date Permit No.

Permit to Drill, Plug Back, or Deepen

04/27/2018 839303

Rule 37 Exception



Fluid Injection Permit



O&G Waste Disposal Permit

11/14/2018 15848

Other:



COMPLETION INFORMATION

ISpud date: 07/16/2018

Date of first production after rig released: 08/31/2018 I

Date plug back, deepening, recompletion, or Date plug back, deepening, recompletion, or

drilling operation commenced: 07/16/2018

drilling operation ended: 08/31/2018

Number of producing wells on this lease in

Distance to nearest well in lease &

this field (reservoir) including this well:

1 reservoir (ft.): 0.0

Total number of acres in lease: 640.00

Elevation (ft.): 3627 GR

Total depth TVD (ft.): 11980

Total depth MD (ft.):

Plug back depth TVD (ft.): 11980

Plug back depth MD (ft.):

Was directional survey made other than

Rotation time within surface casing (hours): 72.0

inclination (Form W-12)? Yes

Is Cementing Affidavit (Form W-15) attached? Yes

Recompletion or reclass? No

Multiple completion? No

Type(s) of electric or other log(s) run: Combo of Induction/Neutron/Density/Sonic

Electric Log Other Description:



Location of well, relative to nearest lease boundaries Off Lease: No

of lease on which this well is located:

200.0 Feet from the North Line and



200 0 Feet from the West Line of the



rattlesnake agi Lease.

FORMER FIELD (WITH RESERVOIR) & GAS ID OR OIL LEASE NO.

Field & Reservoir

Gas ID or Oil Lease No. Well No. Prior Service Type



Page 1 of4


-------
G1:	N/A

PACKET:	N/A

FOR NEW DRILL OR RE-ENTRY, SURFACE CASING DEPTH DETERMINED BY:
GAU Groundwater Protection Determination	Depth (ft.): 2025.0	Date: 01/12/2018

SWR 13 Exception	Depth (ft.):

GAS MEASUREMENT DATA

I Date of test: Gas measurement method(s):





Gas production during test (MCF):







Was the well preflowed for 48 hours? No







Orif. or 24 hr. Coeff.

Run Line Choke Orif. Or Choke Static Pm or Diff
No. size Size (in.) (in.) Choke (in.) (hw)

Flow

Temp Temp. Gravity
(°F) (l-tt) (hg)

Compress
(Fpv)

Volume
(MCF/day)

N/A







FIELD DATA AND PRESSURE CALCULATIONS

Gravity (dry gas):

Gas-Liquid Hydro Ratio (CF/Bbl):

Avg. shut in temp. (°F):

Gravity (liquid hydrocarbons) (Deg. API):

Gravity (mixture): Gmix=

Bottom hole temp, and depth: °F@ ft

Run No. Time of Run (Min.)

Choke Size (in.) Wellhead Pressure (PSIA) Wellhead Flow Temp (°F )

N/A



CASING RECORD

Casing Hole Setting Multi - Multi -	Cement Slurry Top of TOC

Type of

Size

Size

Depth Stage Tool Stage Shoe Cement Amount Volume Cement Determined

Row Casing

(in.)

(in.)

(ft.)

Depth (ft.) Depth (ft.)

Class

(sacks)

(cu. ft.)

(ft.)

By

1 Surface

13 3/8

17 1/2

504



c

510

687.5

0

Circulated to Surface

3 Intermediate

9 5/8

12 1/4

5498

5498

c

485

797.0

4275

Circulated to Surface

2 Intermediate

13 3/8

17 1/2

5498

4275

c

1650

3045.0

0

Circulated to Surface

6 Conventional Production

7

8 3/4

11023



WELL

60

337.0

9575

Calculation











LOCK









5 Conventional Production

7

8 3/4

11023

5591

PREM

380

906.5

0

Circulated to Surface











PLUS









4 Conventional Production

7

8 3/4

11023

9575

PREM

380

906.5

5591

Calculation











PLUS









LINER RECORD









Cement

Slurry

Top of

TOC

Liner Hole

Liner

Liner

Cement

Amount

Volume

Cement

Determined

Row Size (in.) Size (in.)

Top (ft.)

Bottom (ft.)

Class

(sacks)

(cu. ft.)

(ft.)

By

N/A















TUBING RECORD

Row

Size (in.)

Depth Size (ft.)

Packer Depth (ft.)/Type

1

3 1/2

10966

10966 / HALLIBURTON







BWD

PRODUCING/INJECTION/DISPOSAL INTERVAL

Row

Open hole?

From (ft.)

To (ft.)

1

Yes

L 11025

11980

Page 2 of4


-------
ACID, FRACTURE, CEMENT SQUEEZE,

CAST IRON BRIDGE PLUG, RETAINER, ETC.

Was hydraulic fracturing treatment performed? No

Is well equipped with a downhole actuation



sleeve? No

If yes, actuation pressure (PSIG):

Production casing test pressure (PSIG) prior to

Actual maximum pressure (PSIG) during hydraulic

hydraulic fracturing treatment:

fracturing:

Has the hydraulic fracturing fluid disclosure been



reported to FracFocus disclosure registry (SWR29)?

No

Row Type of Operation Amount and Kind of Material Used Depth Interval (ft.)

N/A



FORMATION RECORD

Is formation

Formations	Encountered Depth TVD (ft.) Depth MP (ft.) isolated? Remarks

YATES

Yes

3019.0

Yes



SAN ANDRES - HIGH FLOWS, H2S,

Yes

4465.0

Yes



CORROSIVE









GLORIETA

Yes

6316.0

Yes



CLEARFORK - ACTIVE C02 FLOOD

Yes

6492.0

Yes



WICHITA

Yes

8628.0

Yes



UPPER WOLFCAMP

Yes

9239.0

Yes



STRAWN

Yes

10030.0

Yes



ATOKA

Yes

10230.0

Yes



WOODFORD

Yes

10973.0

Yes



DEVONIAN

Yes

11036.0

No

DISPOSAL

WRISTEN

Yes

11268.0

No

DISPOSAL

FUSSELMAN

Yes

11538.0

No

DISPOSAL

MONTOYA

Yes

11974.0

No

DISPOSAL

RED BED-SANTA ROSA

No



No

NOT IN AREA

LEONARD

No



No

NOT IN AREA

WOLFCAMP

No



No

NOT IN AREA

PENNSYLVANIAN

No



No

NOT IN AREA

STRAWN

No



No

NOT IN AREA

MISSISSIPPIAN

No



No

NOT IN AREA

Do the producing interval of this well produce H2S with a concentration in excess of 100 ppm (SWR 36)?	No

s the completion being downhole commingled (SWR 10)?	No

REMARKS

NEW WELL PUTTING ON SCHEDULE.

Page 3 of4


-------
OPERATOR'S CERTIFICATION

Printed Name: Karen Zornes

Title:

Telephone No.: (281) 872-9300

Date Certified: 06/25/2019

Page 4 of4


-------
APPENDIX C - GAS COMPOSITION


-------
C-1

1 rv » n,,

natural Gas Analysis

www.permianls.com
575.397.3713 2609 W Marland HobbS NM 88240

11093G

30/30 Acid Gas

Sample Point Code

Sample Point Name

C6+ Gas Analysis Report

30/30 Acid Gas

Sample Point Location

Laboratory Services

Date Sampled

2021048523

1781

E Benavides - Spot

Source Laboratory



Lab File No

Container Identity

Sampler

USA

USA



USA

Texas

District

Area Name



Field Name

Facility Name

Nov 16, 2021



Nov 16, 2021

Nov 19, 2021 09:59

Nov 19, 2021

Date Effective

System Administrator

Ambient Temp (°F)

Flow Rate (Mcf)

Analyst

Date Received

21 @ 129

Press PSI @ Temp °F
Source Conditions

Date Reported

Stakeholder Midstream

30/30

Operator

Lab Source Description

Component

Normalized
Mol %

Un-Normalized
Mol %

GPM

H2S (H2S)

9.2000

9.2



Nitrogen (N2)

0.0000

0



C02 (C02)

89.6780

98.775



Methane (CI)

0.3030

0.331



Ethane (C2)

0.0580

0.063

0.0150

Propane (C3)

0.1080

0.118

0.0300

I-Butane (IC4)

0.0000

0

0.0000

N-Butane (NC4)

0.0250

0.027

0.0080

I-Pentane (IC5)

0.0000

0

0.0000

N-Pentane (NC5)

0.0000

0

0.0000

Hexanes Plus (C6+)

0.6280

0.686

0.2710

TOTAL

100.0000

109.2000

0.3240

Method(s): Gas C6+ - GPA 2261, Extended Gas - GPA 2286, Calculations - GPA 2172

Analyzer Information
Device Type: Gas Chromatograph Device Make: Shimadzu
Device Model: GC-2014	Last Cal Date: Nov 14, 2021

Gross Heating Values (Real, BTU/ft3)

14.696 PSI @ 60.00 A°F	14.65 PSI @ 60.00 A°F

Dry	Saturated	Dry	Saturated

98.7	98.00	98.4	97.7

Calculated Total Sample Properties

GPA2145-16 Calculated at Contract Conditions
Relative Density Real	Relative Density Ideal

1.5042	1.4956

Molecular Weight

43.3157

C6 - 60.000%

C6+ Group Properties

Assumed Composition

C7 - 30.000%

C8 - 10.000%

Field H2S

92000 PPM

PROTREND STATUS:	DATA SOURCE:

Passed By Validator on Nov 21, 2021 Imported

PASSED BY VALIDATOR REASON:

Close enough to be considered reasonable.

VALIDATOR:

Dustin Armstrong

VALIDATOR COMMENTS:

OK

Nov 22, 2021 7:57 a

Powered By ProTrend -www.criticalcontrol.com

Page 1 of 1


-------
APPENDIX D - MONITORING AREA MAPS

APPENDIX D-l: MMA MAP
APPENDIX D-2: AMA MAP


-------
A-1143

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& Stabilized Plume
with

1/2-Mile Maximum Monitoring Area (MMA)

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN • HOUSTON jfc CALGARY • WICHITA
DENVER • COLLEGE STATION T BATON ROUGE • EDMONTON

Rattlesnake AGI No. 1 SHL

I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

1560


-------
A-1143

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& 19-Year Plume
with

1/2-Mile Active Monitoring Area (AMA)

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

1560


-------
APPENDIX E - FACILITY SAFETY PLOT PLANS


-------
PLANT NORTH

LEGEND

•

FIRE EXTINGUISHER

~

SCBA/ESCAPE PACK

~

WIND SOCK

®

LEL/H2S MONITOR



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NO.

05/11 / 22
DATE

INITIAL RELEASE K C V 1 C V V
REVISION DESCRIPTION

KLD
BY

BEC
FCE

JB
CLIENT

CHAR1S ENGINEERING. LLC
"IX ENG. FIRM NO. F-1B8B4
MIDLAND. IX

STAKEHOLDER
MIDSTREAM

CLIENT ;

PROJECT ;

TITLE :

STAKEHOLDER MIDSTREAM

30-30 GAS PLANT

SAFETY EQUIPMENT PLOT PLAN

1" = 50'—0"

DATE

5/11/22

ME—PLNP—AOOO—0004

A


-------
APPENDIX F - MMA/AMA REVIEW MAPS

APPENDIX F-l: PLUME BOUNDARY AT END OF INJECTION, STABILIZED PLUME BOUNDARY AND MAXIMUM
MONITORING AREA MAP

APPENDIX F-2: ACTIVE MONITORING AREA MAP

APPENDIX F-3: OIL AND GAS WELLS WITHIN THE MMA MAP

APPENDIX F-4: OIL AND GAS WELLS WITHIN THE MMA LIST

APPENDIX F-5: INJECTION INTERVAL PENETRATING WELLS WITHIN THE MMA MAP

APPENDIX F-6: GROUNDWATER WELLS WITHIN THE MMA

APPENDIX F-7: WELLBORE SCHEMATICS FOR INJECTION INTERVAL PENETRATING WELLS


-------
A-1143

A-545

A-1866
A-572

A-£ 58

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& Stabilized Plume
with

1/2-Mile Maximum Monitoring Area (MMA)

Stakeholder Midstream
Yoakum Co., TX

A-1314

A-549

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY

1



ENGINEERS

ADVISORS



AUSTIN • HOUSTON jj

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

Rattlesnake AGI No. 1 SHL

I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

J Plume Boundary at End of Injection

1560


-------
A-1143

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& 19-Year Plume
with

1/2-Mile Active Monitoring Area (AMA)

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY

1



ENGINEERS

ADVISORS



AUSTIN • HOUSTON jj

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

F-2

Rattlesnake AGI No. 1 SHL

1 Active Monitoring Area Boundary

1 9-Year Plume

J Plume Boundary at End of Injection

Abstract

Note: All coordinates shown are in NAD83 (DD).

MAP EXTENT

~


-------
A-1866



A-1314

iiiiiiiiij

36998 l\

RATTLESNAKE AGI NO

33.0513499,1

-102.90450576

00000

32541

00261

32531

00000

iiiiiiiiii

00000"

00000

00262

000

\ 00645 •

00050

00643s

00644

00000

33349.

33530

00057

33173

32702

34984\

32065

00059

33172

33531

A-1484

33531'

32703

33351

32064

,00061

00000

00060

00058

32704

33 no 3

00065

00068

00064

^067 ^

32945

32975

32077

32075

: 30600

32076

36156

00267

00266

00066 3271 i

00063

02992

02991

02990

02989 35820

A-1816

34878

32070

36155

36151 30604 35791 30602

30606

JO fyy

36152

35821

30630

32072

36153

30601

30605

35794

35793 30598

36150

30603

36048

36154

35180

35703

35701

35705

30000

=3058.4;

32270

33065

1:34099;

00755

30583

30629

35961'

34797

56428 00000

• °l

36098

-34023 •

00768J

34124

30580

36327

33843

LONQUIST & CO LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN • HOUSTON jfc CALGARY • WICHITA
DENVER • COLLEGE STATION T BATON ROUGE • EDMONTON

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

+ Rattlesnake AC I No. 1 SHL
| ~ ~ ™ 1/2-Mile Buffer from Max. Plume Extent (MMA)
I ~ Z Z Z Combined Maximum Plume Extent
1	Stabilized Plume

I ~ ~ ~ Z Plume Boundary at End of Injection
Abstract

	Lateral (21)

API (42-501-...) SHL Status - Type (Count)
O Horizontal Surface Location (21)

•	Active - Oil (93)

Active - Injection/Disposal (21)

•» Active - Injection/Disposal from Oil (22)
X Plugged - Oil (69)

^ Plugged - Gas (1)

Plugged- Injection/Disposal from Oil (1)

Shut-In - Oil (1)

TA - Injection/Disposal (3)

TA - Injection/Disposal from Oil (7)

"0" Dry Hole (6)
o Permitted Location (2)
0 Canceled/Abandoned Location (6)
X Expired Permit (7)

API (42-501-...) BHL Status - Type (Count)

•	Active - Oil (11)

•A Active - Injection/Disposal from Oil (1)

Shut-In - Oil (1)

TA - Injection/Disposal from Oil (1)

o Permitted Location (4)

X Expired Permit (3)

Sou rce:

1.)	Oil/Cas Well SHL Data: DI-2022

2.)	Oil/Cas Well BHL Data: DI-2022

3.)	Oil/Cas Well Directional Data: DI-2022

* Note: All coordinates shown are in NAD83 (DD). *

Rattlesnake AGI No. 1
Maximum Monitoring Area
with

1/2-Mile MMA Oil/Gas Well
Area of Review

Stakeholder Midstream
Yoakum Co., TX

1

A-1531

A-1064

A-87

A-1483

A-1641

A-499

VI55 !

i .-1777

A


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

F-4

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250101829

DENVER UNIT

2215W

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5300

5300

2215W

4250101835

DENVER UNIT

2207

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5185

5185

2207

4250130914

DENVER UNIT

2222

OCCIDENTAL PERMIAN LTD.

Active - Oil





2222

4250101832

DENVER UNIT

2201W

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5190

5190

2201W

4250101826

DENVER UNIT

2203

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5250

5250

2203

4250101319

ROBERTS UNIT

4532W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5200

5200

4532W

4250130629

ROBERTS UNIT

4535

APACHE CORPORATION

Active - Oil

5280

5280

4535

4250130583

ROBERTS UNIT

4525

APACHE CORPORATION

Active - Oil

5286

5286

4525

4250101318

ROBERTS UNIT

4541

APACHE CORPORATION

TA - Injection/Disposal from Oil

5240

5240

4541

4250101889

ROBERTS UNIT

3614

APACHE CORPORATION

Plugged - Oil

5180

5180

3614

4250130598

Roberts Unit

3647

APACHE CORPORATION

Plugged - Oil

5281

5281

3647

4250130603

ROBERTS UNIT

3626

APACHE CORPORATION

Plugged - Oil

5289

5289

3626

4250102992

ROBERTS UNIT

3612W

APACHE CORPORATION

Plugged - Oil

5226

5226

3612W

4250100066

ROBERTS UNIT

3532

APACHE CORPORATION

Plugged - Oil

5231

5231

3532

4250101886

ROBERTS UNIT

3631

APACHE CORPORATION

Plugged - Oil





3631

4250101885

ROBERTS UNIT

3641

APACHE CORPORATION

Plugged - Oil

5212

5212

3641

4250100068

ROBERTS UNIT

3521

APACHE CORPORATION

Plugged - Oil

5225

5225

3521

4250100064

ROBERTS UNIT

3541

APACHE CORPORATION

Plugged - Oil

5264

5264

3541

4250102014

ROBERTS UNIT

2443

APACHE CORPORATION

Plugged - Oil

5226

5226

2443

4250100050

ROBERTS UNIT

1654

APACHE CORPORATION

Plugged - Oil

5198

5198

1654

4250133531

ROBERTS UNIT

2443A



Active - Injection/Disposal

5325

5325

2443A

4250133502

ROBERTS UNIT

2527A



Plugged - Oil

5308

5308

2527A

4250100000

C. A. ELLIOTT

6

AMERICAN LIBERTY OIL CO

Plugged - Oil

5229

5229

6

4250100000

C. A. ELLIOTT

7

AMERICAN LIBERTY AND ATLANTIC

Active - Oil

5182

5182

7

4250100000

GEO CLEVELAND

1

DELFERN OIL CO

Dry Hole

5071

5071

1

4250100000

JAMES H. LYNN

1614

AMERICAN LIBERTY

Active - Oil

5169

5169

1614

4250100000

J. H. LYNN

1634

AMERICAN LIBERTY

Active - Oil

5160

5160

1634

4250100000

A. T. MORRIS

1

ATLANTIC

Active - Oil

5235

5235

1

4250100000

A. T. MORRIS

2

AMERICAN LIBERTY OIL CO

Plugged - Oil

5179

5179

2

4250100000

W.J. CARPENTER

1642

AMERICAN LIBERTY OIL COMPANY

Plugged - Oil

5183

5183

1642

4250100000

E.S.SMITH

1

CREAT WESTERN FROD

Dry Hole

5216

5216

1

4250130607

ROBERTS UNIT

3546



Active - Oil





3546

4250135958

DENVER UNIT

2247

OCCIDENTAL PERMIAN LTD.

Active - Oil

2333

2333

2247

4250131542

DENVER UNIT

2229

SHELL OIL COMPANY

Dry Hole

2409

2409

2229

4250101320

ROBERTS UNIT

4543

APACHE CORPORATION

Active - Injection/Disposal from Oil

5120

5120

4543

4250137301

MILLER

8H

AMTEX ENERGY, INC.

Active - Oil

5157

5157

8H

4250137304

MILLER 732 C

10H

AMTEX ENERGY, INC.

Permitted Location

5157

5157

10H

4250137305

MILLER 732 D

11H

AMTEX ENERGY, INC.

Permitted Location

5157

5157

11H

4250101888

ROBERTS UNIT

3634W

APACHE CORPORATION

Plugged - Oil

5160

5160

3634W


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250101031

ROBERTS UNIT

3534W

APACHE CORPORATION

Plugged - Oil

5164

5164

3534W

4250101828

DENVER UNIT

2208

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5170

5170

2208

4250101032

ROBERTS UNIT

3544

APACHE CORPORATION

Plugged - Oil

5170

5170

3544

4250101841

DENVER UNIT

2206

OCCIDENTAL PERMIAN LTD.

TA - Injection/Disposal from Oil

5177

5177

2206

4250101842

ROBERTS UNIT

3643W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5180

5180

3643W

4250101035

ROBERTS UNIT

3533W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5180

5180

3533W

4250132704

ROBERTS UNIT

2615

APACHE CORPORATION

Active - Oil

5180

5180

2615

4250100261

ROBERTS UNIT

1643W

APACHE CORPORATION

Plugged - Oil

5180

5180

1643W

4250101323

ROBERTS UNIT

4542W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5182

5182

4542W

4250102989

ROBERTS UNIT

3642W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5182

5182

3642W

4250102991

ROBERTS UNIT

3622W

APACHE CORPORATION

Plugged - Oil

5185

5185

3622W

4250132417

MILLER

3

AMTEX ENERGY, INC.

Active - Oil

5186

5186

3

4250101025

ROBERTS UNIT

2613W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5188

5188

2613W

4250101887

ROBERTS UNIT

3644

APACHE CORPORATION

Active - Injection/Disposal from Oil

5189

5189

3644

4250101830

DENVER UNIT

2214WC

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5190

5190

2214WC

4250101103

ROBERTS UNIT

3621

APACHE CORPORATION

Plugged - Oil

5190

5190

3621

4250101024

ROBERTS UNIT

2623

APACHE CORPORATION

Plugged - Oil

5190

5190

2623

4250101023

ROBERTS UNIT

2622W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5190

5190

2622W

4250101022

ROBERTS UNIT

2632

APACHE CORPORATION

Active - Oil

5190

5190

2632

4250101019

ROBERTS UNIT

2621

APACHE CORPORATION

Active - Oil

5190

5190

2621

4250101030

ROBERTS UNIT

3524W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5193

5193

3524W

4250101829

DENVER UNIT

2205

OCCIDENTAL PERMIAN LTD.

TA - Injection/Disposal from Oil

5195

5195

2205

4250101836

DENVER UNIT

2213WC

OCCIDENTAL PERMIAN LTD.

TA - Injection/Disposal from Oil

5200

5200

2213WC

4250101833

DENVER UNIT

2202WC

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5200

5200

2202WC

4250134099

DENVER UNIT

2239WC

OCCIDENTAL PERMIAN LTD.

Dry Hole

5200

5200

2239WC

4250132717

ROBERTS UNIT

3531A

APACHE CORPORATION

TA - Injection/Disposal

5200

5200

3531A

4250101014

ROBERTS UNIT

2624W

APACHE CORPORATION

Plugged - Oil

5200

5200

2624W

4250101028

ROBERTS UNIT

3523

APACHE CORPORATION

Plugged - Oil

5205

5205

3523

4250101102

ROBERTS UNIT

3611

APACHE CORPORATION

Plugged - Oil

5206

5206

3611

4250101827

DENVER UNIT

2209W

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5210

5210

2209W

4250101015



2643

TEXACO INCORPORATED

Active - Injection/Disposal from Oil

5210

5210

2643

4250100266

ROBERTS UNIT

3522W

APACHE CORPORATION

Plugged - Oil

5211

5211

3522W

4250132632

MILLER

5

AMTEX ENERGY, INC.

Active - Oil

5213

5213

5

4250100057

ROBERTS UNIT

2512W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5213

5213

2512W

4250101890

ROBERTS UNIT

3624W

APACHE CORPORATION

Plugged - Oil

5214

5214

3624W

4250101033

ROBERTS UNIT

3543W

APACHE CORPORATION

Plugged - Oil

5215

5215

3543W

4250101012

ROBERTS UNIT

2634W

APACHE CORPORATION

Plugged- Injection/Disposal from Oil

5215

5215

2634W

4250101734

ROBERTS UNIT

2442

APACHE CORPORATION

Plugged - Oil

5215

5215

2442

4250101020

ROBERTS UNIT

2611W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5215

5215

2611W


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250100067

ROBERTS UNIT

3531

APACHE CORPORATION

Plugged - Oil

5216

5216

3531

4250101013

ROBERTS UNIT

2614W

APACHE CORPORATION

Plugged - Oil

5216

5216

2614W

4250101844

ROBERTS UNIT

3623W

APACHE CORPORATION

Plugged - Oil

5217

5217

3623W

4250131869

ROBERTS UNIT

A3534W

APACHE CORPORATION

Plugged - Oil

5220

5220

A3534W

4250102990

ROBERTS UNIT

3632W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5220

5220

3632W

4250100262

ROBERTS UNIT

1644W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5220

5220

1644W

4250132858

DENVER UNIT

2235

OCCIDENTAL PERMIAN LTD.

Shut-In - Oil

5225

5225

2235

4250100058

ROBERTS UNIT

2544W

APACHE CORPORATION

Plugged - Oil

5225

5225

2544W

4250130584

ROBERTS UNIT

4520

APACHE CORPORATION

Active - Oil

5230

5230

4520

4250130630

ROBERTS UNIT

3535

APACHE CORPORATION

Active - Oil

5230

5230

3535

4250100063

ROBERTS UNIT

3542W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5230

5230

3542W

4250132076

ROBERTS UNIT

3627

APACHE CORPORATION

Active - Oil

5230

5230

3627

4250100267

ROBERTS UNIT

3512W

APACHE CORPORATION

Plugged - Oil

5233

5233

3512W

4250101016

ROBERTS UNIT

2642W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5234

5234

2642W

4250134716

DENVER UNIT

2242

OCCIDENTAL PERMIAN LTD.

Active - Oil

5236

5236

2242

4250100061

ROBERTS UNIT

2524W

APACHE CORPORATION

Plugged - Oil

5238

5238

2524W

4250101021

ROBERTS UNIT

2633

APACHE CORPORATION

Plugged - Oil

5240

5240

2633

4250101011

ROBERTS UNIT

2644W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5241

5241

2644W

4250132541

FUTCH

1

AMTEX ENERGY, INC.

Active - Oil

5244

5244

1

4250101026

ROBERTS UNIT

2612W

APACHE CORPORATION

Plugged - Oil

5245

5245

2612W

4250100059

ROBERTS UNIT

2513W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5246

5246

2513W

4250132531

MILLER

4

AMTEX ENERGY, INC.

Plugged - Oil

5248

5248

4

4250132687

ROBERTS UNIT

2635

APACHE CORPORATION

Plugged - Oil

5248

5248

2635

4250131656

DENVER UNIT

2232WC

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5250

5250

2232WC

4250131791

DENVER UNIT

2231

SHELL OIL COMPANY

Canceled/Abandoned Location

5250

5250

2231

4250134118

DENVER UNIT

2238

OCCIDENTAL PERMIAN LTD.

Active - Oil

5250

5250

2238

4250101342

ROBERTS UNIT



APACHE CORPORATION

Plugged - Gas

5250

5250



4250132269

ROBERTS UNIT

3601

APACHE CORPORATION

Plugged - Oil

5250

5250

3601

4250101843

ROBERTS UNIT

3633W

APACHE CORPORATION

Plugged - Oil

5250

5250

3633W

4250130608

ROBERTS UNIT

3545

APACHE CORPORATION

Active - Oil

5250

5250

3545

4250132077

ROBERTS UNIT

3617

APACHE CORPORATION

Active - Oil

5250

5250

3617

4250134963

DENVER UNIT

2244WC

OCCIDENTAL PERMIAN LTD.

TA- Injection/Disposal

5251

5251

2244WC

4250100060

ROBERTS UNIT

2514

APACHE CORPORATION

Plugged - Oil

5251

5251

2514

4250101459

DENVER UNIT

2211

OCCIDENTAL PERMIAN LTD.

Active - Oil

5252

5252

2211

4250132521

DENVER UNIT

2233W

OCCIDENTAL PERMIAN LTD.

TA- Injection/Disposal from Oil

5253

5253

2233W

4250135211

DENVER UNIT

2241

OCCIDENTAL PERMIAN LTD.

Active - Oil

5253

5253

2241

4250101837

DENVER UNIT

2212W

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5255

5255

2212W

4250132793

MILLER

6

AMTEX ENERGY, INC.

Active - Oil

5258

5258

6

4250132356

MILLER

1

AMTEX ENERGY, INC.

Active - Oil

5260

5260

1


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250101017

ROBERTS UNIT

2641

APACHE CORPORATION

Active - Oil

5260

5260

2641

4250101825

DENVER UNIT

2204W

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5264

5264

2204W

4250132416

MILLER

2

AMTEX ENERGY, INC.

Active - Oil

5269

5269

2

4250100065

ROBERTS UNIT

3511W

APACHE CORPORATION

Plugged - Oil

5270

5270

3511W

4250101018

ROBERTS UNIT

2631

APACHE CORPORATION

Active - Oil

5270

5270

2631

4250130600

ROBERTS UNIT

3645

APACHE CORPORATION

Active - Oil

5273

5273

3645

4250130580

ROBERTS UNIT

4536

APACHE CORPORATION

Active - Oil

5279

5279

4536

4250130599

ROBERTS UNIT

3646

APACHE CORPORATION

Active - Oil

5279

5279

3646

4250130602

ROBERTS UNIT

3635

APACHE CORPORATION

Active - Oil

5283

5283

3635

4250132997

DENVER UNIT

2208WC

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5284

5284

2208WC

4250130601

ROBERTS UNIT

3636

APACHE CORPORATION

Active - Oil

5286

5286

3636

4250132174

SHEPHERD

1

YOUNG, MARSHALL R., OIL CO.

Dry Hole

5286

5286

1

4250130604

ROBERTS UNIT

3625

APACHE CORPORATION

Active - Oil

5287

5287

3625

4250130912

DENVER UNIT

2224

OCCIDENTAL PERMIAN LTD.

Active - Oil

5288

5288

2224

4250130911

DENVER UNIT

2225

OCCIDENTAL PERMIAN LTD.

Active - Oil

5290

5290

2225

4250130609

ROBERTS UNIT

4530

APACHE CORPORATION

Active - Oil

5291

5291

4530

4250130605

ROBERTS UNIT

3616

APACHE CORPORATION

Plugged - Oil

5291

5291

3616

4250130606

ROBERTS UNIT

3615

APACHE CORPORATION

Active - Oil

5293

5293

3615

4250133172

ROBERTS UNIT

2523

CONOCOPHILLIPS COMPANY

Plugged - Oil

5295

5295

2523

4250132739

CLEVELAND

1

HIGHLAND PRODUCTION COMPANY

Plugged - Oil

5300

5300

1

4250133064

DENVER UNIT

2238

SHELL WESTERN E&P INC.

Canceled/Abandoned Location

5300

5300

2238

4250132927

DENVER UNIT

2236

OCCIDENTAL PERMIAN LTD.

Active - Oil

5300

5300

2236

4250133065

DENVER UNIT

2237

SHELL WESTERN E&P INC.

Expired Permit

5300

5300

2237

4250132270

ROBERTS UNIT

4540

APACHE CORPORATION

Active - Oil

5300

5300

4540

4250132414

ROBERTS UNIT

3523A

APACHE CORPORATION

Active - Injection/Disposal

5300

5300

3523A

4250132712

ROBERTS UNIT

3537

APACHE CORPORATION

Plugged - Oil

5300

5300

3537

4250132722

ROBERTS UNIT

3547

APACHE CORPORATION

Active - Oil

5300

5300

3547

4250132945

ROBERTS UNIT

3541A

TEXACO PRODUCING INC.

Expired Permit

5300

5300

3541A

4250132975

ROBERTS UNIT

3641A

TEXACO PRODUCING INC.

Expired Permit

5300

5300

3641A

4250132711

ROBERTS UNIT

3620

APACHE CORPORATION

Active - Oil

5300

5300

3620

4250133527

ROBERTS UNIT

2518

APACHE CORPORATION

Active - Oil

5300

5300

2518

4250132714

ROBERTS UNIT

2637

APACHE CORPORATION

Plugged - Oil

5300

5300

2637

4250133351

ROBERTS UNIT

2526

TEXACO PRODUCING INC.

Expired Permit

5300

5300

2526

4250132703

ROBERTS UNIT

2516

APACHE CORPORATION

Plugged - Oil

5300

5300

2516

4250133348

ROBERTS UNIT

2533

TEXACO PRODUCING INC.

Expired Permit

5300

5300

2533

4250132702

ROBERTS UNIT

2515

APACHE CORPORATION

Active - Oil

5300

5300

2515

4250133350

ROBERTS UNIT

2525

APACHE CORPORATION

Active - Oil

5300

5300

2525

4250133498

ROBERTS UNIT

2532

TEXACO PRODUCING INC.

Expired Permit

5300

5300

2532

4250133173

ROBERTS UNIT

2522

APACHE CORPORATION

Active - Oil

5300

5300

2522


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250133499

ROBERTS UNIT

2527

TEXACO PRODUCING INC.

Dry Hole

5300

5300

2527

4250133530

ROBERTS UNIT

2507

APACHE CORPORATION

Active - Oil

5300

5300

2507

4250132685

ROBERTS UNIT

2638

APACHE CORPORATION

Plugged - Oil

5302

5302

2638

4250133349

ROBERTS UNIT

2517

APACHE CORPORATION

Active - Oil

5302

5302

2517

4250132718

ROBERTS UNIT

3532A

APACHE CORPORATION

Active - Injection/Disposal

5304

5304

3532A

4250132713

ROBERTS UNIT

2625

APACHE CORPORATION

Active - Oil

5308

5308

2625

4250133502

ROBERTS UNIT

2527A

APACHE CORPORATION

Plugged - Oil

5308

5308

2527A

4250132716

ROBERTS UNIT

3526

APACHE CORPORATION

Active - Oil

5309

5309

3526

4250100645

ROBERTS UNIT

1624W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5309

5309

1624W

4250130913

DENVER UNIT

2223

OCCIDENTAL PERMIAN LTD.

Active - Oil

5310

5310

2223

4250132686

ROBERTS UNIT

2636

APACHE CORPORATION

Active - Oil

5310

5310

2636

4250101457

DENVER UNIT

2210

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5325

5325

2210

4250133529

ROBERTS UNIT

2508

APACHE CORPORATION

Plugged - Oil

5325

5325

2508

4250133531

ROBERTS UNIT

2443A

APACHE CORPORATION

Active - Injection/Disposal

5325

5325

2443A

4250133528

ROBERTS UNIT

2511

APACHE CORPORATION

Active - Oil

5325

5325

2511

4250135912

ROBERTS UNIT

3771W

APACHE CORPORATION

Active - Injection/Disposal

5330

5330

3771W

4250132075

ROBERTS UNIT

3637

APACHE CORPORATION

Active - Oil

5330

5330

3637

4250132063

ROBERTS UNIT

2705

APACHE CORPORATION

Active - Oil

5330

5330

2705

4250135793

ROBERTS UNIT

3672

APACHE CORPORATION

Active - Oil

5334

5334

3672

4250135819

ROBERTS UNIT

3674W

APACHE CORPORATION

Active - Injection/Disposal

5336

5336

3674W

4250135792

ROBERTS UNIT

3671

APACHE CORPORATION

Active - Oil

5339

5339

3671

4250135820

ROBERTS UNIT

3675W

APACHE CORPORATION

Active - Injection/Disposal

5341

5341

3675W

4250135818

ROBERTS UNIT

3633RW

APACHE CORPORATION

Active - Injection/Disposal

5344

5344

3633RW

4250135790

ROBERTS UNIT

3647R

APACHE CORPORATION

Active - Oil

5345

5345

3647R

4250100768

CORNELL UNIT

3107W

XTO ENERGY INC.

Active - Injection/Disposal from Oil

5350

5350

3107W

4250130915

DENVER UNIT

2221

OCCIDENTAL PERMIAN LTD.

Active - Oil

5350

5350

2221

4250136048

ROBERTS UNIT

3634RW

APACHE CORPORATION

Active - Injection/Disposal

5350

5350

3634RW

4250135908

ROBERTS UNIT

3678W

APACHE CORPORATION

Active - Injection/Disposal

5350

5350

3678W

4250132072

ROBERTS UNIT

3525

APACHE CORPORATION

Active - Oil

5350

5350

3525

4250135915

ROBERTS UNIT

3626R

APACHE CORPORATION

Active - Oil

5350

5350

3626R

4250132281

ROBERTS UNIT

2446

APACHE CORPORATION

Active - Oil

5350

5350

2446

4250132064

ROBERTS UNIT

2704

APACHE CORPORATION

Active - Oil

5350

5350

2704

4250132280

ROBERTS UNIT

2445

APACHE CORPORATION

Plugged - Oil

5350

5350

2445

4250135791

ROBERTS UNIT

3670

APACHE CORPORATION

Active - Oil

5351

5351

3670

4250135794

ROBERTS UNIT

3673

APACHE CORPORATION

Active - Oil

5352

5352

3673

4250135821

ROBERTS UNIT

3676W

APACHE CORPORATION

Active - Injection/Disposal

5352

5352

3676W

4250135914

ROBERTS UNIT

3681W

APACHE CORPORATION

Active - Injection/Disposal

5352

5352

3681W

4250100643

ROBERTS UNIT

1634W

APACHE CORPORATION

Plugged - Oil

5353

5353

1634W

4250135796

ROBERTS UNIT

3669

APACHE CORPORATION

Active - Oil

5356

5356

3669


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250100644

ROBERTS UNIT

1614

APACHE CORPORATION

Plugged - Oil

5356

5356

1614

4250135913

ROBERTS UNIT

3680W

APACHE CORPORATION

Active - Injection/Disposal

5357

5357

3680W

4250135705

ROBERTS UNIT

3752

APACHE CORPORATION

Active - Oil

5360

5360

3752

4250135822

ROBERTS UNIT

3677W

APACHE CORPORATION

Active - Injection/Disposal

5362

5362

3677W

4250134984

ROBERTS UNIT

2626W

APACHE CORPORATION

Active - Injection/Disposal

5364

5364

2626W

4250135701

ROBERTS UNIT

3667

APACHE CORPORATION

Active - Oil

5365

5365

3667

4250132070

ROBERTS UNIT

3536

APACHE CORPORATION

Active - Oil

5370

5370

3536

4250132065

ROBERTS UNIT

2703

APACHE CORPORATION

Active - Oil

5370

5370

2703

4250100755

CORNELL UNIT

3101W

XTO ENERGY INC.

Active - Injection/Disposal from Oil

5373

5373

3101W

4250135703

ROBERTS UNIT

3668

APACHE CORPORATION

Active - Oil

5380

5380

3668

4250135229

DENVER UNIT

2240

OCCIDENTAL PERMIAN LTD.

Active - Oil

5388

5388

2240

4250136152

ROBERTS UNIT

3682W

APACHE CORPORATION

Active - Injection/Disposal

5397

5397

3682W

4250131539

DENVER UNIT

2230

SHELL OIL COMPANY

Canceled/Abandoned Location

5400

5400

2230

4250136327

ROBERTS UNIT

4547

APACHE CORPORATION

Active - Oil

5400

5400

4547

4250136154

ROBERTS UNIT

3624RW

APACHE CORPORATION

Active - Injection/Disposal

5400

5400

3624RW

4250136155

ROBERTS UNIT

3683W

APACHE CORPORATION

Active - Injection/Disposal

5402

5402

3683W

4250136156

ROBERTS UNIT

3686

APACHE CORPORATION

Active - Oil

5404

5404

3686

4250134797

CORNELL UNIT

3194

XTO ENERGY INC.

Active - Oil

5405

5405

3194

4250135696

CORNELL UNIT

113

XTO ENERGY INC.

Active - Oil

5406

5406

113

4250136150

ROBERTS UNIT

3684

APACHE CORPORATION

Active - Oil

5421

5421

3684

4250133629

CORNELL UNIT

3156

XTO ENERGY INC.

Active - Oil

5425

5425

3156

4250135961

DENVER UNIT

2246

OCCIDENTAL PERMIAN LTD.

Active - Oil

5425

5425

2246

4250135960

DENVER UNIT

2249

OCCIDENTAL PERMIAN LTD.

Active - Oil

5431

5431

2249

4250136153

ROBERTS UNIT

3623RW

APACHE CORPORATION

Active - Injection/Disposal

5439

5439

3623RW

4250135353

CORNELL UNIT

107

XTO ENERGY INC.

Active - Oil

5450

5450

107

4250135528

ROBERTS UNIT

3549

APACHE CORPORATION

Active - Oil

5452

5452

3549

4250136151

ROBERTS UNIT

3685

APACHE CORPORATION

Active - Oil

5463

5463

3685

4250135963

DENVER UNIT

2252

OCCIDENTAL PERMIAN LTD.

Active - Oil

5476

5476

2252

4250136434

ROBERTS UNIT

263H

APACHE CORPORATION

Expired Permit

5500

5500

263H

4250136433

ROBERTS UNIT

262H

APACHE CORPORATION

Expired Permit

5500

5500

262H

4250136098

CORNELL UNIT

110

XTO ENERGY INC.

Active - Injection/Disposal

5510

5510

110

4250133615

ROBERTS UNIT

2442A

APACHE CORPORATION

TA - Injection/Disposal

5516

5516

2442A

4250135180

ROBERTS UNIT

3534B

APACHE CORPORATION

Active - Injection/Disposal

5517

5517

3534B

4250136428

CORNELL UNIT

124

XTO ENERGY INC.

Active - Oil

5532

5532

124

4250134878

ROBERTS UNIT

3548

APACHE CORPORATION

Active - Oil

5550

5550

3548

4250135966

DENVER UNIT

2251

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2251

4250135962

DENVER UNIT

2250

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2250

4250135356

DENVER UNIT

2246

OCCIDENTAL PERMIAN LTD.

Expired Permit

5600

5600

2246

4250135959

DENVER UNIT

2248

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2248


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250135210

DENVER UNIT

2240

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2240

4250135211



2241

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2241

4250134710



2240

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2240

4250101845

ROBERTS UNIT

3613

APACHE CORPORATION

Active - Oil

7000

7000

3613

4250110083

RANDALL, E.

36

EXXON CORP.

Plugged - Oil

8595

8595

36

4250110046

ELLIOTT, C.A.

2

MCCLURE OIL COMPANY, INC.

Plugged - Oil

9000

9000

2

4250136692

MISS KITTY 704-669

3XH

RILEY EXPLORATION OPG CO, LLC

Expired Permit

9000

9000

3XH

4250133793

RANDALL, E.

39

XTO ENERGY INC.

Active - Oil

9000

9000

39

4250137375

RIP WHEELER 705-668

5XH

RILEY PERMIAN OPERATING CO, LLC

Permitted Location

9000

9000

5XH

4250137358

RIP WHEELER 705-668

1XH

RILEY PERMIAN OPERATING CO, LLC

Permitted Location

9000

9000

1XH

4250133843

ELLIOTT

1

DELTA C02, LLC

Plugged - Oil

9050

9050

1

4250134124

RANDALL, E

46

EXXON CORP.

Canceled/Abandoned Location

9100

9100

46

4250133792

RANDALL, E.

40

XTO ENERGY INC.

Plugged - Oil

9591

9591

40

4250110079

RANDALL, E.

32

EXXON CORP.

Plugged - Oil

9615

9615

32

4250135418

RANDALL, E.

46

XTO ENERGY INC.

Active - Oil

9650

9650

46

4250134023

RANDALL, E.

42

XTO ENERGY INC.

Active - Oil

9660

9660

42

4250134016

RANDALL, E.

43

XTO ENERGY INC.

Active - Oil

9740

9740

43

4250132388

RANDALL, E.

38

EXXON CORP.

Canceled/Abandoned Location

10300

10300

38

4250137302

MILLER 732 B

9H

AMTEX ENERGY, INC.

Active - Oil

5183

10662

9H

4250136432

ROBERTS UNIT

261 H

APACHE CORPORATION

Active - Oil

5151

11117

261 H

4250136998

RATTLESNAKE AGI

1

SANTA FE MIDSTREAM PERMIAN LLC

Active - Injection/Disposal

11980

11980

1

4250137252

MILLER SWD

7

AMTEX ENERGY, INC.

Permitted Location

13000

13000

7

4250136984

MADCAP 731-706

1XH

RILEY PERMIAN OPERATING CO, LLC

Active - Oil

5261

13274

1XH

4250137127

MISS KITTY A 669-704

25XH

RILEY PERMIAN OPERATING CO, LLC

Active - Oil

5321

13428

25XH

4250137287

MISS KITTY A 669-704

4XH

RILEY PERMIAN OPERATING CO, LLC

Shut-In - Oil

5340

13452

4XH

4250137236

MISS KITTY 669-704

2XH

RILEY PERMIAN OPERATING CO, LLC

Active - Oil

5317

13622

2XH


-------
A-1143

Rattlesnake AGI No. 1
Maximum Monitoring Area
with

1/2-Mile MMA Oil/Gas Well Penetrators
Area of Review

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 6/1/2022

Approved by: RH

LONQUIST & CO. LLC



PETROLEUM

ENERGY





ENGINEERS

ADVISORS

1

AUSTIN • HOUSTON jj

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

F-5

+ Rattlesnake AGI No. 1 SHL

I	'

I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

Stabilized Plume

J Plume Boundary at End of Injection

Abstract

API (42-501-...) SHL Status - Type (Count)

• Active - Oil (4)

Active - Injection/Disposal (1)

Plugged - Oil (4)

® Permitted Location (1)

Sou rce:

1.)	Oil/Gas Well SHL Data: DI-2022

2.)	Oil/Gas Well BHL Data: DI-2022

3.)	Oil/Gas Well Directional Data: DI-2022

* Note: All coordinates shown are in NAD83 (DD).

1560


-------
A-1143

Rattlesnake AGI No. 1
Maximum Monitoring Area
with

1/2-Mile MMA Groundwater Well
Area of Review

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY

F-6



ENGINEERS

ADVISORS

| AUSTIN • HOUSTON J

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

+ Rattlesnake AGI No. 1 SHL

|	I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

Stabilized Plume

J Plume Boundary at End of Injection

Abstract

SDRDB Groundwater Wells [TWDB-2022]

Proposed Use (Labeled with Well Report No.)
A Industrial (1)

Irrigation (5)

TWDB Groundwater Wells [TWDB-2022]

Well Type (Labeled with State Well No.)
¦ Withdrawal of Water (1)

Sou rce:

1.)	SDRDB Groundwater Well SHL Data: TWDB-2022

2.)	TWDB Groundwater Well SHL Data: TWDB-2022

3.)	Brackish Groundwater Well SHL Data: TWDB-2022
* Note: All coordinates shown are in NAD83 (DD). *

1560


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Cement Plug #9
@7'-1,013'

Cement Plug #8
@ 1,730'- 1,800'

Cement Plug #7
@ 2,031' - 2,100

Cement Plug #6
@2,430'-2,500'

Cement Plug #5
@2,660'-2,719'

Cement Plug #4
@2,790'-2,860'

Cement Plug #3
@3,172'-3,239'

Cement Plug #2
@3,765'-3,831'

Cement Plug #1
@ 3,900'-3,960'

Perfs @ 8,231
8,396', 8,420'
8,447', 8,462'

Casing Information

Label

1

2

Type

Surface

Production

OD

8-5/8"

4-1/2"

Depth Set

2,134'

9,601'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-10079

RRC District No: 8-A

Drawn: KAS

E. Randall No. 32

State/Province: Texas

Spud Date: 05/10/1965

Field: Wasson (Wichita Albany)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 18231

Date: 05/31/2022

Approved: SLP


-------
Cement Plug #5
@ 0' - 458'

Cement Plug #4
@2,070'-2,295'

Cement Plug #3
@2,780'- 3,009'

Cement Plug #2
@4,450'-4,870'

Cement Plug #1
@5,184'-5,266'

Perfs@ 9,496'-9,516'

TD@ 9,591'
PBTD @ 9,560'



DV Tool ® 4,522'

DV Tool @ 5,676'

Casing Information

Label

1

3

Type

Surface

Production

OD

9-5/8"

5-1/2"

Weight

36 lb/ft

UNK

Depth Set

2,162'

9,569'

Hole Size

12-1/4"

7-7/8"

TOC

Surface

2,350'

Volume

880 sks

5,450 sks

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

XTO Energy Inc.

Country: USA

Location: Section 833, Block D

API No: 42-501-337932

RRC District No: 8-A

Drawn: KAS

E. Randall No. 40

State/Province: Texas

Spud Date: 12/04/1992

Field: Wasson (Wichita Albany)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—





A

Perfs (5) 9,536' - 9,540'

SI

[S

: . I





DV Tool @ 5,968'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54 lb/ft

36 lb/ft
40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,129'

5,606'

9,699'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

Surface

Volume

1,790 sks

2,910 sks

1,590 sks

2-3/8" Tubing & Packer Set @ 9,331'

TD @ 9,700'
PBTD @ 9,654'

MD

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN • HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 832, Block D

API No: 42-501-33885

RRC District No: 8-A

Drawn: KAS

E. Randall No. 41L

State/Province: Texas

Spud Date: 02/05/1994

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Perfs (5) 9,533' - 9,553'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,167'

5,830'

9,658'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

440'

1,800'

Volume

1,530 sks

3,500 sks

1,050 sks

DV Tool ® 7,414'

2-3/8" Tubing & Packer Set @ 8,970'

TD @ 9,660' \-(3)
PBTD @ 9,623' W

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-34023

RRC District No: 8-A

Drawn: KAS

E. Randall No. 42L

State/Province: Texas

Spud Date: 07/01/1995

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—



Li;.

Perfs @ 9,550' - 9,538'
9,603'-9,610'

sf.

.... «¦
*'¦ •-

4/?

¦A ¦







" B ¦'





" ¦ /





?







, 4' i

,

"4

t" '

'*¦ ?r









. v.







> .¦







"A



' 'i



;



¦ 'v



„ .: '



4* •"

/











CIBP ® 8,917'

CIBP @ 9,590'

TD @ 9,740'
PBTD @ 8,917'

rv@

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,166'

5,902'

9,735'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

2,000'

Volume

1,530 sks

3,505 sks

967 sks

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 832, Block D

API No: 42-501-34016

RRC District No: 8-A

Drawn: KAS

E. Randall No. 43L

State/Province: Texas

Spud Date: 04/08/1995

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Perfs @ 8,762' - 8,782'

(Sqz w/100 sx)

Perfs @8,822'-8,831'

(Sqz w/ 75 sx)

Perfs @ 9,562' - 9,570'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft
29 lb/ft

Depth Set

2,158'

5,904'

9,620'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

1,600'

Volume

1,450 sks

5,190 sks

1,100 sks

DV Tool ® 7,482'

2-3/8" Tubing & Packer Set @ 9,552'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-34024

RRC District No: 8-A

Drawn: KAS

E. Randall No. 44

State/Province: Texas

Spud Date: 08/09/1995

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Perfs (5) 9,565' - 9,575'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,175'

5,898'

9,615'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

1,500'

Volume

1,530 sks

3,525 sks

1,170 sks

DV Tool ® 7,508'

2-3/8" Tubing Set @ 9,580'

Packer Set (5) 9,394'

TD @ 9,684'

PBTD @ 9,593'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-34017

RRC District No: 8-A

Drawn: KAS

E. Randall No. 45L

State/Province: Texas

Spud Date: 02/05/1994

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
Perfs (5) 9,504' - 9,512'

TD @ 9,650'
PBTD @ 9,594'

Casing/Tubing
Information

Label

1

2

Type

Surface

Production

OD

8-5/8"

5-1/2"

Weight

24 lb/ft

17 lb/ft

Depth Set

2,120'

9,650'

Hole Size

11"

7-7/8"

TOC

Surface

Surface

Volume

900 sks

3,400 sks

DV Tool ® 8,656' & 8,674'

2-7/8" Tubing & Packer Set @ 9,184'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

XTO Energy, Inc.

Country: USA

Location: Section 833, Block D

API No: 42-501-35418

RRC District No: 8-A

Drawn: KAS

E. Randall No. 46

State/Province: Texas

Spud Date: 05/23/2007

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
u

Cement Plug #4
@48'-60'

Cement Plug #3
@ 270' - 450'

Cement Plug #1
@7,549'-8,000'

Perfs @ 8,292' - 8,428'

Cement Plug #2
@3,273'-3,439'

Top of Cut @ 750'
Top of Cut @ 1,439'

TD ® 9,645'

v@

Casing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

5-1/2"

Depth Set

300'

3,200'

9,610'

TOC

Surface

Surface

Surface

Volume

400 sks

300 sks

425 sks

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Bonanza Oil Corp.

Country: USA

Location: Section 832, Block D

API No: 42-501-10046

RRC District No: 8-A

Drawn: KAS

C.A. Elliott No. 2

State/Province: Texas

Spud Date: 05/10/1965

Field: Wasson (Wichita Albany)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 18875

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

w

if.

II

: .



Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

48 lb/ft

40 lb/ft

26 lb/ft
28 lb/ft

Depth Set

500'

5,500'

10,695'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

Surface

Volume

350 sks

1,705 sks

1,635 sks

3-1/2" Tubing & Packer Set @ 10,650'

MD

TD @ 13,000'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Amtex Energy, Inc.

Country: USA

Location: Section 732, Block D

API No: 42-501-37252

RRC District No: 7-C

Drawn: KAS

Miller SWD No. 7 (Permitted)

State/Province: Texas

Spud Date: 08/09/1995

Field: Wasson

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

Permit Number: 16637

Date: 05/31/2022

Approved: SLP


-------
Request for Additional Information: 30-30 Gas Plant
July 25, 2022

Instructions: Please enter responses into this table and make corresponding revisions to the MRV Plan as necessary. Any long responses, references,
or supplemental information may be attached to the end of the table as an appendix. This table may be uploaded to the Electronic Greenhouse Gas
Reporting Tool (e-GGRT) in addition to any MRV Plan resubmissions.

No.

MRV Plan

EPA Questions

Responses

Section

Page

1.

NA

NA

Several map figures in the MRV plan have difficult to
read text within the map legends. We recommend
increasing the font size where needed. For example,
Figures 11, 26, 27, etc.

Larger scale versions of all maps have been included in the Appendices and references
to the maps added

2.

INTRO

1

'This AGI well is associated with Stakeholder's 30-30
gas treating and processing plant ("30-30") located in
a rural, sparsely populated area of Yoakum County,
Texas, approximately seven miles northwest of the
town of Plains."

Please add a reference for Figure 1.

"as shown in Figure 1." Added to the last sentence in paragraph 1 (pg 1)

3.

INTRO

2

Please define MMSCF/d and other acronyms upon
first use.

Added: "16 million standard cubic feet per day ("MMSCF/d")." (pg 2)

4.

2

9

'The Rattlesnake AGI #1 well is located and designed
to protect against migration of CO2 into productive oil
and gas formations and freshwater aquifers and to
prevent surface releases."

This sentence is awkwardly worded. We recommend
adjusting to improve clarity.

Sentence modified to "The Rattlesnake AGI #1 well is located and designed to protect
against migration of C02 out of the injection interval and to prevent surface releases."


-------
No.

MRV Plan

EPA Questions

Responses

Section

Page

5.

2

9

"in the area and 8,593' below the base of the lowest
useable quality water table, as Shown in Figure 2."

Please fix capitalization.

Capitalization fixed (pg 9)

6.

2

13

'The Wristen Group is composed of three formations;
Fasken, Frame, and Wink formations."

Please consider changing the semicolon to a colon in
the above sentence.

Semicolon changed to colon (pg 13)

7.

2

16

'The Woodford is a late Devonian-aged..."
Consider changing "aged" to "age"

Changed "aged" to "age" (pg 16)

8.

2

19

Please clarify why the Rattlesnake AGI #1 (42-501-
36998) well log is used in Figure 10, but an offset well
(45-501-10238) is used in Figure 7.

Added "An offset well log was used to depict the upper confining intervals as electric
logs were only run in the Rattlesnake AGI #1 well across the injection zone." to the
paragraph discussing Figure 7 (pg 15)

9.

2

20

The pH values in Table 1 are the same as the values
used in the Campo Viejo Gas Processing Plant MRV
plan. Please confirm whether these values are
accurate for the 30-30 Plant.

The pH values are correct for the Rattlesnake area

10.

2

30

"Figure 19 shows the subsurface and outcrop extent
of the Ogallala Aquifer."

We believe the reference here is to Figure 20. Please
address.

Corrected to "Figure 20" (pg 30)


-------
No.

MRV Plan

EPA Questions

Responses

Section

Page

11.

2

30

"... by approximately 9,500' of rock..."

Section 2 of the MRV plan gives the figure of 8,593
feet. Please clarify.

Corrected to "approximately 8,600' of rock" (pg 30). Also corrected "650' of Salado
salt" to "576' of Salado salt"

12.

2

32

Figure 21 is the exact same as the figure used in the
Campo Viejo Gas Processing Plant MRV plan. Please
clarify whether this figure and values are applicable to
the 30-30 Gas Plant.

The ranges provided for H2S/C02 compositions is applicable, as confirmed in Table 5 -
Modeled Initial Gas Composition. However, the high pressure for the injection pumps
has been updated to reflect the expected permitted MASIP

13.

2

33

'The grid contains 141 blocks in the x-direction (E-W)
and 201 blocks in the y-direction (N-S), totaling 28,341
grid blocks per layer. This results in the grid being
21,150' by 30,150' totaling just over a 23-square mile
area (14,640 acres)."

The MRV plan does not provide the dimensions of the
individual blocks themselves. Please add for clarity.

'The grid blocks are each 150' by 150' by layer thickness as specified in Table 6." added
to provide dimensions (pg 33)

14.

3

40

"In this case, the plume boundary in 2041 is within the
plume at 2036 plus a half-mile buffer. By 2036 at the
latest, a revised MRV will be submitted to define a
new AMA. Figure 27 shows the area covered by the
AMA."

Please add "plan" after "MRV".

"plan" added after MRV (pg 40)

15.

4

44

"A larger scale version of Figure 27 is provided in
Appendix D."

Is this supposed to be Figure 28? Please address.

Figure 27 changed to Figure 28 (pg 44)


-------
No.

MRV Plan

EPA Questions

Responses

Section

Page

16.

4

44

"... a few wells have produced from the Wolfcamp
The Wolfcamp is separated from the..."

It appears that a punctuation mark is missing. Please
address.

Period added after sentence (pg 44)

17.

4

44

"All of the wells which penetrate the injection interval
within the MMA were properly cased and cemented
to prevent annular leakage of CO2 to the surface."

Please clarify whether this is a determination made by
the 30-30 Gas Plant operators or if this is according to
TRRC records.

Sentence changed to "A review of the TRRC records for all of the wells which penetrate
the injection interval within the MMA, shows the wells were properly cased and
cemented to prevent annular leakage of C02 to the surface." to clarify that the TRRC
records show that the wells are properly constructed, (pg 44)

18.

4

48

"In this instance, any new well permitted and drilled
to the Rattlesnake AGI #1 well's injection zone located
within a one-quarter mile radius of the Rattlesnake
AGI #1 well will be required under TRRC Rule 13 to set
steel casing and cement above the Rattlesnake AGI #1
well injection zone."

This sentence is confusing to read. We recommend
adjusting with punctuation or rewording.

Sentence clarified "In this instance, any new well permitted and drilled to the
Rattlesnake AGI #1 well's injection zone, and located within a one-quarter mile radius of
the Rattlesnake AGI #1 well, will be required under TRRC Rule 13 to set steel casing and
cement above the Rattlesnake AGI #1 well injection zone." (pg 48)

19.

4

48

"See GAU letter attached included within Appendix B"

Should this read, "See GAU letter attached in
Appendix B"?

"Attached" removed from sentence (pg 48)

20.

4

50

In Table 9, owners are referred to both as FRANCIS
BARBINI and FRANCIS BARBIDI. Are these two
different owners, or is one a misspelling?

Likely "Barbidi" is a misspelling, but listed as perTWDB records


-------
No.

MRV Plan

EPA Questions

Responses

Section

Page

21.

4

51

"Leakage from Natural or Induced Seismicity" is
discussed primarily from the perspective historical
seismicity in the area. Will there be any operational
practices implemented to ensure that the risk of
induced seismicity is mitigated?

The following: "Pressures will be kept significantly below the fracture gradient of the
injection and confining intervals. Additionally, continuous well monitoring combined
with seismic monitoring will identify any operational anomalies associated with a
seismicity event." was added to this section (pg 51)

22.

5

54

'Table 8 summarizes the monitoring of potential
leakage pathways to the surface."

Should this refer to Table 10?

Table 8 corrected to Table 10 (pg 54)

23.

5

54

"Monitoring will occur during the planned 25-year
injection period, or cessation of injection operations,
plus a proposed 5-year post-injection period."

Other parts of the MRV plan reference an injection
period of 17 years. Please clarify and update the MRV
plan as necessary

"25-year" corrected to "17-year" (pg 54)

24.

5

55

"...which are shown in Figure 28above"

It appears there is a space missing. Please address.

Space added (pg 55)

25.

5

55

'The scope of work will include H2S and CO2
monitoring at the AGI well site as well as minimum,
quarterly atmospheric monitoring near identified
penetrations within the AMA."

Please describe what atmospheric monitoring will be
conducted. E.g., what types of parameters will be
measured?

"At the well site, H2S and C02 concentrations will be monitored continuously with fixed
monitors that detect atmospheric concentrations of H2S and C02. At penetrating well
sites, Stakeholder will similarly measure atmospheric concentrations of C02 and H2S
using mobile gas monitors. This data will be recorded at least quarterly." was added to
clarify the parameters to be measured (pg 55)


-------
No.

MRV Plan

EPA Questions

Responses

Section

Page

26.

5

55

"Stakeholder will monitor the groundwater quality in
fluids above the confining interval by sampling the
well on the facility property and analyzing the sample
with a third-party laboratory on an annual basis."

What types of parameters will be measured in the
groundwater samples?

'The parameters to be measured will include pH, total dissolved solids, total inorganic
and organic carbons, density, temperature and other standard laboratory
measurements. Any significant differences in these parameters from the baseline
sample will be evaluated to determine if leakage of C02 to the USDW may have
occurred." was added to clarify the parameters to be measured (pg 56)

27.

5

56

"Stakeholder plans to install a seismic monitoring
station in the general area of the Rattlesnake AGI #1
well."

When is the seismic monitoring station planned to be
installed?

'The installation of this station would start upon approval of the MRV plan, with an
expected in-service data within six months after the commencement of the installation
project." added to this paragraph (pg 56)

28.

7

59

Mass of CO2 Injected

"Per 40 CFR §98.444(b), since the flow rate of CO2
injected will be measured with a volumetric flow
meter, the total annual mass of CO2, in metric tons,
will be calculated by multiplying the mass flow by the
CO2 concentration in the flow according to Equation
RR-4:"

When using a volumetric flow meter, you must use
Equation RR-5. Equation RR-4 is used when a mass
flow meter is used to measure the injection quantity.
Please clarify what type of flow meter will be used and
which equation will be used to calculate mass of CO2
injected.

Corrected to Equation RR-5 (pg 59)

29.

2

31



Corrected depths and thickness to those provided by GAU letter (pg 30)

30.










-------
STAKEHOLDER

fMIDSTREAM

Subpart RR Monitoring, Reporting, and
Verification (MRV) Plan
Rattlesnake AGI #1

Yoakum County, Texas

Prepared for Stakeholder Gas Services, LLC
San Antonio, TX

By

Lonquist Sequestration, LLC
Austin, TX

Version 1
June 2022

LONQUIST

SEQUESTRATION LLC

i


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INTRODUCTION

Stakeholder Gas Services, LLC ("Stakeholder") currently has a Class II acid gas injection ("AGI") permit, issued
by the Texas Railroad Commission ("TRRC") in November 2018, for the Rattlesnake AGI #1 well, API No. 42-
501-36998. This permit was originally issued to Santa Fe Midstream Permian, LLC, in 2018 and the asset was
subsequently acquired by Stakeholder in December of 2020. This permit currently authorizes Stakeholder to
inject up to 4,500 barrels per day ("bbls/d") of treated acid gas ("TAG") into the Devonian formation at a
depth of 11,000' to 12,000' with a maximum allowable surface pressure of 2,200 psi. Since being permitted,
injection has proceeded without incident. This AGI well is associated with Stakeholder's 30-30 gas treating
and processing plant ("30-30") located in a rural, sparsely populated area of Yoakum County, Texas,
approximately seven miles northwest of the town of Plains.

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YOAKUM

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Gaines













0 0.5 1 2 Miles



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# Stakeholder AGI Well

Figure 1 - Location of Rattlesnake AGI #1 Well

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Stakeholder is submitting this Monitoring, Reporting, and Verification ("MRV") plan to the EPA for approval
under 40 CFR §98.440(a), Subpart RR, of the Greenhouse Gas Reporting Program ("GHGRP"). In addition to
submitting this MRV plan to the EPA, Stakeholder is also applying to the TRRC for an amendment to the
Rattlesnake AGI #1 well's Class II permit to increase its authorized injection volume and maximum allowable
surface injection pressure ("MASIP"). Approval of the permit amendment will allow Stakeholder to increase
the capacity of its existing 30-30 Facility, which removes H2S and C02 from natural gas production using amine
treating, as well as increase the injection well capacity for a future gas processing facility which is currently
under development by Stakeholder. Additionally, expanded capacity allows Stakeholder to potentially
provide future disposal in its AGI well for oil and gas waste derived TAG from similar third-party gas processing
facilities. Increased disposal capacity will allow for greater gas processing capacity in the region, ultimately
helping to reduce flaring and its associated emissions. Throughout this document, both in written reference
and in modeling inputs, Stakeholder has used the applied-for expanded permit capacity of 16 MMSCF/d.
Stakeholder plans to inject C02 for approximately 14 more years.

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ACRONYMS AND ABBREVIATIONS

%

°c

°F

AMA

BCF

CH4

CMG

C02

E

EOS

EPA

ESD

FG

ft

GAU

GEM

GHGs

GHGRP

H2S

md

mi

MIT

MM

MMA

MCF

MMCF

MMSCF

Feet

Percent(Percentage)

Degrees Celsius
Degrees Fahrenheit
Active Monitoring Area
Billion Cubic Feet
Methane

Computer Modelling Group

Carbon Dioxide (may also refer to other Carbon Oxides)
East

Equation of State

U.S. Environmental Protection Agency
Emergency Shutdown
Fracture Gradient
Foot (Feet)

Groundwater Advisory Unit

Computer Modelling Group's GEM 2020.11

Greenhouse Gases

Greenhouse Gas Reporting Program

Hydrogen Sulfide

Millidarcy(ies)

Mile(s)

Mechanical Integrity Test
Million

Maximum Monitoring Area
Thousand Cubic Feet
Million Cubic Feet
Million Standard Cubic Feet


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MSCF/D	Thousand Cubic Feet per Day

MMSCF/d	Million Standard Cubic Feet per Day

MRV	Monitoring, Reporting and Verification

v	Poisson's Ratio

N	North

NW	Northwest

OBG	Overburden Gradient

PG	Pore Gradient

pH	Scale of Acidity

ppm	Parts per Million

psi	Pounds per Square Inch

psig	Pounds per Square Inch Gauge

S	South

SE	Southeast

SF	Safety Factor

SWD	Saltwater Disposal

TAC	Texas Administrative Code

TAG	Treated Acid Gas

TOC	Total Organic Carbon

TRRC	Texas Railroad Commission

UIC	Underground Injection Control

USDW	Underground Source of Drinking Water

W	West

4


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TABLE OF CONTENTS

INTRODUCTION	1

ACRONYMS AND ABBREVIATIONS	3

SECTION 1 - FACILITY INFORMATION	8

Reporter number	8

Underground Injection Control (UIC) Class II Permit	8

UlCWell Identification Number	8

SECTION 2 - PROJECT DESCRIPTION	9

Regional Geology	10

Regional Faulting	15

Site Characterization	15

Stratigraphy and Lithologic Characteristics	15

Upper Confining Interval - Woodford Shale	16

Injection Interval - Fasken Formation	17

Lower Confining Zone - Fusselman Formation	21

Local Structure	21

Injection and Confinement Summary	26

Groundwater Hydrology	26

Description of the Injection Process	31

Current Operations	31

Planned Operations	32

Reservoir Characterization Modeling	32

Simulation Modeling	35

SECTION 3 - DELINATION OF MONITORING AREA	39

Maximum Monitoring Area	39

Active Monitoring Area	40

SECTION 4- POTENTIAL PATHWAYS FOR LEAKAGE	42

Leakage from Surface Equipment	42

Leakage from Wells in the Monitoring Area	44

Oil and Gas Operations within Monitoring Area	44

Groundwater wells	48

Leakage Through Faults or Fractures	50

Leakage Through Confining Layers	51

Leakage from Natural or Induced Seismicity	51

SECTION 5 - MONITORING FOR LEAKAGE	54

Leakage from Surface Equipment	54

Leakage from Existing and Future Wells within Monitoring Area	55

Leakage through Faults, Fractures or Confining Seals	56

Leakage through Natural or Induced Seismicity	56

SECTION 6 - BASELINE DETERMINATIONS	57

Visual Inspections	57

H2S Detection	57

CO2 Detection	57

Operational Data	57

Continuous Monitoring	57

Groundwater Monitoring	58

SECTION 7 - SITE SPECIFIC CONSIDERATIONS FOR MASS BALANCE EQUATION	59

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Mass of C02 Received	59

Mass of CO2 Injected	59

Mass of CO2 Produced	60

Mass of CO2 Emitted by Surface Leakage	60

Mass of CO2 Sequestered	60

SECTION 8 - IMPLEMENTATION SCHEDULE FOR MRV PLAN	62

SECTION 9 - QUALITY ASSURANCE	63

Monitoring QA/QC	63

Missing Data	63

MRV Plan Revisions	64

SECTION 10 - RECORDS RETENTION	65

References	66

APPENDICES	67

LIST OF FIGURES

Figure 1 - Location of Rattlesnake AGI #1 well	1

Figure 2 - Illustrative overview of Rattlesnake AGI #1 and 30-30 Facility	9

Figure 3 - Regional Map of the Permian Basin	10

Figure 4 - Stratigraphic column of the Northwest Shelf	11

Figure 5 - Stratigraphic column depicting the composition of the Silurian group	12

Figure 6 - Thickness map of the Silurian system which composes the Fusselman and Wristen group	14

Figure 7 - Type Log (42-501-10238) with tops, confining and injection zones depicted	15

Figure 8 - Core description of the Woodford Shale and Upper Silurian (Ruppel and Holtz, 1994)	16

Figure 9 - Table of reservoir properties found within the Wristen buildups and platform plays	18

Figure 10 - Rattlesnake AGI #1 open hole log (42-501-36998)	19

Figure 11 - Offset wells used for Formation Fluid Characterization	20

Figure 12 - Silurian Structure Map (subsea depths)	23

Figure 13 - Structural Northeast-Southwest Cross Section	24

Figure 14- Structural Northwest-Southeast Cross Section	25

Figure 15 - Northwest-Southeast Cross Section of aquifers in the Rattlesnake AGI #1 well area 	27

Figure 16 - Potentiometric surfaces from wells completed in A Ogallala aquifer, B the Edwards-Trinity aquifer

and Cthe Dockum aquifer	28

Figure 17 - Regional extent of the Dockum freshwater aquifer (TWDB)	29

Figure 18-Total dissolved solids in groundwater from the Dockum Aquifer	29

Figure 19- Regional extent of the Edwards-Trinity freshwater aquifer	30

Figure 20 - Regional extent of the Ogallala freshwater aquifer 	31

Figure 21 - 30-30 Facility Process Flow Diagram	32

Figure 22 - Permeability Distribution of Karst Limestone	34

Figure 23 - Areal View Gas Saturation Plume, 2036 (End of Injection)	37

Figure 24 - Areal View Gas Saturation Plume, 2779 (End of Density Drift)	38

Figure 25 - Well Injection Rate and Bottomhole Pressure over Time	38

Figure 26 - Plume Boundary at End of Injection, Stabilized Plume, and Maximum Monitoring Area	40

Figure 27 - Active Monitoring Area	41

Figure 28 - Site Plan, 30-30 Facility	43

Figure 29 - Rattlesnake AGI #1 Wellbore Schematic	45

Figure 30 - Oil and Gas Wells within the MMA	46

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Figure 31 - Penetrating Oil and Gas Wells within the MMA	47

Figure 32 - Groundwater Wells within MMA	49

Figure 33 - Seismicity Review (TexNet - 06/01/2022)	52

Figure 34 - Probabilistic Fault Slip Potential Analysis with Rattlesnake AGI #1 location	53

LIST OF TABLES

Table 1 - Analysis of Silurian-Devonian age formation fluids from nearby oil-field brine samples	20

Table 2 - Fracture Gradient Assumptions	21

Table 3 - Geologic and hydrogeologic units with accompanying lithologic descriptions near Gaines, Terry and

Yoakum Counties, Texas	26

Table 4 - Gas Composition of 30-30 Facility outlet	31

Table 5 - Modeled Initial Gas Composition	33

Table 6 - CMG Model Layer Properties	34

Table 7 - All Offset SWDs included in the model	36

Table 8 - All Offset Producers included in the model	36

Table 9 - Groundwater Well Summary	50

Table 10 - Summary of Leakage Monitoring Methods	54

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SECTION 1 - FACILITY INFORMATION

This section contains key information regarding the Acid Gas and C02 injection facility.

Reporter number:

•	Gas Plant Facility Name: 30-30 Gas Plant

•	Greenhouse Gas Reporting Program ID: 574501

o Currently reporting under Subpart UU

•	Operator: Stakeholder Gas Services, LLC

Underground Injection Control (UIC) Permit Class: Class II

The TRRC regulates oil and gas activities in Texas and has primacy to implement the Underground Injection
Control ("UIC") Class II program. TRRC classifies the Rattlesnake AGI #1 well as a UIC Class II well. A Class II
permit was issued to Stakeholder under TRRC Rule 9 (entitled "Disposal into Non-Productive Formations")
and Rule 36 (entitled "Oil, Gas, orGeothermal Resource Operation in Hydrogen Sulfide Areas").

UIC Well Identification Number:

Rattlesnake AGI #1, API No. 42-501-36998, UIC #000117143.

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SECTION 2 - PROJECT DESCRIPTION

This Project Description discusses the geologic setting, planned injection volumes and process, and the
reservoir modeling performed for the Rattlesnake AGI #1 well. The Class II UIC permit was initially applied
for and received by Santa Fe Midstream Permian, LLC. The asset was acquired in 2020 by Stakeholder and
has been in operation since that time. Since the original application, Lonquist has revised and updated the
geology and the plume modeling within the reservoir in preparing this MRV Plan.

The Rattlesnake AGI #1 well is located and designed to protect against migration of CO2 into productive oil
and gas formations and freshwater aquifers and to prevent surface releases. The injection interval for
Rattlesnake AGI #1 is located over 4,720' below the primary producing formation, the San Andres, in the area
and 8,593' below the base of the lowest useable quality water table, as Shown in Figure 2. This well injects
both H2S and C02, therefore the well and the facility are designed to minimize any leakage to the surface.

2,450'

LOWEST
WATER TABLE
DEPTH

5,500'

CASING DEPTH

Casing consists of
reinforced steel
and concrete

11,000'

INJECTION WELL
DEPTH

>8,500'

BELOWTHE
WATER TABLE

Figure 2 - Illustrative overview of Rattlesnake AGI ffl and 30-30 Facility

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Regional Geology

The Rattlesnake AGI #1 well is located on the southern portion of the Northwestern Shelf within the larger
Permian Basin as seen in Figure 3. The Northwestern Shelf is a broad marine shelf located in the northern
portion of the Permian Basin.

Basin

Matador Arch

Midlam
rBasIm

	new.m_exico'

Ttexa's "J
Delaware^
Basin \

Ozona
, Arch

>Val Verde
' Basin

.Ouach/tj
Nj

NEW
[MEXICO

^Permian Basin

Figure 3 - Regional Map of the Permian Basin. Red Star is approximate location of Rattlesnake AGIffl well

Figure 4 depicts the stratigraphic column found at the Rattlesnake AGI #1 well location with red stars
referencing the injection formation and green stars indicating the productive intervals in the area. The
primary injection interval is found within the Wristen group, of Silurian-age, as seen in Figure 5. The TRRC
refers to this sequence under the general terms "Devonian", "Silurian-Devonian" or "Siluro-Devonian".

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Period

Epoch

Formation

General Lithology





Dewey Lake

Redbeds/Anhydrite



Ochoan

Rustler

Halite





Salado

Halite/Anhydrite





Tansil

Anhydrite/Dolomite





Yates

Anhydrite/Dolomite



Guadalupian

Seven Rivers

Dolomite/Anhydrite





Queen

Sandy Dolomite/Anhydrite/Sandstone

Permian



Grayburg

Dolomite/Anhydrite/Shale/Sandstone



~ San Andres

Dolomite/Anhydrite





Glorieta

Sandy Dolomite







Paddock





Leonardian

Yeso

Blinebry

Dolomite/Anhydrite/Sandstone





Tubb







Drinkard







Abo

Dolomite/Anhydrite/Shale



Wolfcampian

^ Wolfcamp

Limestone/Dolomite



Virgilian

Cisco

Limestone/Dolomite



Missourian

Canyon

Limestone/Shale

Pennsylvanian

Des Moinesian

Strawn

Limestone/Sandstone



Atokan

Bend

Limestone/Sandstone/Shale



Morrowan

Morrow

Mississippian



Mississippian Lime

Limestone

Devonian



Woodford

Shale

Silurian



^Wristen Group

Dolomite/Limestone



Fusselman

Dolomite/Chert



Upper

Ordovician

Montoya

Dolomite/Chert

Middle

Simspson Gp

Limestone/Sandstone/Shale



Lower

Ellenburger

Dolomite

Figure 4 - Stratigraphic column of the Northwest Shelf, Red stars indicate injection interval. Green stars indicate productive

intervals.


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¦ MB

Q.
Q.

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secondary porosity development and increased permeability. Dolomite and solution-related features are the
most prominent diagenetic characteristics found within the Silurian. The Wristen Group is composed of three
formations; Fasken, Frame, and Wink formations. The Frame and Wink formations are found near the ramp
boundary to the south, while the Fasken formation is found predominantly in the inner platform, where the
Rattlesnake AGI #1 well is located. The Fasken formation is predominately dolomite grading to limestone,
occurring as cycles, down section. This dolomitization is due in part to sub-areal exposure, during which
karsts and secondary porosity developed. Additional dolomitization was possible during successive sea level
fluctuations via movement of magnesium-rich solution through karsts and vugs, which acted as channels for
fluid flow (Ruppel and Holtz, 1994).

Figure 6 shows a regional isopach map of the Silurian (combined Fasken and Fusselman formations) with a
red star depicting the Rattlesnake AGI #1 well location. Thickness of the Silurian-age rock is approximately
1,000' at the Rattlesnake AGI #1 well location.

North of Andrews County there is little differentiation between the Fasken and Fusselman formations which
are both carbonate deposits with the potential for sub-areal exposure and porosity development. For
purposes of this MRV Plan, the combined Fasken and Fusselman formations are defined as the injection
interval, and the underlying Montoya formation serves as the lower confining unit.

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LJS8C-C*

."OCKVt*

Explanation



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tHjcicsess tfi)

Apptot	«t pn»r\

Wt>lt«n ploltO'ir m/j'Qtn *•

isr«f»5

ME«U
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Regional Faulting

A major uplift that began during the Pennsylvanian Period to the south, the Central Basin Platform, ceased
in the Early Permian (Wolfcampian), which caused a regional unconformity of the underlying formations
(Hoak, Sundberg, and Ortoleva). Faulting on the Northwest Shelf can be seen through high angle basement
faults that tend to die within the Pennsylvanian strata. These faults predominately represent contractional
(thrust) faults that were initiated during the Pennsylvanian as a result of regional tectonics. Hydrocarbon
traps within the Wristen group are primarily anticlinal structures dependent upon reservoir development
(Broadhead, 2005).

Site Characterization

The Rattlesnake AGI #1 well is located in Section 733, Block D, John H. Gibson Survey, in Yoakum County,
Texas. Stakeholder owns the 82.42-acre surface tract where the plant and Rattlesnake AGI #1 well are
located. The following discusses the geological character of this site.

Stratigraphy and Lithologic Characteristics

Figure 7 depicts an open hole log from an offset well (API No. 42-501-10238) to the Rattlesnake AGI #1 well
indicating the injection and primary upper confining zone. This well is approximately 1.8 miles to the
northwest of the Rattlesnake AGI #1 well.

GR

DT

) 15C

120 1C

{

g
^5





F

-f
4

y

1





L

c

=-



RUSTLER [PUJ=21760
SALADO (PU)=2287 6

TANSIL (PU]=2938 1
YATES (PU]=3022 6

SEVEN_RJVERS [PUl=3273

QUEEN (PU)=3867 4

GRAYBURG (PLJ)=4251 9

SAN ADREAS [PU]=4467 9

TUBB (PU]=7079 2

GLORIETA [PU]=5908 4

CLEARFORK [PU]=6516 0

ABO (PUJ=7678 5

Injection
Zone

WOLFCAMP [PU)=8847 9

E

STRAWN|PU]= 100634

ATOKA IPU]*10261 0

M1SS UME (PU]» 10401 1

WOOOFOKD |PLJ)«11018 5
SILURIAN [PLJl311073 4

Figure 7- Type Log (42-501-10238) with tops, confining and injection zones depicted

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Upper Confining Interval - Woodford Shale

The Woodford is a late Devonian-aged organic-rich shale deposited as a result of a widespread marine
transgression. The flooding event occurred over the majority of the Permian basin, which produced a low-
relief blanket-like shale deposit of the Woodford. Two major lithofacies found within the Woodford are black
shale and siltstone. Nutrient-rich surface waters promoted the decay of abundant organic matter within the
Woodford, resulting in a high total organic carbon ("TOC") percentage. The Woodford shale acts as the
primary source and sealant rock for the Wristen Group (Comer, 1991).

Figure 8 is a description of a core sample taken in Lea County, New Mexico just southwest of the Rattlesnake
AGI #1 well location. This sample is referenced as C9 in the reference map with the blue star representing
the Rattlesnake AGI #1 well. In the core description, black shale with abundant illitic clays is observed in the
upper section, and medium gray dolomitic siltstone found in the basal section. The mineralogic and lithologic
properties recorded in this description serve as excellent sealant characteristics to prohibit any injected fluids
from migrating above the injection interval.

The Woodford at the Rattlesnake AGI #1 well location is encountered at 10,973' and is approximately 63'
thick.

C9

Shell No. 5 Pacific Royalty
Lea County, New Mexico
Section 10, T 15 S - R 37 E
Elevation 3814 ft

I Boilgy	

| Cochron

¦»

| Roosevelt |

jjP	

I Yookum

I

I

"a I ~

CI3	' Goines

Figure 8 - Core description of the Woodford Shale and Upper Silurian (Ruppel and Holtz, 1994)

a
<

I Formation |

'c
ZD

TOC

Weight
percent
1 2 3 4 5

GR

ngm Ra-
eq/ton

12 3 4

Sample no.

Uthology

Thickness 1

xz

s.


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Injection Interval - Fasken Formation

The Rattlesnake AGI #1 well reaches total depth in the Fasken/Fusselman formation (Silurian in age), directly
below the Woodford formation. Dolomites at the top of the Fasken formation underwent multiple leaching
and diagenetic episodes which developed secondary porosity. This is evidenced in offset wells by the practice
of only drilling through the top 30' of the Fasken, in anticipation of encountering the best reservoir quality.
In Figure 8, the uppermost Silurian section is described as 'vuggy dolostone' in the core description. Beds
below the top of the Fasken section may also have similar petrophysical attributes if exposed to multiple
diagenetic events. Solution-collapse and karst breccia horizons can be found within inner platform deposits,
some occurring as much as 100' below the Fasken top (Ruppel and Holtz, 1994).

Porositv/Permeabilitv Development

Porosity in the Fasken formation at the Rattlesnake AGI #1 well location is typically moldic and intercrystalline
associated with leaching of allochem-rich intervals. Porosity is directly related to these leaching events which
occurred during and post-deposition, resulting in vugs and karst-like features. Figure 9 provides reservoir
information from core data within fields in the Wristen buildup and platform carbonate play. The average
porosity of these cores is 7.1% with an average permeability of 45.28 millidarcies (Ruppel and Holtz, 1994).
The porosity and permeability described in the offset core data indicate the Fasken formation provides
sufficient accessible pore space for the amount of fluid injection proposed.

Using the above values as reference points, the Rattlesnake AGI #1 porosity log (API No. 42-501-36998) was
evaluated. Figure 10 is the product of the petrophysical analysis performed on the open hole logs run within
the injection interval at the Rattlesnake AGI #1 well. A permeability curve was generated from the effective
porosity curve using the table in Figure 9 to establish the porosity-permeability relationship. In Figure 10,
the majority of the injection interval's porosity and permeability is found at the top of the Fasken formation,
which correlates with the diagenetic processes described above. These curves are extrapolated to the
injection site and used to establish reservoir characteristics in the plume model.

17


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Wristen







Fusselman

Buildups and

Thirtyone

Thirtyone



Shallow Platform

Platform

Ramp

Deep-Water



Carbonate play

Carbonate play

Carbonate play

Chert play



Porosity (%)





Number of data points

33

30

16

35

Mean

7.93

7.10

6.41

14.85

Minimum

1.00

2.70

3.50

2.00

Maximum

17.70

14.00

Q.50

30.00

Standard deviation

4.01

2.67

1.75

6.76



Permeability (md)





Number of data points

21

24

12

33

Mean

11.61

45.28

1.51

8.56

Mnimum

0.60

2.90

0.40

1.00

Maximum

84.80

400.00

30.00

100.00

Standard deviation

22.48

99.17

8.36

22.23



Initial water saturation (%)





Number of data points

24

28

10

31

Mean

26.96

31.55

24.70

31.46

Mnimum

10.00

20.00

16.00

10.00

Maximum

50.00

55.00

40.00

45.00

Standard deviation

9.31

10.45

7.39

8.33



Residual oil saturation (%)





Number of data points

8

13

5

22

Mean

34.06

30.54

21.30

29.17

Mnimum

30.00

20.00

9.00

14.00

Maximum

50.00

35.00

35.00

48.20

Standard deviation

6.99

4.61

11.66

9.76



Oil viscosity (cp)





Number of data points

11

12

5

21

Mean

0.69

1.16

0.33

0.68

Minimum

0.13

0.32

0.04

0.07

Maximum

1.08

2.00

1.00

1.03

Standard deviation

0.81

0.75

0.40

0.42



Oil formation volume factor





Number of data points

21

22

6

32

Mean

1.67

1.22

1.65

1.50

Mnimum

1.05

1.05

1.31

1.30

Maximum

1.91

1.55

1.66

1.73

Standard deviation

0.28

0.14

0.48

0.16



Bubble-point pressure (psi)





Number of data points

9

9

5

19

Mean

2.272

1,055

3,750

2,752

Minimum

798

450

2,660

1,755

Maximum

4,050

2,600

4,440

4,656

Standard deviation

1.300

689

756

667











Figure 9 - Table of reservoir properties found within the Wristen buildups and platform plays (Ruppel and Holtz, 1994)


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Low Perm

42501369980000
RATTLESNAKE AG I
1

STAKEHOLDER GAS SERVICES

0

[PLJ]=11036.9

Figure 10 - Rattlesnake AGI ffl open hole log (42-501-36998) with effective porosity (green) and permeability (black)

Formation Fluid

Four wells were identified through a review of chemical analyses of oil-field brines from the U.S. Geological
Survey National Produced Waters Geochemical Database v2.1 within the Devonian, Silurian-Devonian, or
Fusselman formations within 20 miles of the Rattlesnake AGI #1 well. The location of these wells is shown in
Figure 11. Water chemistry analyses conducted on oil-field brines in Gaines County, as reported to the Texas

19


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Water Development Board, provided additional data on Devonian and Silurian reservoir fluids. Results from
the synthesis of these two sources are provided in Table 1. The fluids have greater than 20,000 parts per
million ("ppm") total dissolved solids, therefore these aquifers are considered saline. These analyses indicate
the in-situ reservoir fluid of the Devonian, Silurian, and Fusselman formations are compatible with the
proposed injection fluids.

Table 1 - Analysis of Silurian-Devonian age formation fluids from nearby oil-field brine samples



Average

Low

High

Total Dissolved Solids (ppm)

41,428

23,100

55,953

pH

7,2

7.0

7.3

Sodium (ppm)

12,458

7,426

15,948

Calcium (ppm)

1,759

1,010

2,320

Chlorides (ppm)

23,423

12,810

31,930

Fracture Pressure Gradient

Fracture pressure gradient was estimated using Eaton's equation. Eaton's equation is commonly accepted
as the standard practice for the determination of fracture gradients. Poisson's ratio ("v"), overburden
gradient ("OBG"), and pore gradient ("PG") are all variables that can be changed to match the site-specific
injection zone. Through literature review and industry standards, we are able to determine the expected

20


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fracture gradient. First, 1.05 psi/ft and 0.465 psi/ft were assumed for both the overburden and pore
gradients, respectively. These values are considered best practice values when there are no site-specific
numbers available. For limestone/dolomite rock, the Poisson's ratio to be assumed to be 0.3 through
literature review (Molina, Vilarras, Zeidouni 2016). Using these values in the equation below, a fracture
gradient of 0.72 psi/ft was calculated. A 10% safety factor was then applied to this number resulting in
maximum allowed bottom hole pressure of 0.64 psi/ft. This was done to ensure that the injection pressure
would never exceed the fracture pressure of the injection zone.

For the upper confining interval, a similar fracture gradient as the limestone was calculated. Shale has an
increased chance to vertically fracture if the injection interval is fractured (Molina, Vilarras, Zeidouni 2016),
so assuming a Poisson's ratio equal to the injection interval was used as a conservative estimate. The lower
confining zone was assumed to be of a similar matrix to that of the injection interval, with the key difference
being that the formation is much tighter (lower porosity/permeability). The Poisson's ratio was assumed to
be slightly higher in this rock. As seen in Table 2, the fracture gradient is slightly higher than the upper zones.

Table 2 - Fracture Gradient Assumptions



Injection Interval

Upper Confining

Lower Confining

Overburden Gradient (psi/ft)

1.05

1.05

1.05

Pore Gradient (psi/ft)

0.465

0.465

0.465

Poisson's Ratio

0.30

0.30

0.31

Fracture Gradient psi/ft

0.72

0.72

0.73

FG +10% Safety Factor (psi/ft)

0.64

0.64

0.66

The following steps were taken to calculate fracture gradient:

FG = —— (OBG - PG) + PG
1 — v

0.3

FG = l_Q3(1.05 - 0.465) + 0.465 = 0.72
FG with SF = 0.72 x (1 - 0.1) = 0.64

Lower Confining Zone - Montoya Formation

The low-permeability Montoya Formation is a tight limestone/dolomite that will act as the lower confining
unit for the injection interval. Figure 10 shows the decreasing trend in porosity of the limestone rock in the
lower section that was not exposed to leaching diagenesis. Porosity in the lower section can range from 2-
3% with permeabilities below 1 millidarcy. The Rattlesnake AGI #1 well drilled 6' into the Montoya formation,
but the section was not logged. The Montoya is anticipated to be roughly 250' thick. These petrophysical
characteristics represent ideal sealing properties to prohibit any migration of injected fluid outside of the
injection interval.

Local Structure

Regional structure in the area of the Rattlesnake AGI #1 well is dictated by carbonate buildups and structural
events causing anticlinal to synclinal features throughout the area. The Rattlesnake AGI #1 well is specifically
located at the base of a syncline with anticlinal features to the northeast, south, and east. Figure 12 is a

21


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structure map of the Silurian formation of subsea depths with the star representing the location of the
Rattlesnake AGI #1 well. The red and blue lines represent the cross-section reference lines.

Faulting can be seen to the south and east of the Rattlesnake AGI #1 well location. These faults were
interpreted from roughly 9 square miles of 3D seismic indicated by the purple outline in Figure 12. Many of
these faults are minor, with offsets less than 50'. The nearest large fault is found southeast of the Rattlesnake
AGI #1 well and has an offset of roughly 120'. None of these faults project above the Wolfcamp formation,
rather, they appear to terminate between the Strawn and base of the Wolfcamp formation. Production is
associated with a hydrocarbon trap set up by the larger fault to the southeast, indicating the fault is vertically
sealing in nature. If, in the unlikely event the faults' sealing properties are compromised post-injection,
secondary confinement is provided by the tight limestones found within the overlying Mississippian Lime
formation along with shale layers found in the Atoka and Wolfcamp formations. As seen in Figure 14, the
largest fault found southeast of the Rattlesnake AGI #1 well terminates within the Atoka formation. Though
it crosses the Silurian section, this fault thrusts the Mississippian Lime upward against the Atoka shales. The
tight reservoir characteristics of the Mississippian Lime and shaley section of the Atoka create a confining
environment vertically and laterally to contain potential upward migration of buoyant fluids. Shales within
the Wolfcamp formation provide additional confining beds between overlying USDWs and the fault plane.
Figures 13 and 14 are north-south and west-east structural cross sections showing the structural dips. As
seen in these figures, the Woodford formation is laterally present above the injection interval, alleviating risk
of erosion of the upper sealant formation.

Larger versions of Figures 12, 13 and 14 are provided in Appendix A.

22


-------
I

5600
M50
5700
5750
5800
5850
5900
•5950
-6000
¦6050
-©100
-6150
-6200
•6250
•6300
•6350
-6400
-6450
-6500
•6550
-6600
•6650
•6700
¦6750
-6800
-€850
•6900
-6950
-7000
-7050
-7100
-7150
-7200
•7250 |
-7300
-7350
-7400
-7450
-7500
•7550
•7600
-7650
-7700
-7750
-7800
-7850
-7900
-7950
-8000
-8050
-8100
-8150

B Any Raster

Figure 12 - Silurian Structure Mop (subsea depths)

23


-------
42501340160000
RANDALL. E

43

EXXON MOBIL

ABOIPU1

VYOLFCAMP IplJ1

Figure 13 - Structural Northeast-Southwest Cross Section

24


-------
42501358340000
ROBERTS UNIT
2

APACHE
a

42501335110000
CORNELL UNIT

3019D
EXXON MOBIL

42501105700000
1-667

TEXAS CRUDE OIL CO
+

<14,201 FT>

42501369980000
RATTLESNAKE AG I
1

STAKEHOLDER GAS SERVICES

<-1 n 51 fiFT^,


-------
Injection and Confinement Summary

The Iithologic and petrophysical characteristics of the Faskeri and Fusselman formations at the Rattlesnake
AGI #1 well location indicate the formations have sufficient thickness, porosity, permeability, and lateral
continuity to accept the proposed injection fluids. The Woodford formation shale at the Rattlesnake AGI #1
well has low permeability and is of sufficient thickness and lateral continuity to serve as the upper confining
zone. Beneath the injection interval, the low permeability, low porosity Montoya formation is unsuitable for
fluid migration and serves as the lower confining zone. Deeper, laterally continuous formations, including the
Simpson Group, provide additional confinement.

Groundwater Hydrology

Yoakum County falls within the boundary of the Sandy Land Underground Water Conservation District. Three
aquifers are identified by the Texas Water Development Board's Aquifers of Texas report in the vicinity of the
proposed Rattlesnake AGI #1 well: the Dockum Aquifer, Edwards-Trinity Aquifer, and Ogallala Aquifer
(George, Mace and Petrossian, 2011). Table 3 references the aquifers' positions in geologic time and the
associated geologic formations. A schematic cross section in Figure 15, near the proposed Rattlesnake AGI
#1 well, illustrates the structure and stratigraphy of these water-bearing formations. Groundwater flow
direction is the same for the three aquifers, generally from northwest to southeast, Figure 16 (Teeple, et al.,
2021).

Table 3 - Geologic and hydrogeologic units with accompanying lithologic descriptions near Gaines, Terry and Yoakum Counties, Texas
(Teeple, etal. 2021)

Era

Period

Epoch or series

Geologic unit group
or formation

Lithologic descriptions

Hydrogeologic unit

Cenozoic

Tertiary

Pliocene

Ogallala Formation

Gravel, sand, silt,
and clay

High Plains
aquifer system
(Ogallala aquifer)

Miocene

Mesozoic

Cretaceous1

Comanchean
Series

Washita Group"

Shale and limestone

Ed wards-T rinity
(High Plains)
aquifer system

Fredericksburg Group

Clay, shale, and
limestone

Trinity Group

Sand and gravel

T riassic

Upper

Dockum Group

Siltstone, mudstone,
shale, and sandstone

Dockum aquifer

26


-------
Cretaceous
clay/shale

3,600
3,500

~ 3'400

J3 3,300
£ 3,200
nj 3.100
^ 3,000
2,900
2,800
2.700

Gaines	< Yoakum

' *

Terry ! Hockley

B-B1

Lubbock

Ogallala
Formation

Triassic
Dockum Group

Cretaceous Antters Formation

Figure 15 - NW-SE Cross Section of aquifers in the Rattlesnake AGlttl well area (George, Mac and Petrossian, 2011)

27


-------
•HOCKLfcVCOrXTV B 103^'
33=70'

4IOC'KLE\ CQI'NTV

I /C^a 7 • V •

i• "	/ 62 \ .	# , "



L^Z-HOCKLEY C 01 NT\

ft

I I w	r |

33°ai	- vbakim V ~'	rr-5'-cr) ~

V \ ,/imm A	}*!J Uii

jvi-	. ' \	' kchlMtA'

l'

GSS,*f \ ,

y,/ n«uu s y "

WoytMl+ifiL-



r	x '< V' \	<'''

i-	.Y	J	'	\ -l

I	Denscry«y^~-^s.« Ys— - 		^^ 1 ' ^

I. *	a /	iv'r.i -V%« i1 gi	I

D 5 10 IS MILES
i i 11 i1—J

o 5 ra iskmmetbb

Base modified from U S Geological Survey 1 250,000-seals to 1.2,000,000- scale digital data,
Universal rransverne Mercator projection, zone 13
North American Datum of 1983

Groundwater love I altitude, in
feel above North American
Vertical Datum of 1983

¦ >3.750
kiT 3-MO
3,250
3,000
<2,750

I

EXPLANATION

Study area boundary

Edwards-Trinity IHigh Plains! aquifer downdip extent
Underground water conservation district boundary

llano Estacado Underground Water Conservation District
Sandy Land Underground Water Conservation District
South Plaint Underground Water Conservation District

Potantiometric contour Shows attitude at
which water level would have stood in
tightly cased wells. Contour interval i$
100 feet Datum is North American
Vertical Datum of 1968 Dashed where
inferred.

Groundwater low paths - Dashed whero
inferred

Groundwater level measurement I Payne
end others, 2020)

Figure 16 - Potentiometric surfaces from wells completed in A, Ogallala aquifer, B, the Edwards-Trinity aquifer and C, the Dockum
aquifer (George, Mace and Petrossian, 2011).

The Dockum Aquifer is the oldest of the three aquifers, formed from Triassic-age Dockum Group sediments,
and underlies the Cretaceous Trinity and Fredericksburg Groups (Teeple, et al., 2021). Figure 17 shows the
subsurface and outcrop extent of the Dockum Aquifer. As shown in Figure 18, the total dissolved solids in
western Yoakum County exceed 5,000 milligrams per liter ("rrig/L"), therefore the aquifer is considered
brackish.

28


-------
Dockum

Aquifer

Figure 17- Regional extent of the Dockum freshwater aquifer (TWDB)

Figure 18 - Total dissolved solids in groundwater from the Dockum Aquifer (Ewing et at, 2008)

The Edwards-Trinity Aquifer is a collection of Cretaceous age sediments - primarily the Trinity Group Antlers
formation sandstone and limestones of the Fredericksburg Group, specifically the Comanche Peak and
Edwards formations. Figure 19 shows the subsurface and outcrop extent of the Edwards-Trinity Aquifer.
Freshwater infiltration to this aquifer is primarily from the overlying Ogallala Aquifer (George, Mace and
Petrossian, 2011).

29


-------
The Ogallala aquifer consists of sand, gravel, clay and silt sediments (George, Mace and Petrossian, 2011) and
produces the majority of the freshwater for Yoakum County. Figure 19 shows the subsurface and outcrop
extent of the Ogallala Aquifer.

The base of the deepest aquifer is separated from the injection interval by approximately 9,500' of rock,
including 650' of Salado salt. Though unlikely for reasons outlined in the confinement and potential leaks
sections, if migration of injected fluid did occur above the Woodford Shale, thousands of feet of tight
sandstone, limestone, shale, salt and anhydrite beds occur between the injection interval and the lowest
water-bearing aquifer.

30


-------
The TRRC's Groundwater Advisory Unit ("GAU") identified the base of Underground Sources of Drinking
Water ("USDW") at 2,250' at the location of the Rattlesnake AGI #1 well. Therefore, there is approximately
9,470' separating the base of the USDW and the injection interval. A copy of the GAU's Groundwater
Protection Determination letter issued by the TRRC as part of the Class II permitting process for the
Rattlesnake AGI #1 well is provided in Appendix B

Description of the Injection Process
Current Operations

The 30-30 Facility and its associated Rattlesnake AGI #1 well began operating in March of 2019. Since
operations began, 258 million cubic feet ("MMCF") of treated acid gas ("TAG") has been injected, which
equates to 12,316 metric tons of C02. Over the life of the injection period, the average daily injection rate
has been 223 MSCF/d. The approximate current composition of the TAG stream is as follows:

Table 4 - Gas Composition of 30-30 Facility outlet

Component

Mol %











1.12%

31


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The 30-30 Facility is designed to compress, treat, and process natural gas produced from the surrounding
counties in Texas and New Mexico. The gas is dehydrated to remove the water content, then processed to
separate natural gas liquids which are then sold, along with the pipeline quality natural gas, to various
customers. TAG is then directly routed from the plant amine regen system to the Rattlesnake AGI #1 well.
The facility is manned 24 hours per day, 7 days per week.

Planned Operations

Stakeholder anticipates increasing the amount of C02 injected into Rattlesnake AGI #1 well from the current
rate up to 16 MMSCF/d. Additional growth is expected both at Stakeholder facilities and regionally as rising
sour gas production and flaring reduction mandates create the need for additional CO2 and H2S disposal
capacity. Stakeholder plans to inject into this AGI well for another 14 years for a total of 17 years from the
start of injection in 2019.

Figure 21 shows a high-level view of the current process flow plus the prospective additional operations over
time.

>96% C02
1,090-1,150 psig

CO, Offtake

13% H2S, 87% C02

Prospective Facilities

Meter

I	

er XV



1,400-2,200 psig

|

Amine Regen

AGI 1

	*j, 1	~r

System

Compression |

11 w i

Meter :

~

!_

1

1

£-13% H2S, 87%-

95% C02
1,400-5,900 psig

Injection
Pumps

H£It

S-1

XV

Current Operation

AGI
Well

Figure 21 - 30-30 Facility Process Flow Diagram

Reservoir Characterization Modeling

The modeling software used to evaluate this project was Computer Modelling Group's GEM 2020.11 ("GEM")
simulator. Computer Modelling Group ("CMG") has put together one of the most accurate and technically
sound reservoir simulation software packages for conventional, unconventional, and secondary recovery.
GEM utilizes equation-of-state ("EOS") algorithms along with some of the most advanced computational
methods to evaluate compositional, chemical, and geochemical processes and characteristics to produce
highly accurate and reliable simulation models for carbon injection and storage. The GEM model is
recognized by the EPA for use in area of review delineation modeling as listed in the Class VI Well Area of
Review Evaluation and Corrective Action Guidance document.

The Silurian (Fasken/Fusselman) formation is the target formation for Rattlesnake AGI #1 well. The Petra
software package was used to create the geologic model of the target formation. The faulting and geologic
structure was then imported into GEM and used to create contours for the model grid.

32


-------
Porosity and permeability estimates were determined using the porosity log from the Rattlesnake AGI #1
well and a petrophysical analysis was performed to correlate porosity values by depth with core porosities
as shown in the Holtz paper. The Coates permeability equation was then used to calculate permeability with
depth. Both porosity and permeability are assumed to be laterally homogeneous in the reservoir.

The reservoir is assumed to be at hydrostatic equilibrium and initially saturated with 100% brine. An infinite
acting reservoir was created to simulate boundary conditions. The gas injectate is composed of H2S, C02,
CH4, and other components as shown in Table 5. Core data from literature review was used to determine
residual gas saturation (Ruppel and Holtz, 1994). The modeled composition only takes into consideration the
carbon dioxide and hydrogen sulfide as they comprise nearly 99% of total stream. For the initial injection
period, these compositions are normalized up to 100%. For the proposed additional injection period, it is
expected that a larger portion of the gas added is carbon dioxide, changing the composition to ~93% C02 and
~7% H2S.

Table 5 - Modeled Initial Gas Composition



Measured Current

2019-2024 Model

2024-2036 Model

Component

Composition (mol%)

Composition (mol%)

Composition (mol%)

Carbon Dioxide (C02)

89.678

90.696

92.921

Hydrogen Sulfide (H2S)

9.200

9.304

7.079

Methane (CI)

0.303

0

0

Ethane (C2)

0.058

0

0

Propane (C3)

0.108

0

0

N-Butane (NC4)

0.025

0

0

Hexane Plus (C6+)

0.628

0

0

Core data from literature review was used to determine relative permeability curves between carbon dioxide
and the connate brine within the Silurian-Devonian carbonates (Ruppel and Holtz, 1994). The key inputs
used in the model include an irreducible water saturation of 25% and a maximum residual gas saturation of
21%.

The grid contains 141 blocks in the x-direction (E-W) and 201 blocks in the y-direction (N-S), totaling 28,341
grid blocks per layer. This results in the grid being 21,150' by 30,150' totaling just over a 23-square mile area
(14,640 acres). Each layer in the model was determined by identifying higher permeability zones as targets
for injection from the logs and assigning each high permeability and intermediary low permeability zone its
own layer. One zone was identified as being a karst limestone (layers 2-7). Due to the "karsted" nature of
this rock, it was determined that most of the injectate would flow into this zone. Therefore, the karst
limestone was further split into layers by permeability to provide higher resolution and more accurately
simulate which layer will have the greatest gas flows. Figure 22 provides a detailed breakdown of the
"karsted" rock.

33


-------
Permeability Distribution of Karst Zone

2

3

4


n:

—i

5

6

7

1	10	100	1000

Permeability (mD)

Figure 22 - Permeability Distribution of Karst Limestone

In total, there are sixteen (16) layers in the model, representing ten (10) layers of pay and six (6) layers of
intermediary low permeability zones. The properties of each of these layers are summarized in Table 6
below.

Table 6 - CMG Model Layer Properties

Layer #

Top (ft)

Thickness (ft)

Permeability (mD)

Porosity

1

11,037

71

1

2.8%

2

11,108

57

47

8.0%

3

11,165

19

223

11.9%

4

11,184

16

15

6.3%

5

11,200

39

70

9.2%

6

11,238

11

228

12.3%

7

11,249

21

49

8.3%

8

11,270

251

2

3.7%

9

11,520

46

9

5.6%

10

11,566

13

3

4.3%

11

11,579

19

17

6.5%

12

11,597

14

2

3.9%

13

11,611

103

13

6.0%

14

11,714

46

2

3.7%

15

11,759

67

23

6.1%

16

11,826

125

2

3.6%

34


-------
Simulation Modeling

The primary objectives of the model simulation were to:

1)	Estimate the maximum areal extent and density drift of the acid gas plume after injection

2)	Assess the impact of offset saltwater disposal ("SWD") well injection on density drift of the plume

3)	Assess the impact of offset producing wells on the density drift of the plume

4)	Determine the ability of the target formation to handle the required injection rate without
fracturing the injection zone

5)	Assess the likelihood of the acid gas plume migrating into potential leak pathways

The reservoir is assumed to be an aquifer filled with 100% brine. The salinity of the formation is estimated
to be 53,000 ppm (Texas Water Development Board, 1972). The acid gas stream is primarily composed of
C02 and H2S as stated previously. Core data was used to help generate relative permeability curves. Cores,
from the literature reviews previously discussed, that most closely represent the vuggy carbonate seen in
this region were identified and the Corey-Brooks equations were used to develop the curves. The lowest
residual gas saturation found in the cores was then used for a conservative estimate of plume size. From
offset injection well analysis, the initial reservoir pressure was determined to be 5,132 psi which is equivalent
to a 0.465 psi/ft pressure gradient. The fracture gradient of the injection zone was estimated to be 0.72
psi/ft, which was determined using Eaton's equation. A 10% safety factor was then applied to this number,
putting the maximum bottom-hole pressure allowed in the model at 0.64 psi/ft which is equivalent to 7,064
psi.

The model also takes into account offset saltwater disposal ("SWD") injection volumes within five (5) miles
of the Rattlesnake AGI #1 well. These SWDs create a pressure front that push the plume further up-dip of
the formation. A total of twenty (20) offset wells currently injecting into the target formation were identified.
Eleven (11) of these offset SWDs were out of the confines of the grid, but were still accounted for in the
model. Nine (9) salt-water disposals were modeled within the boundaries of the 23-square-mile grid. Two
(2) of these offset injectors are currently only permitted (not drilled) but were assumed to start active
injection within the first year of the model. Both permits were simulated at the forecasted injection rate
schedule for 30 years. These forecasts were provided by the operators of these wells. Historical injection
rates of each of the other existing wells were analyzed and projected into the model. This simulation includes
the effect of water injection on the density drift of the plume and bottom hole pressure.

Further review of the area revealed production wells in the Silurian-Devonian formation that could impact
the density drift of the plume by creating a "pressure sink". A "pressure sink" is an area of lower pressure
caused by the production of formation fluids. To simulate this effect, nine (9) production wells were grouped
together and their respective production rates combined into a single well to add more conservatism into
the model. These producers were forecasted an additional 15 years to simulate their potential economic
lifespan. This simulation includes the effect of fluid production on the density drift of the plume and bottom
hole pressure. Overall, the "pressure sink" has little effect on the density drift and, as discussed below, the
plume never reaches the producing wells.

The model runs for a total of 814 years, starting in 1965 with the beginning of offset production until the
calculated stabilization of the plume in 2779. The injection of TAG from Rattlesnake AGI #1 is modeled from
the beginning of injection in 2019 through the planned 14 years of future injection. The model also includes
the 57 years of historical plus 15 years of forecasted future oil and gas production.

Additionally, historical monthly injection rates of all nearby SWDs were incorporated into the model to
simulate any additional near-wellbore pressure increase that may occur due to offset injection. The

35


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modelling of the saltwater injection begins in 1984 when the first offset SWD well became operational. The
SWDs to the North were grouped into four (4) separate groups to simulate their combined effect on the
density drift of the plume. All offset injection wells and their groupings are included in Table 7. All offset
production wells are listed in Table 8.

Table 7-All Offset SWDs included in the model

Grouping

API

Well Name

Well#



42-501-32511

SAWYER, DESSIE

1



42-501-02068

WEST, M. M.

2

Group 1

42-501-02053

NORTH CENTRAL OIL CO. "A"

1



42-501-01453

SMITH, EDS. HEIRS "B"

1



42-501-02059

SMITH, ED "C"

1W

Group 2

42-501-30051

JOHNSON

2

42-501-30001

JOHNSON

ID

Group 3

42-501-37066

MISS KITTY SWD 669

1W

42-501-36650

RUSTY CRANE 604

1W

Group 4

42-501-36745

SUNDANCE 642

1

42-501-33887

WINFREY 602

3WD



42-501-37252

Miller SWD

7



42-501-37367

BLONDIE 704

1W



42-501-37206

BRUSHY BILL 707

1WD



42-501-36622

WISHBONE FARMS 710

1W

Standalone

42-501-35834

ROBERTS UNIT

2



42-501-33297

STATE ELMORE

1



42-501-10238

SHEPHERD SWD

1



42-501-33511

CORNELL UNIT

3019D



42-501-32868

WILLARD UNIT

1WD

Table 8 - All Offset Producers included in the model

API

Well Name

Well#

42-501-10046

ELLIOTT, C.A.

2

42-501-10079

RANDALL, E

32

42-501-337932

RANDALL, E

40

42-501-33885

RANDALL, E

41L

42-501-34016

RANDALL, E

43 L

42-501-34017

RANDALL, E.

45 L

42-501-34023

RANDALL, E

42 L

42-501-34024

RANDALL, E

44

42-501-35418

RANDALL, E

46

Rattlesnake AGI #1 came online in 2019 and the model simulated its historical monthly injection rates until
2024. After this initial period, it is conservatively assumed that the injection rate increases to the maximum
permitted rate of 16 MMSCF/d for the remainder of the active injection period in 2036. At this point, the

36


-------
Rattlesnake AGI #1 well stops injection while the offset SWD injectors continue operations for thirty more
years. Density drift then occurs until plume stabilizes, which was determined to be 814 years from the start
of the model in 1965. Stabilization of the plume is determined to occur when the model shows no further
lateral movement horizontally or vertically. The plume boundary is then defined by a weighted average gas
saturation in the aquifer of 3%.

The maximum plume extent during the 17-year Rattlesnake injection period is shown in Figure 23. The final
extent after 743 years of density drift after injection ceases is shown in Figure 24. The extensive time of the
modeled density drift of the plume is driven by the buoyant forces of the gas, the permeability/porosity of
the rock, and the residual gas saturation. Initially, the karsted region takes on most of the injection, but due
to the buoyant forces, it is slowly pushed up higher into the less permeable layers of the injection interval.
These lower permeable layers increase the amount of time it takes for the plume to reach its maximum areal
extent. As all the inputs to the model were based on the most conservative approach, the maximum extent
of the plume will likely be smaller and the effective impact on reaching potential leakage pathways will be
minimal as the amount of C02 at those far extents will be small. Throughout the entirety of the density drift
period the plume does not intersect any likely leakage pathways.

State Elmore

Brushy Bills 707

Shepherd SWD

Rattlesnake AGI Plume
Global Mole Fraction(CQ2) 2036-Jan-0) K Rone: 2 of 16

Group 2 Group 4 Group 3 Group 1

9,170'







Blondie 704

Miller SWD

I

1

i



Rattlesnake AGI

	

6,452' ] ¦





*¦

S

Willard Unit



~

Roberts Unit

Production Wells

Cornell Unit

Figure 23 -Areal View Gas Saturation Plume, 2036 (End of Injection)

37


-------
Rattlesnake AGI

State Elmore

Brushy Bills 707

Shepherd SWD

Rattlesnake AGI Hume
Global Mole Froctior*(CQ2) 2779-Dec-OI K Plane: 2 of 16

-0.70

¦ -0 60

0.90
-080

Blondie 704

Miller SWD

6,900

Willard Unit

Roberts Unit

Cornell Unit

Group 2

Group 4

Group 3

Group 1

Production Wells

Figure 24 - AreaI View Gas Saturation Plume, 2779 (End of Density Drift)

Figure 25 shows the surface injection rate and bottom hole pressure over the injection period and the period
of density drift after injection ceases. The bottomhoie pressure increases the most as the injection rate
reaches its peak, reaching a maximum pressure of 5,413 psi. This buildup of 280 psi keeps the bottomhoie
pressure well below the fracture pressure of 7,064 psi. The maximum surface pressure associated with the
maximum bottomhoie pressure reached is 2,494 psi.







































































		





















V



























































mufii

ipr



































C—1

































2021 2023 2025 2027 2029 2031 2033 2035 2037 2039 2041 2043 2045 2047 2049 2051 2053 2055

—	Rattlesnake AGI, Gas Rate SC - Daily

—	Rattlesnake AGI, Well Bottom-hole Pressure

Figure 25 - Well Injection Rate and Bottomhoie Pressure over Time

38


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SECTION 3 - DELINATION OF MONITORING AREA

This section discusses the delineation of Maximum Monitoring Area ("MMA") and Active Monitoring Area
("AMA") as described in EPA 40 CFR §98.448(a)(l).

Maximum Monitoring Area

The MMA is defined as equal to or greater than the area expected to contain the free-phase C02 plume until
the CO2 plume has stabilized plus an all-around buffer zone of at least one-half mile. Numerical simulation
was used to predict the size and drift of the plume. With CMG's GEM software package, reservoir modeling
was used to determine the areal extent and density drift of the plume. The model takes into account the
following considerations:

•	Offset well logs to estimate geologic properties

•	Petrophysical analysis to calculate the heterogeneity of the rock

•	Geological interpretations to determine faulting and geologic structure

•	Offset injection history to adequately predict the density drift of the plume

Acid gas injectate was analyzed by a third-party vendor to determine the initial composition used in the
model. The report is provided in Appendix C. The molar composition of the gas is primarily C02 with some
H2S and CH4. The change in molar composition was also incorporated into the model as future predominantly
CO2 streams are added for injection. As discussed in Section 2, the gas was injected into the Silurian
formation, specifically, the Fasken/Fusselman formation. The geomodel was created based off the rock
properties seen in the Fasken/Fusselman.

The plume boundary was defined by the weighted average gas saturation in the aquifer. A value of 3% gas
saturation was used to determine the boundary of the plume. When injection ceases in 2036, the areal
expanse of the plume will be 1,052 acres. The maximum distance between the wellbore and the edge of the
plume is approximately 0.87 miles to the southeast. After 743 additional years of density drift, the areal
extent of the plume is 2,177 acres with a maximum distance to the edge of the plume of approximately 1.35
miles to the southeast.

Figure 26 shows the plume boundary at the end of injection, the stabilized plume boundary and the MMA.

39


-------




Rattlesnake ACI No. 1
luee Boundary at End of Injection
& Stabilized Plume
with

1/2-Hile Maximun Monitoring Area (MH/

Stakeholder Midstream

	Yoakum Co,. TX	

PCS: KADB3 TX-NC FIPS 4202 (US 1.)	

Drawn ay: ER | Pre: 5/31/2022 | Approved by R1

LONQUIST & CO LLC

+ R«t*sn»kt Ml No. 1 $H I

ile luffer from Mm, Hume E«tent IMMAj

©

I

3

S !

' Plume lousdtry at End of Iryeciion

1 Inch = 0.S1 Mile

0 54 V, X 1

\

m
~



Figure 26 - Plume Boundary at End of Injection, Stabilized Plume Boundary, and Maximum Monitoring Area

Active Monitoring Area

The initial AMA will cover a 14-year monitoring period. This period equates to the time of expected future
injection. The AMA will be established by superimposing the area based on a half-mile buffer around the
anticipated plume location at the end of injection (2036) with the area of the projected free-phase C02 plume
at five additional years (2041). In this case, the plume boundary in 2041 is within the plume at 2036 plus a
half-mile buffer. By 2036 at the latest, a revised MRV will be submitted to define a new AMA. Figure 27 shows
the area covered by the AMA.

40


-------
1 Inch = 0.51 Nile
1:32,000 gj

ffi



fl}

Rattlesnake ACI No. 1
PI use Boundary at End of Injection
& 19-Year PI use
with

l/2-H-ile Active Monitoring Area (AHA)

Stakeholder Midstream

	Yoakum Co.. TX	

PCS: NAD S3 TX-NC Fl^S 4202 (US Ft.)

Prawn ny. EP |	5; 31 /20: | Apcr:ved by- RH

LtMQUIST t CO LLC
I'liili"!

+ Rct«:-ikt I

ne louadarv *t End of iwj

m

r ~

Figure 27-Active Monitoring Area

41


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SECTION 4 - POTENTIAL PATHWAYS FOR LEAKAGE

This section identifies the potential pathways for C02 to leak to the surface within the MMA and the
likelihood, magnitude and timing of such leakage. The potential leakage pathways are:

•	Leakage from surface equipment

•	Leakage through existing wells within MMA

•	Leakage through faults and fractures

•	Natural or Induced Seismicity

•	Drilling through the MMA

•	Leakage through the confining layer

Leakage from Surface Equipment

The surface facilities at the 30-30 Facility are designed for injecting acid gas containing H2S, and therefore
minimize leakage points such as valves and flanges following industry standards and best practices. H2S gas
detectors are located around the facility and the well site. These gas detectors trigger alarms at 10 parts per
million ("ppm"). Additionally, all Stakeholder field personnel are required to wear H2S monitors which are
triggered at 5 ppm of H2S. A shut-in valve is located at the wellhead and is locally controlled by pressure,
with a high pressure and low pressure shut-off.

The facilities have been designed and constructed with additional safety systems to provide for safe
operations. These systems include Emergency Shutdown ("ESD") valves to isolate portions of the plant and
pipeline, pressure relief valves along the pipeline to prevent over pressurization, and flares to allow piping
and equipment to be de-pressured rapidly under safe and controlled operating conditions in the event of a
leak. Figures 28 and 29 display the facility safety plot plan, taken from the 30-30 H2S Contingency Plan, and
show the location of the H2S monitors in the vicinity of the plant and the Rattlesnake AGI #1 well. Should
Stakeholder construct additional C02 facilities, as indicated in Figure 21, a separate meter will be installed for
the additional stream in order to comply with the 40 CFR §98.448(a)(5) measurement. As this meter will be
in close proximity to the existing facilities, it will utilize the existing monitoring programs discussed previously.
Additionally, C02 monitors will be installed near the new meter and tied into the facility monitoring systems.

42


-------
Figure 28 - Site Plan, 30-30 Facility

43


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With the level of monitoring at the 30-30 Facility and the Rattlesnake AGI #1 well, any release of H2S and C02
would be quickly identified, and the safety systems would quickly minimize the volume of the release. The
CO2 injected into the Rattlesnake AGI #1 is injected with H2S at a concentration of 10% (100,000 ppm). At
this high level of H2S concentration, even a small leakage would trigger personal and facility H2S monitors set
to alarm at 5 ppm and 10 ppm respectively. If any leakage were to be detected, the volume of CO2 released
will be quantified based on the operating conditions at the time of release, as stated in Section 7 in
accordance with 40 CFR §98.448(a)(5).

A larger scale version of Figure 27 is provided in Appendix D.

Leakage from Wells in the Monitoring Area
Oil and Gas Operations within Monitoring Area

A significant number of wells have historically been drilled within the area of the Rattlesnake AGI #1 well,
however production has primarily been from the shallower San Andres formation in the Wasson Field. The
San Andres is separated from the Silurian-Devonian interval by 4,720' in this area. In addition to the primary
San Andres production, a few wells have produced from the Wolfcamp The Wolfcamp is separated from the
Siluro-Devonian interval by is 1,800'. Within the projected plume area of the Rattlesnake AGI #1 well, there
are no penetrations of the injection interval. There are ten wells within the MMA that penetrate the
injection interval.

All of the wells which penetrate the injection interval within the MMA were properly cased and cemented to
prevent annular leakage of CO2 to the surface. The plugged wells are also adequately protected against
migration from the Devonian by the placement of the plugs within the wellbores. Additionally, the
Rattlesnake AGI #1 well was designed to prevent migration from the injection interval to the surface through
the casing and cement placed in the well, as shown in Figure 29. Mechanical integrity tests ("MIT") required
under TRRC rules are run annually to verify the well and wellhead can hold the appropriate amount of
pressure. If the MIT were to indicate a leak, the well would be isolated and the leak mitigated quickly to
prevent leakage to the atmosphere.

A map of all wells within the MMA is shown in Figure 30. Figure 31 shows only those wells which penetrate
the injection interval within the MMA. The MMA review maps, a summary of all the wells in the MMA and
detailed wellbore schematics for those wells which penetrate the injection interval are provided in Appendix
D.

44


-------
4.500' -
5,000- -
5.500' -

Base of USDW@375'

Rustler @ 2,345'

Salado @ 2,443'

Yates @ 3,019'

Seven Rivers @ 3,440' *

dK

Grayburg @ 4,190'
San Andres @ 4,465'

DV Tool @4,275'

DV Tool @5,591'

Glorieta @ 6,316'
Clearfork @ 6,492'

Wichita @ 8,628'

13.000'
13.500'



Upper Wolfcamp @ 9,239'

Strawn @ 10,030'
Atoka @ 10,230*

Woodford @ 10,973'
Devonian @11,036'
Wristen @ 11,268'
Fusselman @ 11,538'
Montoya @ 11,974'

Lr

DV Tool @9,575'
Packer @ 10,966'

TD@ 11,980'

KB:

N/A

BHF:

NA

GL:

3,627'

Spud:

5/27/2018

Casing/Tubing Information

Label

1

2

3

4

Type

Surface

Intermediate

Production

Tubing

OD

13-3/8"

9-5/8"

7"

3-1/2"

Weight

48

40

29

9.2

WT

.330

.395

408

NA

Grade

H40/J55 STC

L- 80 BTC

L80 LTC
2535 Vam Top:

L80 Vam Top:
G3 Vam Top'

Hole Size

17-1/2"

12-1/4"

8 3/4

6"

Depth Set

504'

5,498'

11,014'

10,966'

TOC

Surface

Surface

Surface

NA

Volume

510 sks

2,135 sks

760 sks

NA

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

HOUSTONICALGARY
AUSTIN I WICHITA I DENVER

Stakeholder Midstream

Country: USA

Location: 33.07884, -103.904514

API No: 42-501-36998

Rattlesnake No. 1

State/Province: Texas

Site:

County/Parish: Yoakum

Survey:

Well Type/Status: AGI

Texas License F-9147

RRC District No:

Project No: LS 128

Date: 5/27/2022

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Reviewed: SLP

Approved: SLP

Figure 29 - Rattlesnake AGI ttl Wellbore Schematic

45


-------
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Maxiuum Monitoring Area
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Stakeholder Widstrearo
Yoakum Co.. TX

PCS: t*AD33 TX-NC FIPS 4202 (US Ft.)

Drawn by: EH | Date: 5/31/2Q22 | Apprered by: RH

LONQUISI & CO LLC

+ Catassnite ACI No. 1 381
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Figure 30 - Oil and Gas Wells within the MMA

46


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1 Inch =0.51 Mile
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0 54 % %

/,*	seesa

RATTLESNAKE AGI NO. 1
38.5613.4891
, '	-102.SC44S675 +

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Rattlesnake AGI No. 1
Haxinum Nonitoring Area
wi th

1/2-ttile MMA Oil/Gas Well Penetrators
Area of Review

Stakeholder Midstream
	Yoakum Co., TX	

PCS: KADB3 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER | Date: 6/T/2022 | Approved by: RH

LQMQUIST & CD LLC

+ RttBesaake ACI Ha. 1 SHL

|	I 1 /2-Mile luFFer from M«. ?lume Litent iMM A)

_ J Combined Maximum Plyme Extent

I	I Stabilised Piume

J Plume fousdary at End a? Injection

AJI <4-2-501-—1 SHL Status - Type (Count >
Active - Oil«)

•i, Active - iitfe-etras/DisoDsal (11

Perm.tted Location (1)

UOlCaj Weft SHL Dim. CH2022
2.JOd/Cas well SHLDstK K-2022
3jCtl/Cas Wti: D'wtjc'1 Diss: H-2022
- Moke:« cscrarKt: ssws are i> w*D*3 ion i

Z f « L«i

X *	«ieP£l7S»T

~

tSi

Figure 31 - Penetrating Oil and Gas Wells within the MMA

47


-------
Future Drilling

Potential leak pathways caused by future drilling in the area are not expected to occur. The deeper
formations, such as the Devonian, have proven to-date to be less productive or non-productive in this area,
which is why the location was selected for injection. Furthermore, any drilling permits issued by the TRRC in
the area of the Rattlesnake AGI #1 well include a list of formations for which oil and gas operators are
required to comply with TRRC Rule 13 (entitled "Casing, Cementing, Drilling, Well Control, and Completion
Requirements"). 16 TAC § 3.13. By way of example, see the Rattlesnake AGI #1 well drilling permit provided
in Appendix B. The Devonian is among the formations listed for which operators in Yoakum County (where
the Rattlesnake #1 is located) are required to comply with TRCC Rule 13 (Appendix B, pg. 5). TRRC Rule 13
requires oil and gas operators to set steel casing and cement across and above all formations permitted for
injection under TRRC Rule 9 or immediately above all formations permitted for injection under Rule 46 for
any well proposed within a one-quarter mile radius of an injection well. In this instance, any new well
permitted and drilled to the Rattlesnake AGI #1 well's injection zone located within a one-quarter mile radius
of the Rattlesnake AGI #1 well will be required under TRRC Rule 13 to set steel casing and cement above the
Rattlesnake AGI #1 well injection zone. Additionally, Rule 13 requires operators to case and cement across
and above all potential flow zones and/or zones with corrosive formation fluids. The TRRC maintains a list of
such known zones by TRRC district and county and provides that list with each drilling permit issued, which
is also shown in the above-mentioned permit in Appendix B.

If any leakage were to be detected, the volume of C02 released will be quantified based on the operating
conditions at the time of release.

Groundwater wells

There are seven groundwater wells located within the MMA, as identified by the Texas Water Development
Board. All of the identified groundwater wells in the area have total depths less than or equal to 265', as
shown in Figure 32 and Table 9. One of the wells is located on the 30-30 facility property with a total depth
of 119'and is operated by Stakeholder.

The surface and intermediate casings of the Rattlesnake AGI #1 well, as shown in Figure 29, are designed to
protect the shallow freshwater aquifers consistent with applicable TRRC regulations and the GAU letter
issued for this location. See GAU letter attached included within Appendix B. The wellbore casings and
cements also serve to prevent CO2 leakage to the surface along the borehole.

48


-------
to

1 Inch = 0.51 Mile
1:32,000 ^2

0 % K %

S30S1248 Bt
-1D2 S04BDS76
+

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Rattlesnake ACI No. 1
Maximum Monitoring Area
wi th

1/2-Mile MMA Groundwater Well
Area of Review

Stakeholder Midstream
Yoakum Co., TX

PCS: NADB3 TX-NC FI=S 4202  Stabilizes Plunt

_ J Plume lousdiry at End of Injection
Abstract

50R0B Groundwater Wetls [TWDB-2G22I
Propcatd U»e :L Bbzkti w.-tti WeH Report Ho J
A Industrial (I)

TWOS Groundwater Wells [TWDfl-2022]

We)! Type ¦Ubcfct) wit* State Wei! No.)
¦ Withdrawal of Water 0)

Scuree.

1.1SKOS GreuratwaterWet SHL Osts: 7WD1-20EI
2JTWW C^'d-lter WHI SHI Sea TWDI-2022
3.11'vJrisH Croun#»ale" Wet BHL Di£a. 7WDI-202I

« Sets: 4I1 oxrii *e« :to»* tt ia ML CM 3 iDZ <



&?S

2 <

ar * WFExrarr

~





Figure 32 - Groundwater Wells within MMA

49


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Table 9 - Groundwater Well Summary

State Well ID

Owner Name

Primary Use Well Depth Data Source

370449

Frances Barbini

Irrigation

237

SDRDB

443840

Frances Jean Barbini

Irrigation

250

SDRDB

482963

Santa Fe Midstream Permian

Industrial

119

SDRDB

510854

FRANCIS BARNINI

Irrigation

255

SDRDB

520249

Thomas Durham

Irrigation

264

SDRDB

543433

FRANCIS BARBIDI

Irrigation

240

SDRDB

84760

TEXACO PRODUCING INC





TWDB BW

Leakage Through Faults or Fractures

Faults were interpreted from roughly 9 square miles of 3D seismic indicated by the purple outline in Figure
12. Faulting in this region terminates vertically below the Pennsylvanian-age rock. Secondary confining
shales within the Wolfcampian and younger strata provide additional, redundant confining layers that would
prevent C02from migrating into freshwater aquifers. None of the mapped faults project above the Wolfcamp
formation; rather, they appear to terminate between the Strawn and base of the Wolfcamp formation. If in
the unlikely event the faults' sealing properties are compromised post-injection, secondary confinement is
provided by the tight limestones found within the overlying Mississippianan Lime formation and the shale
layers found in the Atoka and Wolfcamp formations. As seen in Figure 14, the largest fault found SE of the
Rattlesnake AGI #1 well, terminates within the Atoka formation. Though it crosses the Silurian section, this
fault thrusts the Mississippian Lime upward against the Atoka shales. The tight reservoir characteristics of
the Mississippian Lime and shaley section of the Atoka create a confining environment vertically and laterally
to contain potential upward migration of buoyant fluids. Shales within the Wolfcamp formation provide
additional confining beds between overlying USDWs and the fault plane.

Should an unmapped fault exist within the plume boundary, the offset would be below 3D seismic resolution.
The offset would be less than the thickness of the Woodford shale, juxtaposing the Woodford against itself,
preventing vertical migration.

Fractures and subsequent subaerial exposure are responsible for porosity development within the injection
intervals. Open hole logs show little to no porosity development indicating the Woodford or Mississippian
Lime were not exposed at this location. Upward migration of injected gas through confining bed fractures is
unlikely.

50


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Leakage Through Confining Layers

The Silurian-Devonian injection zones have competent sealing rocks above and below the porous sub-aerially
exposed carbonate. The properties of the overlying transgressive Woodford shale (widespread deposition,
high illite clay and organic matter composition, and low porosity and permeability) make an excellent sealing
rock to the underlying Silurian formation. Tight Mississippian Lime of roughly 660', lay between Atoka and
Woodford shale formations, forming an impermeable upper seal to the injection interval. Above this
confining unit, correlative shales of the Wolfcamp, Abo and Tubb formations will prevent any upper fluid
migration. These impermeable shales are capped by hundreds of feet of the regionally present Salado
formation evaporites. The USDW lies above the sealing properties of the formations outlined above, making
stratigraphic migration of fluids into the USDW highly unlikely. The underlying low porosity and permeability
Montoya carbonate minimizes the likelihood of downward migration of injected fluids. The relative
buoyancy of injected gas to the in-situ reservoir fluid makes migration below the lower confining layer
unlikely.

Leakage from Natural or Induced Seismicitv

The location of Rattlesnake AGI #1 is in an area of the Permian Basin that is inactive from a seismicity
perspective, whether induced or natural. A review of historical seismic events on the USGS's Advanced
National Seismic System site (from 1971 to present) and the Bureau of Economic Geology's TexNet catalog
(from 2017 to present), as shown in Figure 33, indicates the nearest seismic event occurred more than 60
miles away.

A regional analysis of the probabilistic fault slip potential across the Permian Basin (Snee & Zoback 2016), as
seen in Figure 34, further demonstrates that the Rattlesnake AGI #1 well is located in a seismically inactive
area and confirms that this area has little to no potential for an induced seismicity event.

Therefore, there is no indication that seismic activity poses a risk for loss of CO2 to the surface within the
MMA.

51


-------
Cctclir 3M	'

LaveHand	Lubbock

LI A NO ES 7 ACA 0 O
(STAKED Pi. A IN!

Figure 33 - Seismicity Review (TexNet - 06/01/2022)

52


-------
Dagger
Draw
field

\ Living
'i jGiialidni fault'

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m ^ ^taSbersor?

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Figure 34 - Probabilistic Fault Slip Potential Analysis with Rattlesnake AGI #1 location (Snee & Zobak 2016)

53


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SECTION 5 - MONITORING FOR LEAKAGE

This section discusses the strategy that Stakeholder will employ for detecting and quantifying surface leakage
of C02 through the pathways identified in Section 4 to meet the requirements of 40 CFR §98.448(a)(3). As
the injectate stream contains both H2S and C02, the H2S will be a proxy for C02 leakage and therefore the
monitoring systems in place to detect H2S will also indicate a release of C02. Table 8 summarizes the
monitoring of potential leakage pathways to the surface. Monitoring will occur during the planned 25-year
injection period, or cessation of injection operations, plus a proposed 5-year post-injection period.

•	Leakage from surface equipment

•	Leakage through existing and future wells within MMA

•	Leakage through faults and fractures

•	Leakage through the confining layer

•	Leakage through natural or induced seismicity

Because the acid gas injection stream also contains H2S, any leakage would be detected by the H2S alarms
located around the facility and would be quickly addressed which would minimize the release of C02 into the
atmosphere.

Table 10 - Summary of Leakage Monitoring Methods

Leakage Pathway

Monitoring Method

Leakage from surface equipment

Fixed H2S monitors throughout the AGI facility

Daily visual inspections

Personal H2S monitors

Distributed Control System Monitoring (Volumes and Pressures)

Leakage through existing wells

Fixed H2S monitor at the AGI well

SCADA Continuous Monitoring at the AGI Well

Annual Mechanical Integrity Tests ("MIT") of the AGI Well

Visual Inspections

Quarterly C02 Measurements within AMA

Leakage through groundwater wells

Annual GroundwaterSamples on Property

Leakage from future wells

H2S Monitoring during offset drilling operations

Leakage through faults and fractures

SCADA Continuous Monitoring at the AGI Well (volumes and pressures)

Fixed In-field H2S monitors

Leakage through confining layer

SCADA Continuous Monitoring at the AGI Well (volumes and pressures)

Fixed In-field H2S monitors

Leakage from natural or induced
seismicity

Seismic monitoring station to be installed

54


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Leakage from Surface Equipment

As the 30-30 Facility and the Rattlesnake AGI #1 well are designed to handle H2S, leakage from surface
equipment is unlikely to occur and would be quickly detected and addressed. The facility design minimizes
leak points through the equipment used and the type of connections are designed to minimize corrosion
points. The H2S in the injectate serves as a proxy for the release of C02. The facility and well site contain a
number of H2S alarms, set with a high alarm setpoint of 10 ppm of H2S, which are shown in Figure 28above.
Additionally, all Stakeholder field personnel are required to wear H2S monitors, which trigger the alarm at 5
ppm H2S.

The AGI facility is continuously monitored through automated systems. In addition, field personnel conduct
daily visual field inspections of gauges, monitors and leak indicators such as vapor plumes. The effectiveness
of the internal and external corrosion control program is monitored through the periodic inspection of the
system, analysis of liquids collected from the line, and inspection of the cathodic protection system. These
inspections, in addition to the automated systems, allow Stakeholder to quickly respond to any leakage
situation. Monitoring will occur for the duration of injection and the post-injection period. Should leakage
be detected during active injection operations, the volume of C02 released will be calculated based on
operating conditions at the time of the event, per 40 CFR §98.448(a)(5).

Leakage from Existing and Future Wells within Monitoring Area

Stakeholder continuously monitors and collects injection volumes, pressures, temperatures and gas
composition data, through their SCADA systems, for the Rattlesnake AGI #1 well. This data is reviewed by
qualified personnel and will follow response and reporting procedures when data is outside acceptable
performance limits. Rattlesnake AGI #1 has a pressure and temperature gauge placed in the injection stream
at its wellhead, and a pressure gauge on the casing annulus. A change of pressure on the annulus would
indicate the presence of a possible leak. Mechanical integrity tests ("MITs") performed annually would also
indicate the presence of a leak. Upon a negative MIT, the well would immediately be isolated and the leak
mitigated.

The ten offset penetrating wells within the MMA are adequately cased and cemented to prevent potential
leakage of CO2 from the Rattlesnake AGI #1 well plume. Additionally, the plugged wells were done so in a
way to prevent migration of CO2 as provided in Appendix E. As discussed previously, Rule 13 would ensure
that new wells in the field would be constructed in a manner to prevent migration from the injection interval.

In addition to the fixed and personal monitors described previously, Stakeholder will also establish and
operate an in-field monitoring program to detect any C02 leakage within the AMA. The scope of work will
include H2S and C02 monitoring at the AGI well site as well as minimum, quarterly atmospheric monitoring
near identified penetrations within the AMA. Upon approval of the MRV and through the post-injection
monitoring period, Stakeholder will have these monitoring systems in place. Additional monitoring will be
added as the AMA is updated over time.

Groundwater Quality Monitoring

Stakeholder will monitor the groundwater quality in fluids above the confining interval by sampling the well
on the facility property and analyzing the sample with a third-party laboratory on an annual basis. Any
significant changes to the water analysis would be investigated to determine if such change was a result of
leakage from the Rattlesnake AGI #1 well.

55


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Leakage through Faults. Fractures or Confining Seals

Stakeholder continuously monitors the operations of the Rattlesnake AGI #1 well through automated
systems. Any deviation from normal operating conditions indicating movement into a potential pathway
such as a fault or breakthrough of the confining seal would trigger an alert. Any such alert would be reviewed
by field personnel and action taken to shut in the well, if necessary. Field H2S monitoring systems would alert
field personnel for any release of H2S/CO2 caused by such leakage.

Leakage through Natural or Induced Seismicitv

While the likelihood of a natural or induced seismicity event is extremely low, Stakeholder plans to install a
seismic monitoring station in the general area of the Rattlesnake AGI #1 well. This monitoring station will be
tied in to the Bureau of Economic Geology's TexNet Seismic Monitoring system. If a seismic event of 3.0
magnitude or greater is detected, Stakeholder will review the injection volumes and pressures at the
Rattlesnake AGI #1 well to determine if any significant changes occur that would indicate potential leakage.

56


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SECTION 6- BASELINE DETERMINATIONS

This section identifies the strategies Stakeholder will undertake to establish the expected baselines for
monitoring C02 surface leakage per 40 CFR §98.448(a)(4). Stakeholder will use the existing SCADA monitoring
systems to identify changes from expected performance that may indicate leakage of C02.

Visual Inspections

Daily inspections will be conducted by field personnel at the 30-30 Facility and the Rattlesnake AGI #1 well.
These inspections will aid with identifying and addressing issues timely to minimize the possibility of leakage.
If any issues are identified, such as vapor clouds or ice formations, corrective actions would be taken to
address such issues.

H2S Detection

H2S will be initially injected into the AGI well at a concentration of approximately ten (10) percent or 100,000
ppm. The concentration will drop to approximately six (6) percent as additional volumes are added. H2S gas
detectors are located throughout the AGI facility and well site and are set to trigger the alarm at 10 ppm.
Additionally, all field personnel are required to wear personal H2S monitors, which are set to trigger the alarm
at 5 ppm. Any alarm would trigger an immediate response to protect personnel and verify that the monitors
are working properly. If monitors are working correctly, immediate actions would be taken to secure the
facility and mitigate potential leaks.

CO2 Detection

Any C02 release would be accompanied by H2S and therefore the H2S monitors at the facility would also serve
as a C02 release warning system. In addition to the fixed and personal monitors described previously,
Stakeholder will also establish and operate an in-field monitoring program to detect any C02 leakage within
the AMA. The scope of work will include H2S and C02 monitoring at the AGI well site as well as atmospheric
monitoring near identified penetrations within the AMA.

Operational Data

Upon starting injection operations, baseline measurements of injection volumes and pressures will be taken.
Any significant deviations over time will be analyzed for indication of leakage of C02.

Continuous Monitoring

Mass of C02 emitted by surface leakage and equipment leaks will not be measured directly as the injection
stream for this well contains H2S which would be extremely dangerous for personnel to perform a direct leak
survey. Any leakage would be detected and managed as per Texas regulations and Stakeholder's TRRC-
approved H2S Contingency Plan. Gas detectors and continuous monitoring systems would trigger an alarm
upon a release. The mass of the C02 released would be calculated for the operating conditions at the time,
including pressure, flow rate, size of the leak point opening, and duration of the leak. This method is
consistent with 40 CFR §98.448(a)(5), allowing the operator to calculate site-specific variables used in the
mass balance equation.

57


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No C02 emissions will occur from venting because of the high H2S concentrations. Blowdown emissions are
sent to flares and would be reported as part of the required reporting for the gas plant.

Groundwater Monitoring

An initial sample will be taken from the groundwater well on Stakeholder's property, identified as Well #
482963 in Table 9 above, upon approval of Stakeholder's MRV and prior to increasing injection. The sample
will be analyzed by a third-party laboratory to establish the baseline properties of the groundwater.

58


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SECTION 7 - SITE SPECIFIC CONSIDERATIONS FOR MASS BALANCE

EQUATION

This section identifies how Stakeholder will calculate the mass of C02 injected, emitted, and sequestered.
This also includes site-specific variables for calculating the CO2 emissions from equipment leaks and vented
emissions of CO2 between the injection flow meter and the injection well, per 40 CFR §98.448(a)(5).

Mass of CO2 Received

Per 40 CFR §98.443, the mass of C02 received must be calculated using the specified C02 received equations
"unless you follow the procedures in 40 CFR §98.444(a)(4)." 40 CFR §98.444(a)(4) states that "if the CO2 you
receive is wholly injected and is not mixed with any other supply of CO2, you may report the annual mass of
CO2 injected that you determined following the requirements under paragraph (b) of this section as the total
annual mass of CO2 received instead of using Equation RR-1 or RR-2 of this subpartto calculate C02 received."
The CO2 received for this injection well is wholly injected and not mixed with any other supply and the annual
mass of C02 injected will equal the amount received. Any future streams would be metered separately before
being combined into the calculated stream.

Mass of CO2 Injected

Per 40 CFR §98.444(b), since the flow rate of C02 injected will be measured with a volumetric flow meter, the
total annual mass of CO2, in metric tons, will be calculated by multiplying the mass flow by the C02
concentration in the flow according to Equation RR-4:

C02,u = Annual C02 mass injected (metric tons) as measured by flow meter u

QP,u = Quarterly mass flow rate measurement for flow meter u in quarter p (metric tons per quarter)

Cco2,P,u = Quarterly C02 concentration measurement in flow for flow meter u in quarter p (wt. percent
CO2, expressed as a decimal fraction)

p = Quarter of the year

u = Flow meter

4

p = 1

where:

59


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Mass of CO2 Produced

The Rattlesnake AGI #1 well is not part of an enhanced oil recovery project; therefore, no C02 will be
produced.

Mass of CO2 Emitted by Surface Leakage

Mass of C02 emitted by surface leakage and equipment leaks will not be measured directly as the injection
stream for this well contains H2S which would be extremely dangerous for personnel to perform a direct leak
survey. Any leakage would be detected and managed as a major upset event. Gas detectors and continuous
monitoring systems would trigger an alarm upon a release. The mass of the C02 released would be calculated
for the operating conditions at the time, including pressure, flow rate, size of the leak point opening, and
duration of the leak. This method is consistent with 40 CFR §98.448(a)(5), allowing the operator to calculate
site-specific variables used in the mass balance equation.

In the unlikely event that CO2 was released as a result of surface leakage, the mass emitted would be
calculated for each surface pathway according to methods outlined in the plan and totaled using Equation
RR-10 as follows:

C02 = Total annual C02 mass emitted by surface leakage (metric tons) in the reporting year
C02,x= Annual C02 mass emitted (metric tons) at leakage pathway x in the reporting year
X = Leakage pathway

Calculation methods from subpart W will be used to calculate C02 emissions from equipment located on
the surface between the flow meter used to measure injection quantity and the injection wellhead

Mass of CO2 Sequestered

The mass of C02 sequestered in subsurface geologic formations will be calculated based off Equation RR-12,
as this well will not actively produce oil or natural gas or any other fluids, as follows:

X

X=1

Where:

C02 — C02i C02e C02f

Where:

60


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C02 = Total annual C02 mass sequestered in subsurface geologic formations (metric tons) at the
facility in the reporting year

CO21 = Total annual C02 mass injected (metric tons) in the well or group of wells covered by this source
category in the reporting year

CO 2E — Total annual CO2 mass emitted (metric tons) by surface leakage in the reporting year

CO 2F1 - Total annual CO2 mass emitted (metric tons) from equipment leaks and vented emissions of
CO2 from equipment located on the surface between the flow meter used to measure injection
quantity and the injection wellhead

CO2F1 will be calculated in accordance with Subpart W reporting of GHGs. Because no venting would occur
due to the high H2S concentrations of the injectate stream, the calculations would be based on the blowdown
emissions that would be sent to flares and would be reported as part of the required GHG reporting for the
gas plant.

• Calculation methods from subpart W will be used to calculate C02emissions from equipment located
on the surface between the flow meter used to measure injection quantity and the injection
wellhead.

61


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SECTION 8 - IMPLEMENTATION SCHEDULE FOR MRV PLAN

The Rattlesnake AGI #1 well currently reports GHGs under Subpart UU, but Stakeholder has elected to submit
an MRV plan under, and otherwise comply with, Subpart RR. The MRV plan will be implemented upon
receiving EPA approval. The Annual Subpart RR Report will be filed on March 31st of the year following the
reporting year.

62


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SECTION 9 - QUALITY ASSURANCE

This section identifies how Stakeholder plans to manage quality assurance and control, to meet the

requirements of 40 CFR §98.444.

Monitoring QA/QC

CO 2 Injected

•	The flow rate of the C02 being injected will be measured with a volumetric flow meter, consistent
with industry best practices. These flow rates will be compiled quarterly.

•	The composition of the C02 stream will be measured upstream of the volumetric flow meter with a
continuous gas composition analyzer or representative sampling consistent with industry best
practices.

•	The gas composition measurements of the injected stream will be averaged quarterly.

•	The CO2 measurement equipment will be calibrated according to manufacturer recommendations.

C02 Emissions from Leaks and Vented Emissions

•	Gas detectors will be operated continuously, except for maintenance and calibration.

•	Gas detectors will be calibrated according to manufacturer recommendations and API standards.

•	Calculation methods from subpart W will be used to calculate C02emissions from equipment located
on the surface between the flow meter used to measure injection quantity and the injection
wellhead.

Measurement Devices

•	Flow meters will be continuously operated except for maintenance and calibration.

•	Flow meters will be calibrated according to the requirements in 40 CFR §98.3(i).

•	Flow meters will be operated per an appropriate standard method as published by a consensus-
based standards organization.

•	Flow meter calibrations will be traceable to the National Institute of Standards and Technology
(NIST).

All measured volumes of C02 will be converted to standard cubic meters at a temperature of 60 degrees

Fahrenheit and an absolute pressure of 1 atmosphere.

Missing Data

In accordance with 40 CFR §98.445, Stakeholder will use the following procedures to estimate missing data

if unable to collect the data needed for the mass balance calculations:

•	If a quarterly quantity of C02 injected is missing, the amount will be estimated using a representative
quantity of C02 injected from the nearest previous period of time at a similar injection pressure.

•	Fugitive C02 emissions from equipment leaks from facility surface equipment will be estimated and
reported per the procedures specified in subpart W of 40 CFR §98.

63


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MRV Plan Revisions

If any of the changes outlined in 40 CFR §98.448(d) occur, Stakeholder will revise and submit an amended
MRV plan within 180 days to the Administrator for approval.

64


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SECTION 10 - RECORDS RETENTION

Stakeholder will retain records as required by 40 CFR §98.3(g). These records will be retained for at least
three years and include:

•	Quarterly records of the CO2 injected

o Volumetric flow at standard conditions
o Volumetric flow at operating conditions
o Operating temperature and pressure
o Concentration of the C02 stream

•	Annual records of the information used to calculate the C02 emitted by surface leakage from leakage
pathways.

•	Annual records of information used to calculate C02 emitted from equipment leaks and vented
emissions of C02 from equipment located on the surface between the flow meter used to measure
injection quantity and the injection wellhead.

65


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References

Broadhead, Ronald E., 2005. Regional Aspects of the Wristen petroleum system, southeastern New Mexico:
New Mexico Bureau of Geology and Mineral Resources Open File Report, no. 485.

Comer, John B., 1991. Stratigraphic Analysis of the Upper Devonian Woodford Formation, Permian Basin,
West Texas and Southeastern New Mexico: Bureau of Economic Geology Report of Investigations, no. 201.

George, Peter G., Mace, Robert E., and Petrossian, Rima, 2011. Aquifers of Texas: Texas Water Development
Board Report, no 380.

Hoak, T., Sundberg, K., and Ortoleva, P. Overview of the Structural Geology and Tectonics of the Central Basin
Platform, Delaware Basin, and Midland Basin, West Texas and New Mexico: Department of Energy Open File
Report.

Molina, Oscar, Vilarras, Victor, and Zeidouni, Mehdi, 2016. Geologic carbon storage for shale gas recovery:
13th International Conference on Greenhouse Gas Control Technologies, GHGT-13, 14-18.

Ruppel, Stephen C. and Holtz, Mark H., 1994. Depositional and Diagenetic Facies Patterns and Reservoir
Development in Silurian and Devonian Rocks of the Permian Basin: Bureau of Economic Geology Report of
Investigations, no. 216.

Snee, Jens-Erik Lund and Zoback, Mark D., 2016. State of stress in the Permian Basin, Texas and New Mexico:
Implications for induced seismicity.

Teeple, Andrew P., Ging, Patricia B., Thomas, Jonathan V., Wallace, David S., and Payne, Jason D., 2021.
Hydrogeologic Framework, Geochemistry, Groundwater-Flow System, and Aquifer Hydraulic Properties Used
in the Development of a Conceptual Model of the Ogallala, Edwards-Trinity (High Plains), and Dockum
Aquifers In and Near Gaines, Terry, and Yoakum Counties, Texas: USGS Scientific Investigations Report 2021-
5009.

66


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APPENDICES


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APPENDIX A-GEOLOGY

APPENDIX A-l: SILURIAN STRUCTURE MAP
APPENDIX A-2: NE-SW CROSS SECTION
APPENDIX A-3: NW-SE CROSS SECTION


-------

-------
mi

LONQU 1ST

SEQUESTRATION L

Stakeholder Midstream


-------
42501105700000
1-667

TEXAS CRUDE OIL CO

42501358340000
ROBERTS UNIT
2

APACHE

<14,201 FT>

42501369980000
RATTLESNAKE AG I
1

STAKEHOLDER GAS SERVICES


-------
APPENDIX B - TRRC FORMS Rattlesnake AG I #1

APPENDIX B-l: UIC CLASS II ORDER

APPENDIX B-2: GAU GROUNDWATER PROTECTION DETERMINATION
APPENDIX A-3: DRILLING PERMIT
APPENDIX A-4: COMPLETION REPORT


-------
Christi Craddick, Chairman
Ryan Sitton, Commissioner
Wayne Christian, Commissioner

B-1

Danny Sorrells
Assistant Executive Director
Director, Oil and Gas Division
Leslie Savage

Assistant Director, Technical Permitting

Railroad Commission of Texas

OIL AND GAS DIVISION

PERMIT TO DISPOSE OF NON-HAZARDOUS OIL AND GAS WASTE BY INJECTION INTO A
POROUS FORMATION NOT PRODUCTIVE OF OIL AND GAS

PERMIT NO. 15848

SANTA FE MIDSTREAM PERMIAN LLC
5830 GRANITE PKWY STE 1025
PLANO, TX 75024

DOCKET NO. 8A-0312019

Authority is granted to inject Non-Hazardous Oil and Gas waste into the well identified herein in accordance
with Statewide Rule 9 of the Railroad Commission of Texas and based on information contained in the
application (Form W-14) dated March 12, 2018 for the permitted interval of the DEVONIAN formation and
subject to the following terms and special conditions:

RATTLESNAKE AGI (000000) LEASE

WASSON FIELD

YOAKUM COUNTY, DISTRICT 8A

WELL II

DENTIFIC ATION AND P]

ERMIT PA]

RAMET]

ERS:

Well No.

API No.

UIC Number

Permitted
Fluids

Top
Interval
(feet)

Bottom
Interval
(feet)

Maximum
Liquid
Daily
Injection
Volume
(BBL/day)

Maximum
Gas Daily
Injection
Volume
(MCF/day)

Maximum
Surface
Injection
Pressure
for Liquid
(PSIG)

Maximum
Surface
Injection
Pressure
for Gas
(PSIG)

1

50136998

000117143

C02, and
H2S

11,000

12,000

4,500

N/A

N/A

2,200

SPECIAL CONDITIONS:

Well No.

API No.

Special Conditions

1

50136998

1.	Open hole completions shall have a plug back depth no deeper than the bottom of the
permitted injection interval.

2.	The operator shall provide to the UIC section an annotated electric log, and a mud log if
available, of the subject well with the top(s) and bottom(s) of the permitted formation
indicated on the log. Top and bottom of the authorized injection interval may be modified
based on electric log or mud log indications of the top and bottom of the permitted
formations.

1701 NORTH CONGRESS AVENUE * POST OFFICE BOX 12967 * AUSTIN. TEXAS 78711-2967 * PHONE: 512/463-6792* FAX: 512/463-6780
TDD 800/735-2989 OR TDY 512/463-7284 * AN EQUAL OPPORTUNITY EMPLOYER* http://www.rrc.texas.gov


-------
STANDARD CONDITIONS:

1.	Injection must be through tubing set on a packer. The packer must be set no higher than 100 feet above the
top of the permitted interval.

2.	The District Office must be notified 48 hours prior to:

a.	running tubing and setting packer;

b.	beginning any work over or remedial operation;

c.	conducting any required pressure tests or surveys.

3.	The wellhead must be equipped with a pressure observation valve on the tubing and for each annulus.

4.	Prior to beginning injection and subsequently after any work over, an annulus pressure test must be
performed. The test pressure must equal the maximum authorized injection pressure or 500 psig, whichever
is less, but must be at least 200 psig. The test must be performed, and the results submitted in accordance
with the instructions of Form H-5.

5.	The injection pressure and injection volume must be monitored at least monthly and reported annually on
Form H-10 to the Commission's Austin office.

6.	Within 30 days after completion, conversion to disposal, or any work over which results in a change in well
completion, a new Form W-2 or G-l must be filed to show the current completion status of the well. The
date of the disposal well permit, and the permit number must be included on the new Form W-2 or G-l.

7.	Written notice of intent to transfer the permit to another operator by filing Form P-4 must be submitted to
the Commission at least 15 days prior to the date of the transfer.

8.	This permit will expire when the Form W-3, Plugging Record, is filed with the Commission. Furthermore,
permits issued for wells to be drilled will expire three (3) years from the date of the permit unless drilling
operations have commenced.

Provided further that, should it be determined that such injection fluid is not confined to the approved interval, then
the permission given herein is suspended and the disposal operation must be stopped until the fluid migration from
such interval is eliminated. Failure to comply with all of the conditions of this permit may result in the operator
being referred to enforcement to consider assessment of administrative penalties and/or the cancellation of the
permit.

APPROVED AND ISSUED ON November 14. 2018.

Injection-Storage Permits Unit

IN-HOUSE AMENDMENT TO CORRECT THE RATE.

Note: This document will only be distributed electronically.

PERMIT NO. 15848
Page 2 of 2


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GROUNDWATER PROTECTION DETERMINATION
Groundwater Advisory Unit

Form GW-2

B-2

Date Issued:

31 August 2017

GAU Number:

179154

Attention:

SANTA FE MIDSTREAM

API Number:





5700 GRANITE PARKWAY

County:

YOAKUM



PLANO, TX 75024

Lease Name:

Roberts Unit

Operator No.:

748093

Lease Number:

Well Number:

Total Vertical Depth:
Latitude:

Longitude:

Datum:

019212
1

11000
33.049990
-102.903464
NAD27

Purpose:

New Drill





Location:

Survey-Gibson, J H/Poole, J T; Block-D; Section-733



To protect usable-quality groundwater at this location, the Groundwater Advisory Unit of the Railroad Commission of
Texas recommends:

The interval from the land surface to a depth of 375 feet must be protected.

Note: Unless stated otherwise, this recommendation is intended to apply only to the subject well and not for area-wide use.
This recommendation is for normal drilling, production, and plugging operations only. It does not apply to saltwater disposal
operation into a nonproductive zone (RRC Form W-14).

This determination is based on information provided when the application was submitted on 08/30/2017. If the location
information has changed, you must contact the Groundwater Advisory Unit, and submit a new application if necessary.
If you have questions, please contact us at 512-463-2741 orgau@rrc.texas.gov.

Groundwater Advisory Unit, Oil and Gas Division

Form GW-2 P.O. Box 12967 Austin, Texas 78771-2967 512-463-2741 Internet address: www.rrc.texas.gov
Rev. 02/2014


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APINa 42-501-36998

RAILROAD COMMISSION OF TEXAS
OIL & GAS DIVISION

APPLICATION FOR PERMIT TO DRILL, RECOMPLETE, OR RE-ENTER

This facsimile W-l was generated electronically from data submitted to the RRC.

A certification of the automated data is available in the RRC's Austin office.

FORM W-l 07/2004

Drilling Permit #

839303

SWR Exception Case/Docket No.

Permit Status: Approved

B-3

1. RRC Operator No.

748093

2. Operator's Name (as shown on form P-5, Organization Report)

SANTA FE MIDSTREAM PERMIAN LLC

3. Operator Address (include street, city, state, zip):

5830 GRANITE PKWY STE 1025
PLANO, TX 75024-0000

4. Lease Name

RATTLESNAKE AGI

5. Well No.

1

GENERAL INFORMATION

6. Purpose of filing (mark ALL appropriate boxes): Ix] New Drill EH Recompletion EH Reclass EH Field Transfer EH Re-Enter

EH Amended EH Amended as Drilled (BHL) (Also File Form W-1D)

7. Wellbore Profile (mark ALL appropriate boxes): 0 Vertical EH Horizontal (Also File Form W-1H) EH Directional (Also File Form W-1D) EH Sidetrack

8. Total Depth

12000

9. Do you have the right to develop the [x] - | |
minerals under any right-of-way ?

10. Is this well subject to Statewide Rule 36 (hydrogen sulfide area)? IS Yes EH \0

SURFACE LOCATION AND ACREAGE INFORMATION

11. RRC District No.

8A

12. County I—, ,—, ,—, ,—¦

YOAKUM 13. Surface Location LXI Land 1—1 Bay/Estuary 1—1 Inland Waterway 1—1 Offshore

14. This well is to be located miles in a NW direction from DENVER CITY which is the nearest town in the county of the well site.

15. Section 16. Block 17. Survey 18. Abstract No.

733 D GIBSON, J H A-89

19. Distance to nearest lease line:

200 ft-

20. Number of contiguous acres in

lease, pooled unit, or unitized tract: 640

21.	Lease ]

22.	Survey

'erpendiculars: 200 ft from the NORTH line and 200 ft froi

nt
nt

ie WEST line.



PprppiiHii^iilars" 200 ft from the NORTH line and 200 ft froi

le WEST line.

23. Is this a pooled unit? EH Yes B No 24. Unitization Docket No:

25. Are you applying for Substandard Acreage Field? EH Yes (attach Form W-1A) S No

FIELD INFORMATION List all fields of anticipated completion including Wildcat. List one zone per line.

26. RRC
District No.

27. Field No.

28. Field Name (exactly as shown in RRC records)

29. Well Type

30. Completion Depth

31. Distance to Nearest
Well in this Reservoir

32. Number of Wells on
this lease in this
Reservoir

8A

95397001

WASSON

Injection Well

12000

0.00

1

8A

95399400

WASSON, NORTH (SAN ANDRES)

Injection Well

12000

0.00

1





























BOTTOMHOLE LOCATION INFORMATION is required for DIRECTIONAL, HORIZONTAL, AND AMENDED AS DRILLED PERMIT APPLICATIONS

Remarks

[FILER Apr 16, 2018 5:16 PM]: Filing for an acid gas injection well.

Certificate:

I certify that information stated in this application is true and complete, to the
best of my knowledge.

Jessica Risien, Regulatory Compliance

Specialist Apr 25, 2018

Name of filer Date submitted

(281)8729300 jrisien@ntglobal.com

Phone E-mail Address (OPTIONAL)

RRC Use Only Data Validation Time Stamp: Apr 27, 2018 10:36 AM( As Approved' Version )

Page 1 of 1


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NOTE: Acreages shown hereon ere based on Information provided by others.

This plat represents a staked well location and does not represent a boundary survey.
The Information shown does not meet the current TBPLS minimum standards for boundary
surveys. Limited field measurements were acquired. Lease and tract line Information is
compiled from record information and additional sources.

NOTES:

1)

2)

3-J

ALL BEARINGS. DISTANCES ANO COORDINATES SHOWN
HEREON WERE DERIVED FROM <3. P S. OBSERVATIONS
CONVERTED TO THE TEXAS COORDINATE SYSTEM,
NORTH CENTRAL ZONE (NAD 1993). US FOOT AND ARE
REFERENCED TO THE LOCAL GNSS RTK NETWORK.
THE PROPOSED WELL LOCATION IS SITUATED N 37~W -
7.3 MILES FROM DENVER CITY, TX.

THE PROPOSED WELL LOCATION IS SITUATED SOW FROM
THE NSL AND 200 FROM THE WSL.

6

5°X'

rC-< liw



SECTION 704. BLOCK D
J. H. GIBSON SURVEY-
ABSTRACT NO. 1144
YOAKUM COUNTY. TX

704

733

RA TTLESMAKE AGf No.
(PROPOSED)

.0^

SURFACE L OCA T/ON
NAD 83, TX-NC, U.S. FT.
NORTH/NG/Y; 7093713.4ST
EASTING/X 619409-13"

LATITUDE (DDJ- 33.05134722°
LONGITUDE (DO)- -102.90450555*

NAD 27, TX-NC, US- FT,
NORTHfNG/Y: 546285.34*
EAST/NG/X; 344968.61'

LA TTTUDE (DO)- 33.05124473"
LONGITUDE (DO)- -102.90401331°
SURFACEELEVA T/ON- 3627.05-

732

*

83^8

2

5>^0
S



Af /=>&?AfMA/LLG
rtATTL£SA/j4/C£-s4G/A/o. 7
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yOAKt/AS GCHSA/TX TjEXAS

m	Y aHcmws80i*a,7x:7B>

IhtebkityRk

i ] Positions, llc


-------
Railroad Commission of Texas

PERMIT TO DRILL, RE-COMPLETE, OR RE-ENTER ON REGULAR OR ADMINISTRATIVE EXCEPTION LOCATION

CONDITIONS AND INSTRUCTIONS

Permit Invalidation. It is the operator's responsibility to make sure that the permitted location complies with Commission density and
spacing rules in effect on the spud date. The permit becomes invalid automatically if, because of a field rule change or the drilling of another
well, the stated location is not in compliance with Commission field rules on the spud date. If this occurs, application for an exception to
Statewide Rules 37 and 38 must be made and a special permit granted prior to spudding. Failure to do so may result in an allowable not being
assigned and/or enforcement procedures being initiated.

Notice Requirements. Per H.B 630, signed May 8,2007, the operator is required to provide notice to the surface owner no later than the
15th business day after the Commission issues a permit to drill. Please refer to subchapter Q Sec. 91.751-91.755 of the Texas Natural
Resources Code for applicability.

Permit expiration. This permit expires two (2) years from the date of issuance shown on the original permit. The permit period will not
be extended.

Drilling Permit Number. The drilling permit number shown on the permit MUST be given as a reference with any notification to the
district (see below), correspondence, or application concerning this permit.

Rule 37 Exception Permits. This Statewide Rule 37 exception permit is granted under either provision Rule 37 (h)(2)(A) or 37(h)(2)(B).
Be advised that a permit granted under Rule 37(h)(2)(A), notice of application, is subject to the General Rules of Practice and Procedures
and if a protest is received under Section 1.3, "Filing of Documents," and/or Section 1.4, "Computation of Time," the permit may be deemed
invalid.

Before Drilling

Fresh Water Sand Protection. The operator must set and cement sufficient surface casing to protect all usable-quality water, as defined by
the Railroad Commission of Texas (RRC) Groundwater Advisory Unit (GWAU). Before drilling a well, the operator must obtain a letter from
the Railroad Commission of Texas stating the depth to which water needs protection, Write: Railroad Commission of Texas, Groundwater
Advisory Unit (GWAU), P.O. Box 12967, Austin, TX 78711-3087. File a copy of the letter with the appropriate district office.

Accessing the Well Site. If an OPERATOR, well equipment TRANSPORTER or WELL service provider must access the well site from a
roadway on the state highway system (Interstate, U.S. Highway, State Highway, Farm-to-Market Road, Ranch-to-Market Road, etc.), an
access permit is required from TxDOT. Permit applications are submitted to the respective TxDOT Area Office serving the county where the
well is located.

Water Transport to Well Site. If an operator intends to transport water to the well site through a temporary pipeline laid above
ground on the state's right-of-way, an additional TxDOT permit is required. Permit applications are submitted to the respective
TxDOT Area Office serving the county where the well is located.

^NOTIFICATION

The operator is REQUIRED to notify the district office when setting surface casing, intermediate casing, and production casing, or when
plugging a dry hole. The district office MUST also be notified if the operator intends to re-enter a plugged well or re-complete a well into a
different regulatory field. Time requirements are given below. The drilling permit number MUST be given with such notifications.

During Drilling

Permit at Drilling Site : A copy of the Form W-l Drilling Permit Application, the location plat, a copy of Statewide Rule 13
alternate surface casing setting depth approval from the district office, if applicable, and this drilling permit must be kept at the
permitted well site throughout drilling operations.

*Notification of Setting Casing : The operator MUST call in notification to the appropriate district office (phone number shown the
on permit) a minimum of eight (8) hours prior to the setting of surface casing, intermediate casing, AND production casing. The
individual giving notification MUST be able to advise the district office of the drilling permit number.

*Notification of Re-completion/Re-entry : The operator MUST call in notification to the appropriate district office (phone number
shown on permit) a minimum of eight (8) hours prior to the initiation of drilling or re-completion operations. The individual giving
notification MUST be able to advise the district office of the drilling permit number.

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 1 of 5


-------
Completion and Plugging Reports

Hydraulic Fracture Stimulation using Diesel Fuel: Most operators in Texas do not use diesel fuel in hydraulic fracturing fluids.

Section 322 of the Energy Policy Act of 2005 amended the Underground Injection Control (UIC) portion of the federal Safe Drinking Water
Act (42 USC 300h(d)) to define "underground Injection" to EXCLUDE " ...the underground injection of fluids or propping agents (other
than dieselfluels) pursuant to hydraulic fracturing operations related to oil, gas, or geothermal production activities." (italic and underlining
added.) Therefore, hydraulic fracturing may be subject to regulation under the federal UIC regulations if diesel fuel is injected or used as a
propping agent. EPA defined "diesel fuel" using the following five (5) Chemical Abstract Service numbers: 68334-30-5 Primary Name: Fuels,
diesel; 68476-34-6 Primary Name: Fuels, diesel, No. 2; 68476-30-2 Primary Name: Fuel oil No. 2; 68476-31-3 Primary Nmae: Fuel oil, No.
4; and 8008-20-6 Primary Name: Kerosene. As a result, an injection well permit would be required before performing hydraulic fracture
stimulation using diesel fuel as defined by EPA on any well in Texas. Hydraulic fracture stimulation using diesel fuel as defined by EPA on a
well in Texas without an injection well permit could result in enforcement action.

Producing Well: Statewide Rule 16 states that the operator of a well shall file with the Commission the appropriate completion report
within thirty (30) days after completion of the well or within ninety (90) days after the date on which the drilling operation is completed,
whichever is earlier. Completion of the well in a field authorized by this permit voids the permit for all other fields included in the permit
unless the operator indicates on the initial completion report that the well is to be a dual or multiple completion and promptly submits an
application for multiple completion. All zones are required to be completed before the expiration date on the existing permit. Statewide Rule
40(d) requires that upon successful completion of a well in the same reservoir as any other well previously assigned the same acreage,
proration plats and P-15s (if required) must be submitted with no double assignment of acreage.

Dry or Noncommercial Hole : Statewide Rule 14(b)(2) prohibits suspension of operations on each dry or non-commercial well without
plugging unless the hole is cased and the casing is cemented in compliance with Commission rules. If properly cased, Statewide Rule 14(b)(2)
requires that plugging operations must begin within a period of one (1) year after drilling or operations have ceased. Plugging operations must
proceed with due diligence until completed. An extension to the one-year plugging requirement may be granted under the provisions stated in
Statewide Rule 14(b)(2).

Intention to Plug : The operator must file a Form W-3 A (Notice of Intention to Plug and Abandon) with the district office at least five (5)
days prior to beginning plugging operations. If, however, a drilling rig is already at work on location and ready to begin plugging operations,
the district director or the director's delegate may waive this requirement upon request, and verbally approve the proposed plugging
procedures.

*Notification of Plugging a Dry Hole : The operator MUST call in notification to the appropriate district office (phone number shown on
permit) a minimum of four (4) hours prior to beginning plugging operations. The individual giving the notification MUST be able to advise
the district office of the drilling permit number and all water protection depths for that location as stated in the Texas Commission on
Environmental Quality letter.

DIRECT INQUIRIES TO: DRILLING PERMIT SECTION, OIL AND GAS DIVISION

PHONE
(512) 463-6751

MAIL:

PO Box 12967
Austin, Texas, 78711-2967

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 2 of 5


-------
RAILROAD COMMISSION OF TEXAS
OIL & GAS DIVISION

PERMIT TO DRILL, DEEPEN, PLUG BACK, OR RE-ENTER ON A REGULAR OR ADMINISTRATIVE EXCEPTION LOCATION

PERMIT NUMBER

839303

DATE PERMIT ISSUED OR AMENDED
04/27/2018

DISTRICT

8A

API NUMBER

42-501-36998

FORM W-l RECEIVED

04/25/2018

COUNTY

YOAKUM

TYPE OF OPERATION

New Drill

WELLBORE PROFILE(S)

Vertical

ACRES

640.0

OPERATOR 748093
SANTA FE MIDSTREAM PERMIAN LLC

5830 GRANITE PKWY STE 1025
PLANO, TX 75024-0000

NOTICE

This permit and any allowable assigned may
be revoked if payment for fee(s) submitted to
the Commission is not honored.
District Office Telephone No:

(806) 698-6509

LEASE NAME

RATTLESNAKE AGI

WELL NUMBER

1

LOCATION

7.3 miles NW direction from DENVER CITY

TOTAL DEPTH

12000

Section, Block and/or

SECTION 733 BLOCK D ABSTRACT 89
SURVEY GIBSON, J H

DISTANCE TO SURVEY LINES

200.0 ft NORTH 200.0 ft WEST

DISTANCE TO NEAREST LEASE LINE
200.0

DISTANCE TO LEASE LINES

200.0 ft NORTH 200.0 ft WEST

DISTANCE TO NEAREST WELL ON LEASE
See FIELD(s) Below

FIELD(s) and LIMITATIONS:

* SEE FIELD DISTRICT FOR REPORTING PURPOSES *

FIELDNAME	ACRES	DEPTH WELL#	DIST

LEASE NAME	NEAREST LEASE	NEAREST WELL

WASSON	"640!0	12000	1	8A

RATTLESNAKE AGI	200 0	0.0

This is a hydrogen sulfide field. This well shall be drilled in accordance with SWR 36.

Do not use this well for injection/disposal/hydrocarbon storage purposes without approval by the Environmental Services section of the Railroad Commission,
Austin, Texas office.

WASSON, NORTH (SAN ANDRES)	"64o!o	12000	1	8A

RATTLESNAKE AGI	200.0	0.0

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 3 of 5


-------
This is a hydrogen sulfide field. This well shall be drilled in accordance with SWR 36.

Do not use this well for injection/disposal/hydrocarbon storage purposes without approval by the Environmental Services section of the Railroad Commission,
Austin, Texas office.

THE FOLLOWING RESTRICTIONS APPLY TO ALL FIELDS
This well shall be completed and produced in compliance with applicable special field or statewide spacing and density rules. If this well is
to be used for brine mining, underground storage of liquid hydrocarbons in salt formations, or underground storage of gas in salt formations,
a permit for that specific purpose must be obtained from Environmental Services prior to construction, including drilling, of the well in
accordance with Statewide Rules 81, 95, and 97.

This well must comply to the new SWR 3.13 requirements concerning the isolation of any potential flow zones and zones with corrosive
formation fluids. See approved permit for those formations that have been identified for the county in which you are drilling the well in.

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 4 of 5


-------
Railroad Commission of Texas

Oil and Gas Division

SWR #13 Formation Data
YOAKUM (501) COUNTY

l-'oniiiilioii

Koniiirks

Order

I.ITcc(i\c
Diilo

RED BED-SANTA ROSA



1

01/01/2014

YATES



2

01/01/2014

SAN ANDRES

high flows, H2S, corrosive

3

01/01/2014

GLORIETA



4

01/01/2014

CLEARFORK

Active C02 Flood

5

01/01/2014

WICHITA



6

01/01/2014

LEONARD



7

01/01/2014

WOLFCAMP



8

01/01/2014

PENNSYLVANIAN



9

01/01/2014

STRAWN



10

01/01/2014

MISSISSIPPIAN



11

01/01/2014

DEVONIAN



12

01/01/2014

DEVONIAN-SILURIAN



13

01/01/2014

The above list may not be all inclusive, and may also include formations that do not intersect all wellbores. The listing order of the Formation
information reflects the general stratigraphic order and relative geologic age. This is a dynamic list subject to updates and revisions. It is the
operator's responsibility to make sure that at the time of spudding the well the most current list is being referenced. Refer to the RRC website
at the following address for the most recent information, http://www.rrc.texas.gov/oil-gas/compliance-enforcement/rule-13-geologic-
formation-info

Date Validation

Fri, 20 Nov 2020 09:32:59

Page 5 of 5


-------
B-4

RAILROAD COMMISSION OF TEXAS	Form G-1

1701 N. Congress	Status:	Approved

P.O. Box 12967	Date:	07/25/2019

Austin, Texas 78701-2967	Tracking No.:	205926

GAS WELL BACK PRESSURE TEST, COMPLETION OR RECOMPLETION REPORT, AND LOG

OPERATOR INFORMATION

Operator Name: santa fe midstream permian llc	Operator No.: 748093

Operator Address: 5830 granite pkwy ste 1025 plano, tx 75024-0000

WELL INFORMATION

API No.: 42-501-36998

County: YOAKUM

Well No.: 1

RRC District No.: 8A

Lease Name: RATTLESNAKE AG I

Field Name: WASSON

RRC Gas ID No.: 286838

Field No.: 95397001

Location: Section: 733, Block: D, Survey: GIBSON, J H, Abstract: 89



Latitude:

Longitude:

This well is located 7.3 miles in a nw



direction from Denver city,



which is the nearest town in the county.



FILING INFORMATION

Purpose of filing: Well Record Only



Type of completion: New Well



Well Type: Active UIC

Completion or Recompletion Date: 08/31/2018

Type of Permit

Date Permit No.

Permit to Drill, Plug Back, or Deepen

04/27/2018 839303

Rule 37 Exception



Fluid Injection Permit



O&G Waste Disposal Permit

11/14/2018 15848

Other:



COMPLETION INFORMATION

ISpud date: 07/16/2018

Date of first production after rig released: 08/31/2018 I

Date plug back, deepening, recompletion, or Date plug back, deepening, recompletion, or

drilling operation commenced: 07/16/2018

drilling operation ended: 08/31/2018

Number of producing wells on this lease in

Distance to nearest well in lease &

this field (reservoir) including this well:

1 reservoir (ft.): 0.0

Total number of acres in lease: 640.00

Elevation (ft.): 3627 GR

Total depth TVD (ft.): 11980

Total depth MD (ft.):

Plug back depth TVD (ft.): 11980

Plug back depth MD (ft.):

Was directional survey made other than

Rotation time within surface casing (hours): 72.0

inclination (Form W-12)? Yes

Is Cementing Affidavit (Form W-15) attached? Yes

Recompletion or reclass? No

Multiple completion? No

Type(s) of electric or other log(s) run: Combo of Induction/Neutron/Density/Sonic

Electric Log Other Description:



Location of well, relative to nearest lease boundaries Off Lease: No

of lease on which this well is located:

200.0 Feet from the North Line and



200 0 Feet from the West Line of the



rattlesnake agi Lease.

FORMER FIELD (WITH RESERVOIR) & GAS ID OR OIL LEASE NO.

Field & Reservoir

Gas ID or Oil Lease No. Well No. Prior Service Type



Page 1 of4


-------
G1:	N/A

PACKET:	N/A

FOR NEW DRILL OR RE-ENTRY, SURFACE CASING DEPTH DETERMINED BY:
GAU Groundwater Protection Determination	Depth (ft.): 2025.0	Date: 01/12/2018

SWR 13 Exception	Depth (ft.):

GAS MEASUREMENT DATA

I Date of test: Gas measurement method(s):





Gas production during test (MCF):







Was the well preflowed for 48 hours? No







Orif. or 24 hr. Coeff.

Run Line Choke Orif. Or Choke Static Pm or Diff
No. size Size (in.) (in.) Choke (in.) (hw)

Flow

Temp Temp. Gravity
(°F) (l-tt) (hg)

Compress
(Fpv)

Volume
(MCF/day)

N/A







FIELD DATA AND PRESSURE CALCULATIONS

Gravity (dry gas):

Gas-Liquid Hydro Ratio (CF/Bbl):

Avg. shut in temp. (°F):

Gravity (liquid hydrocarbons) (Deg. API):

Gravity (mixture): Gmix=

Bottom hole temp, and depth: °F@ ft

Run No. Time of Run (Min.)

Choke Size (in.) Wellhead Pressure (PSIA) Wellhead Flow Temp (°F )

N/A



CASING RECORD

Casing Hole Setting Multi - Multi -	Cement Slurry Top of TOC

Type of

Size

Size

Depth Stage Tool Stage Shoe Cement Amount Volume Cement Determined

Row Casing

(in.)

(in.)

(ft.)

Depth (ft.) Depth (ft.)

Class

(sacks)

(cu. ft.)

(ft.)

By

1 Surface

13 3/8

17 1/2

504



c

510

687.5

0

Circulated to Surface

3 Intermediate

9 5/8

12 1/4

5498

5498

c

485

797.0

4275

Circulated to Surface

2 Intermediate

13 3/8

17 1/2

5498

4275

c

1650

3045.0

0

Circulated to Surface

6 Conventional Production

7

8 3/4

11023



WELL

60

337.0

9575

Calculation











LOCK









5 Conventional Production

7

8 3/4

11023

5591

PREM

380

906.5

0

Circulated to Surface











PLUS









4 Conventional Production

7

8 3/4

11023

9575

PREM

380

906.5

5591

Calculation











PLUS









LINER RECORD









Cement

Slurry

Top of

TOC

Liner Hole

Liner

Liner

Cement

Amount

Volume

Cement

Determined

Row Size (in.) Size (in.)

Top (ft.)

Bottom (ft.)

Class

(sacks)

(cu. ft.)

(ft.)

By

N/A















TUBING RECORD

Row

Size (in.)

Depth Size (ft.)

Packer Depth (ft.)/Type

1

3 1/2

10966

10966 / HALLIBURTON







BWD

PRODUCING/INJECTION/DISPOSAL INTERVAL

Row

Open hole?

From (ft.)

To (ft.)

1

Yes

L 11025

11980

Page 2 of4


-------
ACID, FRACTURE, CEMENT SQUEEZE,

CAST IRON BRIDGE PLUG, RETAINER, ETC.

Was hydraulic fracturing treatment performed? No

Is well equipped with a downhole actuation



sleeve? No

If yes, actuation pressure (PSIG):

Production casing test pressure (PSIG) prior to

Actual maximum pressure (PSIG) during hydraulic

hydraulic fracturing treatment:

fracturing:

Has the hydraulic fracturing fluid disclosure been



reported to FracFocus disclosure registry (SWR29)?

No

Row Type of Operation Amount and Kind of Material Used Depth Interval (ft.)

N/A



FORMATION RECORD

Is formation

Formations	Encountered Depth TVD (ft.) Depth MP (ft.) isolated? Remarks

YATES

Yes

3019.0

Yes



SAN ANDRES - HIGH FLOWS, H2S,

Yes

4465.0

Yes



CORROSIVE









GLORIETA

Yes

6316.0

Yes



CLEARFORK - ACTIVE C02 FLOOD

Yes

6492.0

Yes



WICHITA

Yes

8628.0

Yes



UPPER WOLFCAMP

Yes

9239.0

Yes



STRAWN

Yes

10030.0

Yes



ATOKA

Yes

10230.0

Yes



WOODFORD

Yes

10973.0

Yes



DEVONIAN

Yes

11036.0

No

DISPOSAL

WRISTEN

Yes

11268.0

No

DISPOSAL

FUSSELMAN

Yes

11538.0

No

DISPOSAL

MONTOYA

Yes

11974.0

No

DISPOSAL

RED BED-SANTA ROSA

No



No

NOT IN AREA

LEONARD

No



No

NOT IN AREA

WOLFCAMP

No



No

NOT IN AREA

PENNSYLVANIAN

No



No

NOT IN AREA

STRAWN

No



No

NOT IN AREA

MISSISSIPPIAN

No



No

NOT IN AREA

Do the producing interval of this well produce H2S with a concentration in excess of 100 ppm (SWR 36)?	No

s the completion being downhole commingled (SWR 10)?	No

REMARKS

NEW WELL PUTTING ON SCHEDULE.

Page 3 of4


-------
OPERATOR'S CERTIFICATION

Printed Name: Karen Zornes

Title:

Telephone No.: (281) 872-9300

Date Certified: 06/25/2019

Page 4 of4


-------
APPENDIX C - GAS COMPOSITION


-------
C-1

1 rv » n,,

natural Gas Analysis

www.permianls.com
575.397.3713 2609 W Marland HobbS NM 88240

11093G

30/30 Acid Gas

Sample Point Code

Sample Point Name

C6+ Gas Analysis Report

30/30 Acid Gas

Sample Point Location

Laboratory Services

Date Sampled

2021048523

1781

E Benavides - Spot

Source Laboratory



Lab File No

Container Identity

Sampler

USA

USA



USA

Texas

District

Area Name



Field Name

Facility Name

Nov 16, 2021



Nov 16, 2021

Nov 19, 2021 09:59

Nov 19, 2021

Date Effective

System Administrator

Ambient Temp (°F)

Flow Rate (Mcf)

Analyst

Date Received

21 @ 129

Press PSI @ Temp °F
Source Conditions

Date Reported

Stakeholder Midstream

30/30

Operator

Lab Source Description

Component

Normalized
Mol %

Un-Normalized
Mol %

GPM

H2S (H2S)

9.2000

9.2



Nitrogen (N2)

0.0000

0



C02 (C02)

89.6780

98.775



Methane (CI)

0.3030

0.331



Ethane (C2)

0.0580

0.063

0.0150

Propane (C3)

0.1080

0.118

0.0300

I-Butane (IC4)

0.0000

0

0.0000

N-Butane (NC4)

0.0250

0.027

0.0080

I-Pentane (IC5)

0.0000

0

0.0000

N-Pentane (NC5)

0.0000

0

0.0000

Hexanes Plus (C6+)

0.6280

0.686

0.2710

TOTAL

100.0000

109.2000

0.3240

Method(s): Gas C6+ - GPA 2261, Extended Gas - GPA 2286, Calculations - GPA 2172

Analyzer Information
Device Type: Gas Chromatograph Device Make: Shimadzu
Device Model: GC-2014	Last Cal Date: Nov 14, 2021

Gross Heating Values (Real, BTU/ft3)

14.696 PSI @ 60.00 A°F	14.65 PSI @ 60.00 A°F

Dry	Saturated	Dry	Saturated

98.7	98.00	98.4	97.7

Calculated Total Sample Properties

GPA2145-16 Calculated at Contract Conditions
Relative Density Real	Relative Density Ideal

1.5042	1.4956

Molecular Weight

43.3157

C6 - 60.000%

C6+ Group Properties

Assumed Composition

C7 - 30.000%

C8 - 10.000%

Field H2S

92000 PPM

PROTREND STATUS:	DATA SOURCE:

Passed By Validator on Nov 21, 2021 Imported

PASSED BY VALIDATOR REASON:

Close enough to be considered reasonable.

VALIDATOR:

Dustin Armstrong

VALIDATOR COMMENTS:

OK

Nov 22, 2021 7:57 a

Powered By ProTrend -www.criticalcontrol.com

Page 1 of 1


-------
APPENDIX D - FACILITY SAFETY PLOT PLANS


-------
PLANT NORTH

LEGEND

•

FIRE EXTINGUISHER

~

SCBA/ESCAPE PACK

~

WIND SOCK

®

LEL/H2S MONITOR



ESD BUTTON

H

STROBE LIGHTS



HORN

D-1



	r

i| 1 | |—1 l\ 71 1 k 1 A 1 \ W—1 / \ 1 1









—\

JKI 1 IMINAKY 1 ()l>











	pn/ic\A/	







0

NO.

05/11 / 22
DATE

INITIAL RELEASE K C V 1 C V V
REVISION DESCRIPTION

KLD
BY

BEC
FCE

JB
CLIENT

CHAR1S ENGINEERING. LLC
"IX ENG. FIRM NO. F-1B8B4
MIDLAND. IX

STAKEHOLDER
MIDSTREAM

CLIENT ;

PROJECT ;

TITLE :

STAKEHOLDER MIDSTREAM

30-30 GAS PLANT

SAFETY EQUIPMENT PLOT PLAN

1" = 50'—0"

DATE

5/11/22

ME—PLNP—AOOO—0004

A


-------
APPENDIX E - MMA/AMA REVIEW MAPS

APPENDIX E-l: PLUME BOUNDARY AT END OF INJECTION, STABILIZED PLUME BOUNDARY AND MAXIMUM
MONITORING AREA MAP

APPENDIX E-2: ACTIVE MONITORING AREA MAP

APPENDIX E-3: OIL AND GAS WELLS WITHIN THE MMA MAP

APPENDIX E-4: OIL AND GAS WELLS WITHIN THE MMA LIST

APPENDIX E-5: INJECTION INTERVAL PENETRATING WELLS WITHIN THE MMA MAP

APPENDIX E-6: GROUNDWATER WELLS WITHIN THE MMA

APPENDIX E-7: WELLBORE SCHEMATICS FOR INJECTION INTERVAL PENETRATING WELLS


-------
A-1143

A-545

A-1866
A-572

A-£ 58

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& Stabilized Plume
with

1/2-Mile Maximum Monitoring Area (MMA)

Stakeholder Midstream
Yoakum Co., TX

A-1314

A-549

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY

1



ENGINEERS

ADVISORS



AUSTIN • HOUSTON jj

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

Rattlesnake AGI No. 1 SHL

I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

J Plume Boundary at End of Injection

1560


-------
A-1143

Rattlesnake AGI No. 1
Plume Boundary at End of Injection
& 19-Year Plume
with

1/2-Mile Active Monitoring Area (AMA)

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY

1



ENGINEERS

ADVISORS



AUSTIN • HOUSTON jj

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

E-2

Rattlesnake AGI No. 1 SHL

1 Active Monitoring Area Boundary

1 9-Year Plume

J Plume Boundary at End of Injection

Abstract

Note: All coordinates shown are in NAD83 (DD).

MAP EXTENT

~


-------
A-1866



A-1314

iiiiiiiiij

36998 l\

RATTLESNAKE AGI NO

33.0513499,1

-102.90450576

00000

32541

00261

32531

00000

iiiiiiiiii

00000"

00000

00262

000

\ 00645 •

00050

00643s

00644

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33349.

33530

00057

33173

32702

34984\

32065

00059

33172

33531

A-1484

33531'

32703

33351

32064

,00061

00000

00060

00058

32704

33 no 3

00065

00068

00064

^067 ^

32945

32975

32077

32075

: 30600

32076

36156

00267

00266

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00063

02992

02991

02990

02989 35820

A-1816

34878

32070

36155

36151 30604 35791 30602

30606

JO fyy

36152

35821

30630

32072

36153

30601

30605

35794

35793 30598

36150

30603

36048

36154

35180

35703

35701

35705

30000

=3058.4;

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33065

1:34099;

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33843

LONQUIST & CO LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN • HOUSTON jfc CALGARY • WICHITA
DENVER • COLLEGE STATION T BATON ROUGE • EDMONTON

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

+ Rattlesnake AC I No. 1 SHL
| ~ ~ ™ 1/2-Mile Buffer from Max. Plume Extent (MMA)
I ~ Z Z Z Combined Maximum Plume Extent
1	Stabilized Plume

I ~ ~ ~ Z Plume Boundary at End of Injection
Abstract

	Lateral (21)

API (42-501-...) SHL Status - Type (Count)
O Horizontal Surface Location (21)

•	Active - Oil (93)

Active - Injection/Disposal (21)

•» Active - Injection/Disposal from Oil (22)
X Plugged - Oil (69)

^ Plugged - Gas (1)

Plugged- Injection/Disposal from Oil (1)

Shut-In - Oil (1)

TA - Injection/Disposal (3)

TA - Injection/Disposal from Oil (7)

"0" Dry Hole (6)
o Permitted Location (2)
0 Canceled/Abandoned Location (6)
X Expired Permit (7)

API (42-501-...) BHL Status - Type (Count)

•	Active - Oil (11)

•A Active - Injection/Disposal from Oil (1)

Shut-In - Oil (1)

TA - Injection/Disposal from Oil (1)

o Permitted Location (4)

X Expired Permit (3)

Sou rce:

1.)	Oil/Cas Well SHL Data: DI-2022

2.)	Oil/Cas Well BHL Data: DI-2022

3.)	Oil/Cas Well Directional Data: DI-2022

* Note: All coordinates shown are in NAD83 (DD). *

Rattlesnake AGI No. 1
Maximum Monitoring Area
with

1/2-Mile MMA Oil/Gas Well
Area of Review

Stakeholder Midstream
Yoakum Co., TX

1

A-1531

A-1064

A-87

A-1483

A-1641

A-499

VI55 !

i .-1777

A


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

E-4

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250101829

DENVER UNIT

2215W

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5300

5300

2215W

4250101835

DENVER UNIT

2207

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5185

5185

2207

4250130914

DENVER UNIT

2222

OCCIDENTAL PERMIAN LTD.

Active - Oil





2222

4250101832

DENVER UNIT

2201W

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5190

5190

2201W

4250101826

DENVER UNIT

2203

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5250

5250

2203

4250101319

ROBERTS UNIT

4532W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5200

5200

4532W

4250130629

ROBERTS UNIT

4535

APACHE CORPORATION

Active - Oil

5280

5280

4535

4250130583

ROBERTS UNIT

4525

APACHE CORPORATION

Active - Oil

5286

5286

4525

4250101318

ROBERTS UNIT

4541

APACHE CORPORATION

TA - Injection/Disposal from Oil

5240

5240

4541

4250101889

ROBERTS UNIT

3614

APACHE CORPORATION

Plugged - Oil

5180

5180

3614

4250130598

Roberts Unit

3647

APACHE CORPORATION

Plugged - Oil

5281

5281

3647

4250130603

ROBERTS UNIT

3626

APACHE CORPORATION

Plugged - Oil

5289

5289

3626

4250102992

ROBERTS UNIT

3612W

APACHE CORPORATION

Plugged - Oil

5226

5226

3612W

4250100066

ROBERTS UNIT

3532

APACHE CORPORATION

Plugged - Oil

5231

5231

3532

4250101886

ROBERTS UNIT

3631

APACHE CORPORATION

Plugged - Oil





3631

4250101885

ROBERTS UNIT

3641

APACHE CORPORATION

Plugged - Oil

5212

5212

3641

4250100068

ROBERTS UNIT

3521

APACHE CORPORATION

Plugged - Oil

5225

5225

3521

4250100064

ROBERTS UNIT

3541

APACHE CORPORATION

Plugged - Oil

5264

5264

3541

4250102014

ROBERTS UNIT

2443

APACHE CORPORATION

Plugged - Oil

5226

5226

2443

4250100050

ROBERTS UNIT

1654

APACHE CORPORATION

Plugged - Oil

5198

5198

1654

4250133531

ROBERTS UNIT

2443A



Active - Injection/Disposal

5325

5325

2443A

4250133502

ROBERTS UNIT

2527A



Plugged - Oil

5308

5308

2527A

4250100000

C. A. ELLIOTT

6

AMERICAN LIBERTY OIL CO

Plugged - Oil

5229

5229

6

4250100000

C. A. ELLIOTT

7

AMERICAN LIBERTY AND ATLANTIC

Active - Oil

5182

5182

7

4250100000

GEO CLEVELAND

1

DELFERN OIL CO

Dry Hole

5071

5071

1

4250100000

JAMES H. LYNN

1614

AMERICAN LIBERTY

Active - Oil

5169

5169

1614

4250100000

J. H. LYNN

1634

AMERICAN LIBERTY

Active - Oil

5160

5160

1634

4250100000

A. T. MORRIS

1

ATLANTIC

Active - Oil

5235

5235

1

4250100000

A. T. MORRIS

2

AMERICAN LIBERTY OIL CO

Plugged - Oil

5179

5179

2

4250100000

W.J. CARPENTER

1642

AMERICAN LIBERTY OIL COMPANY

Plugged - Oil

5183

5183

1642

4250100000

E.S.SMITH

1

CREAT WESTERN FROD

Dry Hole

5216

5216

1

4250130607

ROBERTS UNIT

3546



Active - Oil





3546

4250135958

DENVER UNIT

2247

OCCIDENTAL PERMIAN LTD.

Active - Oil

2333

2333

2247

4250131542

DENVER UNIT

2229

SHELL OIL COMPANY

Dry Hole

2409

2409

2229

4250101320

ROBERTS UNIT

4543

APACHE CORPORATION

Active - Injection/Disposal from Oil

5120

5120

4543

4250137301

MILLER

8H

AMTEX ENERGY, INC.

Active - Oil

5157

5157

8H

4250137304

MILLER 732 C

10H

AMTEX ENERGY, INC.

Permitted Location

5157

5157

10H

4250137305

MILLER 732 D

11H

AMTEX ENERGY, INC.

Permitted Location

5157

5157

11H

4250101888

ROBERTS UNIT

3634W

APACHE CORPORATION

Plugged - Oil

5160

5160

3634W


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250101031

ROBERTS UNIT

3534W

APACHE CORPORATION

Plugged - Oil

5164

5164

3534W

4250101828

DENVER UNIT

2208

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5170

5170

2208

4250101032

ROBERTS UNIT

3544

APACHE CORPORATION

Plugged - Oil

5170

5170

3544

4250101841

DENVER UNIT

2206

OCCIDENTAL PERMIAN LTD.

TA - Injection/Disposal from Oil

5177

5177

2206

4250101842

ROBERTS UNIT

3643W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5180

5180

3643W

4250101035

ROBERTS UNIT

3533W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5180

5180

3533W

4250132704

ROBERTS UNIT

2615

APACHE CORPORATION

Active - Oil

5180

5180

2615

4250100261

ROBERTS UNIT

1643W

APACHE CORPORATION

Plugged - Oil

5180

5180

1643W

4250101323

ROBERTS UNIT

4542W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5182

5182

4542W

4250102989

ROBERTS UNIT

3642W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5182

5182

3642W

4250102991

ROBERTS UNIT

3622W

APACHE CORPORATION

Plugged - Oil

5185

5185

3622W

4250132417

MILLER

3

AMTEX ENERGY, INC.

Active - Oil

5186

5186

3

4250101025

ROBERTS UNIT

2613W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5188

5188

2613W

4250101887

ROBERTS UNIT

3644

APACHE CORPORATION

Active - Injection/Disposal from Oil

5189

5189

3644

4250101830

DENVER UNIT

2214WC

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5190

5190

2214WC

4250101103

ROBERTS UNIT

3621

APACHE CORPORATION

Plugged - Oil

5190

5190

3621

4250101024

ROBERTS UNIT

2623

APACHE CORPORATION

Plugged - Oil

5190

5190

2623

4250101023

ROBERTS UNIT

2622W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5190

5190

2622W

4250101022

ROBERTS UNIT

2632

APACHE CORPORATION

Active - Oil

5190

5190

2632

4250101019

ROBERTS UNIT

2621

APACHE CORPORATION

Active - Oil

5190

5190

2621

4250101030

ROBERTS UNIT

3524W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5193

5193

3524W

4250101829

DENVER UNIT

2205

OCCIDENTAL PERMIAN LTD.

TA - Injection/Disposal from Oil

5195

5195

2205

4250101836

DENVER UNIT

2213WC

OCCIDENTAL PERMIAN LTD.

TA - Injection/Disposal from Oil

5200

5200

2213WC

4250101833

DENVER UNIT

2202WC

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5200

5200

2202WC

4250134099

DENVER UNIT

2239WC

OCCIDENTAL PERMIAN LTD.

Dry Hole

5200

5200

2239WC

4250132717

ROBERTS UNIT

3531A

APACHE CORPORATION

TA - Injection/Disposal

5200

5200

3531A

4250101014

ROBERTS UNIT

2624W

APACHE CORPORATION

Plugged - Oil

5200

5200

2624W

4250101028

ROBERTS UNIT

3523

APACHE CORPORATION

Plugged - Oil

5205

5205

3523

4250101102

ROBERTS UNIT

3611

APACHE CORPORATION

Plugged - Oil

5206

5206

3611

4250101827

DENVER UNIT

2209W

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5210

5210

2209W

4250101015



2643

TEXACO INCORPORATED

Active - Injection/Disposal from Oil

5210

5210

2643

4250100266

ROBERTS UNIT

3522W

APACHE CORPORATION

Plugged - Oil

5211

5211

3522W

4250132632

MILLER

5

AMTEX ENERGY, INC.

Active - Oil

5213

5213

5

4250100057

ROBERTS UNIT

2512W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5213

5213

2512W

4250101890

ROBERTS UNIT

3624W

APACHE CORPORATION

Plugged - Oil

5214

5214

3624W

4250101033

ROBERTS UNIT

3543W

APACHE CORPORATION

Plugged - Oil

5215

5215

3543W

4250101012

ROBERTS UNIT

2634W

APACHE CORPORATION

Plugged- Injection/Disposal from Oil

5215

5215

2634W

4250101734

ROBERTS UNIT

2442

APACHE CORPORATION

Plugged - Oil

5215

5215

2442

4250101020

ROBERTS UNIT

2611W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5215

5215

2611W


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250100067

ROBERTS UNIT

3531

APACHE CORPORATION

Plugged - Oil

5216

5216

3531

4250101013

ROBERTS UNIT

2614W

APACHE CORPORATION

Plugged - Oil

5216

5216

2614W

4250101844

ROBERTS UNIT

3623W

APACHE CORPORATION

Plugged - Oil

5217

5217

3623W

4250131869

ROBERTS UNIT

A3534W

APACHE CORPORATION

Plugged - Oil

5220

5220

A3534W

4250102990

ROBERTS UNIT

3632W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5220

5220

3632W

4250100262

ROBERTS UNIT

1644W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5220

5220

1644W

4250132858

DENVER UNIT

2235

OCCIDENTAL PERMIAN LTD.

Shut-In - Oil

5225

5225

2235

4250100058

ROBERTS UNIT

2544W

APACHE CORPORATION

Plugged - Oil

5225

5225

2544W

4250130584

ROBERTS UNIT

4520

APACHE CORPORATION

Active - Oil

5230

5230

4520

4250130630

ROBERTS UNIT

3535

APACHE CORPORATION

Active - Oil

5230

5230

3535

4250100063

ROBERTS UNIT

3542W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5230

5230

3542W

4250132076

ROBERTS UNIT

3627

APACHE CORPORATION

Active - Oil

5230

5230

3627

4250100267

ROBERTS UNIT

3512W

APACHE CORPORATION

Plugged - Oil

5233

5233

3512W

4250101016

ROBERTS UNIT

2642W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5234

5234

2642W

4250134716

DENVER UNIT

2242

OCCIDENTAL PERMIAN LTD.

Active - Oil

5236

5236

2242

4250100061

ROBERTS UNIT

2524W

APACHE CORPORATION

Plugged - Oil

5238

5238

2524W

4250101021

ROBERTS UNIT

2633

APACHE CORPORATION

Plugged - Oil

5240

5240

2633

4250101011

ROBERTS UNIT

2644W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5241

5241

2644W

4250132541

FUTCH

1

AMTEX ENERGY, INC.

Active - Oil

5244

5244

1

4250101026

ROBERTS UNIT

2612W

APACHE CORPORATION

Plugged - Oil

5245

5245

2612W

4250100059

ROBERTS UNIT

2513W

APACHE CORPORATION

Active - Injection/Disposal from Oil

5246

5246

2513W

4250132531

MILLER

4

AMTEX ENERGY, INC.

Plugged - Oil

5248

5248

4

4250132687

ROBERTS UNIT

2635

APACHE CORPORATION

Plugged - Oil

5248

5248

2635

4250131656

DENVER UNIT

2232WC

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5250

5250

2232WC

4250131791

DENVER UNIT

2231

SHELL OIL COMPANY

Canceled/Abandoned Location

5250

5250

2231

4250134118

DENVER UNIT

2238

OCCIDENTAL PERMIAN LTD.

Active - Oil

5250

5250

2238

4250101342

ROBERTS UNIT



APACHE CORPORATION

Plugged - Gas

5250

5250



4250132269

ROBERTS UNIT

3601

APACHE CORPORATION

Plugged - Oil

5250

5250

3601

4250101843

ROBERTS UNIT

3633W

APACHE CORPORATION

Plugged - Oil

5250

5250

3633W

4250130608

ROBERTS UNIT

3545

APACHE CORPORATION

Active - Oil

5250

5250

3545

4250132077

ROBERTS UNIT

3617

APACHE CORPORATION

Active - Oil

5250

5250

3617

4250134963

DENVER UNIT

2244WC

OCCIDENTAL PERMIAN LTD.

TA- Injection/Disposal

5251

5251

2244WC

4250100060

ROBERTS UNIT

2514

APACHE CORPORATION

Plugged - Oil

5251

5251

2514

4250101459

DENVER UNIT

2211

OCCIDENTAL PERMIAN LTD.

Active - Oil

5252

5252

2211

4250132521

DENVER UNIT

2233W

OCCIDENTAL PERMIAN LTD.

TA- Injection/Disposal from Oil

5253

5253

2233W

4250135211

DENVER UNIT

2241

OCCIDENTAL PERMIAN LTD.

Active - Oil

5253

5253

2241

4250101837

DENVER UNIT

2212W

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5255

5255

2212W

4250132793

MILLER

6

AMTEX ENERGY, INC.

Active - Oil

5258

5258

6

4250132356

MILLER

1

AMTEX ENERGY, INC.

Active - Oil

5260

5260

1


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250101017

ROBERTS UNIT

2641

APACHE CORPORATION

Active - Oil

5260

5260

2641

4250101825

DENVER UNIT

2204W

OCCIDENTAL PERMIAN LTD.

Active - Injection/Disposal from Oil

5264

5264

2204W

4250132416

MILLER

2

AMTEX ENERGY, INC.

Active - Oil

5269

5269

2

4250100065

ROBERTS UNIT

3511W

APACHE CORPORATION

Plugged - Oil

5270

5270

3511W

4250101018

ROBERTS UNIT

2631

APACHE CORPORATION

Active - Oil

5270

5270

2631

4250130600

ROBERTS UNIT

3645

APACHE CORPORATION

Active - Oil

5273

5273

3645

4250130580

ROBERTS UNIT

4536

APACHE CORPORATION

Active - Oil

5279

5279

4536

4250130599

ROBERTS UNIT

3646

APACHE CORPORATION

Active - Oil

5279

5279

3646

4250130602

ROBERTS UNIT

3635

APACHE CORPORATION

Active - Oil

5283

5283

3635

4250132997

DENVER UNIT

2208WC

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5284

5284

2208WC

4250130601

ROBERTS UNIT

3636

APACHE CORPORATION

Active - Oil

5286

5286

3636

4250132174

SHEPHERD

1

YOUNG, MARSHALL R., OIL CO.

Dry Hole

5286

5286

1

4250130604

ROBERTS UNIT

3625

APACHE CORPORATION

Active - Oil

5287

5287

3625

4250130912

DENVER UNIT

2224

OCCIDENTAL PERMIAN LTD.

Active - Oil

5288

5288

2224

4250130911

DENVER UNIT

2225

OCCIDENTAL PERMIAN LTD.

Active - Oil

5290

5290

2225

4250130609

ROBERTS UNIT

4530

APACHE CORPORATION

Active - Oil

5291

5291

4530

4250130605

ROBERTS UNIT

3616

APACHE CORPORATION

Plugged - Oil

5291

5291

3616

4250130606

ROBERTS UNIT

3615

APACHE CORPORATION

Active - Oil

5293

5293

3615

4250133172

ROBERTS UNIT

2523

CONOCOPHILLIPS COMPANY

Plugged - Oil

5295

5295

2523

4250132739

CLEVELAND

1

HIGHLAND PRODUCTION COMPANY

Plugged - Oil

5300

5300

1

4250133064

DENVER UNIT

2238

SHELL WESTERN E&P INC.

Canceled/Abandoned Location

5300

5300

2238

4250132927

DENVER UNIT

2236

OCCIDENTAL PERMIAN LTD.

Active - Oil

5300

5300

2236

4250133065

DENVER UNIT

2237

SHELL WESTERN E&P INC.

Expired Permit

5300

5300

2237

4250132270

ROBERTS UNIT

4540

APACHE CORPORATION

Active - Oil

5300

5300

4540

4250132414

ROBERTS UNIT

3523A

APACHE CORPORATION

Active - Injection/Disposal

5300

5300

3523A

4250132712

ROBERTS UNIT

3537

APACHE CORPORATION

Plugged - Oil

5300

5300

3537

4250132722

ROBERTS UNIT

3547

APACHE CORPORATION

Active - Oil

5300

5300

3547

4250132945

ROBERTS UNIT

3541A

TEXACO PRODUCING INC.

Expired Permit

5300

5300

3541A

4250132975

ROBERTS UNIT

3641A

TEXACO PRODUCING INC.

Expired Permit

5300

5300

3641A

4250132711

ROBERTS UNIT

3620

APACHE CORPORATION

Active - Oil

5300

5300

3620

4250133527

ROBERTS UNIT

2518

APACHE CORPORATION

Active - Oil

5300

5300

2518

4250132714

ROBERTS UNIT

2637

APACHE CORPORATION

Plugged - Oil

5300

5300

2637

4250133351

ROBERTS UNIT

2526

TEXACO PRODUCING INC.

Expired Permit

5300

5300

2526

4250132703

ROBERTS UNIT

2516

APACHE CORPORATION

Plugged - Oil

5300

5300

2516

4250133348

ROBERTS UNIT

2533

TEXACO PRODUCING INC.

Expired Permit

5300

5300

2533

4250132702

ROBERTS UNIT

2515

APACHE CORPORATION

Active - Oil

5300

5300

2515

4250133350

ROBERTS UNIT

2525

APACHE CORPORATION

Active - Oil

5300

5300

2525

4250133498

ROBERTS UNIT

2532

TEXACO PRODUCING INC.

Expired Permit

5300

5300

2532

4250133173

ROBERTS UNIT

2522

APACHE CORPORATION

Active - Oil

5300

5300

2522


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250133499

ROBERTS UNIT

2527

TEXACO PRODUCING INC.

Dry Hole

5300

5300

2527

4250133530

ROBERTS UNIT

2507

APACHE CORPORATION

Active - Oil

5300

5300

2507

4250132685

ROBERTS UNIT

2638

APACHE CORPORATION

Plugged - Oil

5302

5302

2638

4250133349

ROBERTS UNIT

2517

APACHE CORPORATION

Active - Oil

5302

5302

2517

4250132718

ROBERTS UNIT

3532A

APACHE CORPORATION

Active - Injection/Disposal

5304

5304

3532A

4250132713

ROBERTS UNIT

2625

APACHE CORPORATION

Active - Oil

5308

5308

2625

4250133502

ROBERTS UNIT

2527A

APACHE CORPORATION

Plugged - Oil

5308

5308

2527A

4250132716

ROBERTS UNIT

3526

APACHE CORPORATION

Active - Oil

5309

5309

3526

4250100645

ROBERTS UNIT

1624W

APACHE CORPORATION

TA - Injection/Disposal from Oil

5309

5309

1624W

4250130913

DENVER UNIT

2223

OCCIDENTAL PERMIAN LTD.

Active - Oil

5310

5310

2223

4250132686

ROBERTS UNIT

2636

APACHE CORPORATION

Active - Oil

5310

5310

2636

4250101457

DENVER UNIT

2210

OCCIDENTAL PERMIAN LTD.

Plugged - Oil

5325

5325

2210

4250133529

ROBERTS UNIT

2508

APACHE CORPORATION

Plugged - Oil

5325

5325

2508

4250133531

ROBERTS UNIT

2443A

APACHE CORPORATION

Active - Injection/Disposal

5325

5325

2443A

4250133528

ROBERTS UNIT

2511

APACHE CORPORATION

Active - Oil

5325

5325

2511

4250135912

ROBERTS UNIT

3771W

APACHE CORPORATION

Active - Injection/Disposal

5330

5330

3771W

4250132075

ROBERTS UNIT

3637

APACHE CORPORATION

Active - Oil

5330

5330

3637

4250132063

ROBERTS UNIT

2705

APACHE CORPORATION

Active - Oil

5330

5330

2705

4250135793

ROBERTS UNIT

3672

APACHE CORPORATION

Active - Oil

5334

5334

3672

4250135819

ROBERTS UNIT

3674W

APACHE CORPORATION

Active - Injection/Disposal

5336

5336

3674W

4250135792

ROBERTS UNIT

3671

APACHE CORPORATION

Active - Oil

5339

5339

3671

4250135820

ROBERTS UNIT

3675W

APACHE CORPORATION

Active - Injection/Disposal

5341

5341

3675W

4250135818

ROBERTS UNIT

3633RW

APACHE CORPORATION

Active - Injection/Disposal

5344

5344

3633RW

4250135790

ROBERTS UNIT

3647R

APACHE CORPORATION

Active - Oil

5345

5345

3647R

4250100768

CORNELL UNIT

3107W

XTO ENERGY INC.

Active - Injection/Disposal from Oil

5350

5350

3107W

4250130915

DENVER UNIT

2221

OCCIDENTAL PERMIAN LTD.

Active - Oil

5350

5350

2221

4250136048

ROBERTS UNIT

3634RW

APACHE CORPORATION

Active - Injection/Disposal

5350

5350

3634RW

4250135908

ROBERTS UNIT

3678W

APACHE CORPORATION

Active - Injection/Disposal

5350

5350

3678W

4250132072

ROBERTS UNIT

3525

APACHE CORPORATION

Active - Oil

5350

5350

3525

4250135915

ROBERTS UNIT

3626R

APACHE CORPORATION

Active - Oil

5350

5350

3626R

4250132281

ROBERTS UNIT

2446

APACHE CORPORATION

Active - Oil

5350

5350

2446

4250132064

ROBERTS UNIT

2704

APACHE CORPORATION

Active - Oil

5350

5350

2704

4250132280

ROBERTS UNIT

2445

APACHE CORPORATION

Plugged - Oil

5350

5350

2445

4250135791

ROBERTS UNIT

3670

APACHE CORPORATION

Active - Oil

5351

5351

3670

4250135794

ROBERTS UNIT

3673

APACHE CORPORATION

Active - Oil

5352

5352

3673

4250135821

ROBERTS UNIT

3676W

APACHE CORPORATION

Active - Injection/Disposal

5352

5352

3676W

4250135914

ROBERTS UNIT

3681W

APACHE CORPORATION

Active - Injection/Disposal

5352

5352

3681W

4250100643

ROBERTS UNIT

1634W

APACHE CORPORATION

Plugged - Oil

5353

5353

1634W

4250135796

ROBERTS UNIT

3669

APACHE CORPORATION

Active - Oil

5356

5356

3669


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250100644

ROBERTS UNIT

1614

APACHE CORPORATION

Plugged - Oil

5356

5356

1614

4250135913

ROBERTS UNIT

3680W

APACHE CORPORATION

Active - Injection/Disposal

5357

5357

3680W

4250135705

ROBERTS UNIT

3752

APACHE CORPORATION

Active - Oil

5360

5360

3752

4250135822

ROBERTS UNIT

3677W

APACHE CORPORATION

Active - Injection/Disposal

5362

5362

3677W

4250134984

ROBERTS UNIT

2626W

APACHE CORPORATION

Active - Injection/Disposal

5364

5364

2626W

4250135701

ROBERTS UNIT

3667

APACHE CORPORATION

Active - Oil

5365

5365

3667

4250132070

ROBERTS UNIT

3536

APACHE CORPORATION

Active - Oil

5370

5370

3536

4250132065

ROBERTS UNIT

2703

APACHE CORPORATION

Active - Oil

5370

5370

2703

4250100755

CORNELL UNIT

3101W

XTO ENERGY INC.

Active - Injection/Disposal from Oil

5373

5373

3101W

4250135703

ROBERTS UNIT

3668

APACHE CORPORATION

Active - Oil

5380

5380

3668

4250135229

DENVER UNIT

2240

OCCIDENTAL PERMIAN LTD.

Active - Oil

5388

5388

2240

4250136152

ROBERTS UNIT

3682W

APACHE CORPORATION

Active - Injection/Disposal

5397

5397

3682W

4250131539

DENVER UNIT

2230

SHELL OIL COMPANY

Canceled/Abandoned Location

5400

5400

2230

4250136327

ROBERTS UNIT

4547

APACHE CORPORATION

Active - Oil

5400

5400

4547

4250136154

ROBERTS UNIT

3624RW

APACHE CORPORATION

Active - Injection/Disposal

5400

5400

3624RW

4250136155

ROBERTS UNIT

3683W

APACHE CORPORATION

Active - Injection/Disposal

5402

5402

3683W

4250136156

ROBERTS UNIT

3686

APACHE CORPORATION

Active - Oil

5404

5404

3686

4250134797

CORNELL UNIT

3194

XTO ENERGY INC.

Active - Oil

5405

5405

3194

4250135696

CORNELL UNIT

113

XTO ENERGY INC.

Active - Oil

5406

5406

113

4250136150

ROBERTS UNIT

3684

APACHE CORPORATION

Active - Oil

5421

5421

3684

4250133629

CORNELL UNIT

3156

XTO ENERGY INC.

Active - Oil

5425

5425

3156

4250135961

DENVER UNIT

2246

OCCIDENTAL PERMIAN LTD.

Active - Oil

5425

5425

2246

4250135960

DENVER UNIT

2249

OCCIDENTAL PERMIAN LTD.

Active - Oil

5431

5431

2249

4250136153

ROBERTS UNIT

3623RW

APACHE CORPORATION

Active - Injection/Disposal

5439

5439

3623RW

4250135353

CORNELL UNIT

107

XTO ENERGY INC.

Active - Oil

5450

5450

107

4250135528

ROBERTS UNIT

3549

APACHE CORPORATION

Active - Oil

5452

5452

3549

4250136151

ROBERTS UNIT

3685

APACHE CORPORATION

Active - Oil

5463

5463

3685

4250135963

DENVER UNIT

2252

OCCIDENTAL PERMIAN LTD.

Active - Oil

5476

5476

2252

4250136434

ROBERTS UNIT

263H

APACHE CORPORATION

Expired Permit

5500

5500

263H

4250136433

ROBERTS UNIT

262H

APACHE CORPORATION

Expired Permit

5500

5500

262H

4250136098

CORNELL UNIT

110

XTO ENERGY INC.

Active - Injection/Disposal

5510

5510

110

4250133615

ROBERTS UNIT

2442A

APACHE CORPORATION

TA - Injection/Disposal

5516

5516

2442A

4250135180

ROBERTS UNIT

3534B

APACHE CORPORATION

Active - Injection/Disposal

5517

5517

3534B

4250136428

CORNELL UNIT

124

XTO ENERGY INC.

Active - Oil

5532

5532

124

4250134878

ROBERTS UNIT

3548

APACHE CORPORATION

Active - Oil

5550

5550

3548

4250135966

DENVER UNIT

2251

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2251

4250135962

DENVER UNIT

2250

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2250

4250135356

DENVER UNIT

2246

OCCIDENTAL PERMIAN LTD.

Expired Permit

5600

5600

2246

4250135959

DENVER UNIT

2248

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2248


-------
Rattlesnake AGI No. 1
Oil and Gas Wells within MMA

API

WELL NAME

WELL NO

OPERATOR

RRCStatus

TVD

TD

welINo

4250135210

DENVER UNIT

2240

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2240

4250135211



2241

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2241

4250134710



2240

OCCIDENTAL PERMIAN LTD.

Active - Oil

5600

5600

2240

4250101845

ROBERTS UNIT

3613

APACHE CORPORATION

Active - Oil

7000

7000

3613

4250110083

RANDALL, E.

36

EXXON CORP.

Plugged - Oil

8595

8595

36

4250110046

ELLIOTT, C.A.

2

MCCLURE OIL COMPANY, INC.

Plugged - Oil

9000

9000

2

4250136692

MISS KITTY 704-669

3XH

RILEY EXPLORATION OPG CO, LLC

Expired Permit

9000

9000

3XH

4250133793

RANDALL, E.

39

XTO ENERGY INC.

Active - Oil

9000

9000

39

4250137375

RIP WHEELER 705-668

5XH

RILEY PERMIAN OPERATING CO, LLC

Permitted Location

9000

9000

5XH

4250137358

RIP WHEELER 705-668

1XH

RILEY PERMIAN OPERATING CO, LLC

Permitted Location

9000

9000

1XH

4250133843

ELLIOTT

1

DELTA C02, LLC

Plugged - Oil

9050

9050

1

4250134124

RANDALL, E

46

EXXON CORP.

Canceled/Abandoned Location

9100

9100

46

4250133792

RANDALL, E.

40

XTO ENERGY INC.

Plugged - Oil

9591

9591

40

4250110079

RANDALL, E.

32

EXXON CORP.

Plugged - Oil

9615

9615

32

4250135418

RANDALL, E.

46

XTO ENERGY INC.

Active - Oil

9650

9650

46

4250134023

RANDALL, E.

42

XTO ENERGY INC.

Active - Oil

9660

9660

42

4250134016

RANDALL, E.

43

XTO ENERGY INC.

Active - Oil

9740

9740

43

4250132388

RANDALL, E.

38

EXXON CORP.

Canceled/Abandoned Location

10300

10300

38

4250137302

MILLER 732 B

9H

AMTEX ENERGY, INC.

Active - Oil

5183

10662

9H

4250136432

ROBERTS UNIT

261 H

APACHE CORPORATION

Active - Oil

5151

11117

261 H

4250136998

RATTLESNAKE AGI

1

SANTA FE MIDSTREAM PERMIAN LLC

Active - Injection/Disposal

11980

11980

1

4250137252

MILLER SWD

7

AMTEX ENERGY, INC.

Permitted Location

13000

13000

7

4250136984

MADCAP 731-706

1XH

RILEY PERMIAN OPERATING CO, LLC

Active - Oil

5261

13274

1XH

4250137127

MISS KITTY A 669-704

25XH

RILEY PERMIAN OPERATING CO, LLC

Active - Oil

5321

13428

25XH

4250137287

MISS KITTY A 669-704

4XH

RILEY PERMIAN OPERATING CO, LLC

Shut-In - Oil

5340

13452

4XH

4250137236

MISS KITTY 669-704

2XH

RILEY PERMIAN OPERATING CO, LLC

Active - Oil

5317

13622

2XH


-------
A-1143

Rattlesnake AGI No. 1
Maximum Monitoring Area
with

1/2-Mile MMA Oil/Gas Well Penetrators
Area of Review

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 6/1/2022

Approved by: RH

LONQUIST & CO. LLC



PETROLEUM

ENERGY





ENGINEERS

ADVISORS

1

AUSTIN • HOUSTON jj

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

E-5

+ Rattlesnake AGI No. 1 SHL

I	'

I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

Stabilized Plume

J Plume Boundary at End of Injection

Abstract

API (42-501-...) SHL Status - Type (Count)

• Active - Oil (4)

Active - Injection/Disposal (1)

Plugged - Oil (4)

® Permitted Location (1)

Sou rce:

1.)	Oil/Gas Well SHL Data: DI-2022

2.)	Oil/Gas Well BHL Data: DI-2022

3.)	Oil/Gas Well Directional Data: DI-2022

* Note: All coordinates shown are in NAD83 (DD).

1560


-------
A-1143

Rattlesnake AGI No. 1
Maximum Monitoring Area
with

1/2-Mile MMA Groundwater Well
Area of Review

Stakeholder Midstream
Yoakum Co., TX

PCS: NAD83 TX-NC FIPS 4202 (US Ft.)

Drawn by: ER

Date: 5/31/2022

Approved by: RH

LONQUIST & CO LLC



PETROLEUM

ENERGY

E-6



ENGINEERS

ADVISORS

| AUSTIN • HOUSTON J

I CALGARY-WICHITA

DENVER

• COLLEGE STATION 1

[ BATON ROUGE • EDMONTON

+ Rattlesnake AGI No. 1 SHL

|	I 1/2-Mile Buffer from Max. Plume Extent (MMA)

Combined Maximum Plume Extent

Stabilized Plume

J Plume Boundary at End of Injection

Abstract

SDRDB Groundwater Wells [TWDB-2022]

Proposed Use (Labeled with Well Report No.)
A Industrial (1)

Irrigation (5)

TWDB Groundwater Wells [TWDB-2022]

Well Type (Labeled with State Well No.)
¦ Withdrawal of Water (1)

Sou rce:

1.)	SDRDB Groundwater Well SHL Data: TWDB-2022

2.)	TWDB Groundwater Well SHL Data: TWDB-2022

3.)	Brackish Groundwater Well SHL Data: TWDB-2022
* Note: All coordinates shown are in NAD83 (DD). *

1560


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Cement Plug #9
@7'-1,013'

Cement Plug #8
@ 1,730'- 1,800'

Cement Plug #7
@ 2,031' - 2,100

Cement Plug #6
@2,430'-2,500'

Cement Plug #5
@2,660'-2,719'

Cement Plug #4
@2,790'-2,860'

Cement Plug #3
@3,172'-3,239'

Cement Plug #2
@3,765'-3,831'

Cement Plug #1
@ 3,900'-3,960'

Perfs @ 8,231
8,396', 8,420'
8,447', 8,462'

Casing Information

Label

1

2

Type

Surface

Production

OD

8-5/8"

4-1/2"

Depth Set

2,134'

9,601'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-10079

RRC District No: 8-A

Drawn: KAS

E. Randall No. 32 e-7A

State/Province: Texas

Spud Date: 05/10/1965

Field: Wasson (Wichita Albany)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 18231

Date: 05/31/2022

Approved: SLP


-------
Cement Plug #5
@ 0' - 458'

Cement Plug #4
@2,070'-2,295'

Cement Plug #3
@2,780'- 3,009'

Cement Plug #2
@4,450'-4,870'

Cement Plug #1
@5,184'-5,266'

Perfs@ 9,496'-9,516'

TD@ 9,591'
PBTD @ 9,560'



DV Tool ® 4,522'

DV Tool @ 5,676'

Casing Information

Label

1

3

Type

Surface

Production

OD

9-5/8"

5-1/2"

Weight

36 lb/ft

UNK

Depth Set

2,162'

9,569'

Hole Size

12-1/4"

7-7/8"

TOC

Surface

2,350'

Volume

880 sks

5,450 sks

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

XTO Energy Inc.

Country: USA

Location: Section 833, Block D

API No: 42-501-337932

RRC District No: 8-A

Drawn: KAS

E. Randall No. 40

State/Province: Texas

Spud Date: 12/04/1992

Field: Wasson (Wichita Albany)

Project No: LS 128

Reviewed: RKH

Notes:

E-7B

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—





A

Perfs (5) 9,536' - 9,540'

SI

[S

: . I





DV Tool @ 5,968'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54 lb/ft

36 lb/ft
40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,129'

5,606'

9,699'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

Surface

Volume

1,790 sks

2,910 sks

1,590 sks

2-3/8" Tubing & Packer Set @ 9,331'

TD @ 9,700'
PBTD @ 9,654'

MD

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN • HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 832, Block D

API No: 42-501-33885

RRC District No: 8-A

Drawn: KAS

E. Randall No. 41L E-7C

State/Province: Texas

Spud Date: 02/05/1994

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Perfs (5) 9,533' - 9,553'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,167'

5,830'

9,658'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

440'

1,800'

Volume

1,530 sks

3,500 sks

1,050 sks

DV Tool ® 7,414'

2-3/8" Tubing & Packer Set @ 8,970'

TD @ 9,660' \-(3)
PBTD @ 9,623' W

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-34023

RRC District No: 8-A

Drawn: KAS

E. Randall No. 42L

E-7D

State/Province: Texas

Spud Date: 07/01/1995

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—



Li;.

Perfs @ 9,550' - 9,538'
9,603'-9,610'

sf.

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CIBP ® 8,917'

CIBP @ 9,590'

TD @ 9,740'
PBTD @ 8,917'

rv@

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,166'

5,902'

9,735'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

2,000'

Volume

1,530 sks

3,505 sks

967 sks

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 832, Block D

API No: 42-501-34016

RRC District No: 8-A

Drawn: KAS

E. Randall No. 43L E-7E

State/Province: Texas

Spud Date: 04/08/1995

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Perfs @ 8,762' - 8,782'

(Sqz w/100 sx)

Perfs @8,822'-8,831'

(Sqz w/ 75 sx)

Perfs @ 9,562' - 9,570'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft
29 lb/ft

Depth Set

2,158'

5,904'

9,620'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

1,600'

Volume

1,450 sks

5,190 sks

1,100 sks

DV Tool ® 7,482'

2-3/8" Tubing & Packer Set @ 9,552'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-34024

RRC District No: 8-A

Drawn: KAS

E. Randall No. 44 E_7F

State/Province: Texas

Spud Date: 08/09/1995

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

Perfs (5) 9,565' - 9,575'

Casing/Tubing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

7"

Weight

54.5 lb/ft

40 lb/ft

23 lb/ft
26 lb/ft

Depth Set

2,175'

5,898'

9,615'

Hole Size

17-1/2"

12-1/4"

8-3/4"

TOC

Surface

Surface

1,500'

Volume

1,530 sks

3,525 sks

1,170 sks

DV Tool ® 7,508'

2-3/8" Tubing Set @ 9,580'

Packer Set (5) 9,394'

TD @ 9,684'

PBTD @ 9,593'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Exxon Corp.

Country: USA

Location: Section 833, Block D

API No: 42-501-34017

RRC District No: 8-A

Drawn: KAS

E. Randall No. 45L E-7G

State/Province: Texas

Spud Date: 02/05/1994

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
Perfs (5) 9,504' - 9,512'

TD @ 9,650'
PBTD @ 9,594'

Casing/Tubing
Information

Label

1

2

Type

Surface

Production

OD

8-5/8"

5-1/2"

Weight

24 lb/ft

17 lb/ft

Depth Set

2,120'

9,650'

Hole Size

11"

7-7/8"

TOC

Surface

Surface

Volume

900 sks

3,400 sks

DV Tool ® 8,656' & 8,674'

2-7/8" Tubing & Packer Set @ 9,184'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

XTO Energy, Inc.

Country: USA

Location: Section 833, Block D

API No: 42-501-35418

RRC District No: 8-A

Drawn: KAS

E. Randall No. 46 e-7H

State/Province: Texas

Spud Date: 05/23/2007

Field: Bruce (Silurian)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 66970

Date: 05/31/2022

Approved: SLP


-------
u

Cement Plug #4
@48'-60'

Cement Plug #3
@ 270' - 450'

Cement Plug #1
@7,549'-8,000'

Perfs @ 8,292' - 8,428'

Cement Plug #2
@3,273'-3,439'

Top of Cut @ 750'
Top of Cut @ 1,439'

TD ® 9,645'

v@

Casing Information

Label

1

2

3

Type

Surface

Intermediate

Production

OD

13-3/8"

9-5/8"

5-1/2"

Depth Set

300'

3,200'

9,610'

TOC

Surface

Surface

Surface

Volume

400 sks

300 sks

425 sks

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Bonanza Oil Corp.

Country: USA

Location: Section 832, Block D

API No: 42-501-10046

RRC District No: 8-A

Drawn: KAS

C.A. Elliott No. 2 E-7I

State/Province: Texas

Spud Date: 05/10/1965

Field: Wasson (Wichita Albany)

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

RRC Lease Number: 18875

Date: 05/31/2022

Approved: SLP


-------
2,000'D—
2,500'D—
3,000'D—
3,500'D—

5,500'D—
6,000'D—
6,500'D—
7,000'D—
7,500'D—
8,000'D—
8,500'D—
9,000'D—

11,000'D—
11,500'D—
12,000'D—
12,500'D—

w

if.

II

: . I

Casing/Tubing Information

I ahol I 1 I 0 I ^

Surface



3-1/2" Tubing & Packer Set @ 10,650'

MD

TD @ 13,000'

LONQUIST & CO. LLC

PETROLEUM

ENERGY

ENGINEERS

ADVISORS

AUSTIN - HOUSTON 1 CALGARY - WICHITA
DENVER • COLLEGE STATION | BATON ROUGE • EDMONTON

Texas License F-9147

12912 Hill Country Blvd. Ste F-200
Austin, Texas 78738
Tel: 512.732.9812
Fax: 512.732.9816

Amtex Energy, Inc.

Country: USA

Location: Section 732, Block D

API No: 42-501-37252

RRC District No: 7-C

Drawn: KAS

Miller SWD No. 7 (Permitted) E-7J

State/Province: Texas

Spud Date: 08/09/1995

Field: Wasson

Project No: LS 128

Reviewed: RKH

Notes:

County/Parish: Yoakum

Survey: John H. Gipson

Permit Number: 16637

Date: 05/31/2022

Approved: SLP


-------