AMAROQ RESOURCES, LLC — Notice of Amendment

520190011M_Notice of Amendment_02252019_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED February 25, 2019 Mr. Scott Pfoff President and CEO Aurora Exploration LLC 4645 Sweetwater Blvd., Suite 200 Sugarland, Texas 77479 CPF 5-2019-0011M Dear Mr. Pfoff: On August 20 through 22, 2018, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Aurora Exploration LLC’s (Aurora) procedures for Operations and Maintenance and Emergency Response in Anchorage, Alaska. On the basis of the inspection, PHMSA identified the apparent inadequacies within Aurora’s plans or procedures, as described below: 1. § 192.615 Emergency plans. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following: (1) Receiving, identifying, and classifying notices of events which require immediate response by the operator.#

520190011M_Notice of Amendment_02252019_text.pdf, page 2The Operator’s Emergency Response Plan (AG-71-EP-REV1, "ERP”) lacks an adequate process for receiving, identifying, and classifying notices. The ERP designates who will receive, identify, and classify notices of events which require immediate response by Aurora. It states that the first notification of events which need immediate response is “typically the on-duty Production Supervisor with the Manager of Production Operations and Engineering as the secondary contact”. However, based on conversations with the operator, these positions no longer exist within Aurora. The operator failed to update the ERP with the current position(s)for receiving, identifying, and classifying notices of event which require immediate response by the operator. The procedure cannot be implemented as written in the ERP. 2. § 192.615 Emergency plans. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following: (1) …. (4) The availability of personnel, equipment, tools, and materials, as needed at the scene of an emergency. The operator's Emergency Response Plans (AG-71-EP-REV1, "ERP") lacks an inventory or fails to otherwise identify what equipment, tools, and materials would be needed at the scene of an emergency. The ERP states that "[t]he ERP will present an overview of the personnel and equipment typically available for immediate callout in the event or (sic) an emergency. This will include company personnel and equipment, as well as other service providers and contractors active in the area of operations." However, the ERP does not present an overview of personnel and equipment available for callout. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). 2#

520190011M_Notice of Amendment_02252019_text.pdf, page 3Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 60 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Aurora maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Acting Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2019-0011M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Chris Hoidal Acting Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings cc: George Pollock, Senior Operations Consultant, gpollock@aurorapower.com PHP-60 Compliance Registry PHP-500 J. Gano (#160487) 3#

520190011M_Closure Letter_03132020_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED March 13, 2020 Mr. G. Scott Pfoff President Amaroq Resources, LLC 4665 Sweetwater Blvd., Suite 103 Sugar Land, TX 77479 CPF 5-2019-0011M Closure Letter Dear Mr. Pfoff: On August 20 through 22, 2018, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Aurora Exploration, LLC’s procedures in Anchorage, Alaska. As a result of the inspection, Aurora Exploration, LLC was issued a Notice of Amendment (NOA) on February 25, 2019, which proposed amendment of your procedures. Amaroq Resources LLC 1 did not submit amended procedures to PHMSA within 60 days of the receipt of the NOA and was issued an Order Directing Amendment on January 7, 2020. Amaroq Resources, LLC submitted its amended procedures on February 18, 2020. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in the NOA and Order Directing Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Dustin Hubbard Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 Jake Gano (#160487) 1 Amaroq Resources, LLC (formerly Aurora Exploration, LLC) acquired the Nicolai Creek Pipeline system on the west side of Cook Inlet, Alaska along with the producing assets of the Nicolai Creek Gas Field out of the bankruptcy proceedings of Aurora Gas, LLC#

520190011M_Order Directing Amendment_01072020_text.pdf, page 1Official PDFJanuary 7, 2020 Mr. G. Scott Pfoff President and Chief Executive Officer Amaroq Resources, LLC 4665 Sweetwater Boulevard, Suite 103 Sugar Land, Texas 77479 Re: CPF No. 5-2019-0011M Dear Mr. Pfoff: Enclosed please find the Order Directing Amendment issued in the above-referenced case. It makes findings of inadequate procedures and requires Amaroq Resources, LLC (formerly Aurora Exploration, LLC), amend certain emergency procedures. When the amendment of procedures is complete, as determined by the Director, Western Region, this enforcement action will be closed. Service of the Order Directing Amendment by certified mail is effective upon the date of mailing as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure cc: Mr. Dustin Hubbard, Director, Western Region, Office of Pipeline Safety, PHMSA CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

520190011M_Order Directing Amendment_01072020_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ In the Matter of ) Amaroq Resources, LLC, ) CPF No. 5-2019-0011M ) ) ) Respondent. ) ____________________________________) ORDER DIRECTING AMENDMENT From August 20, 2018 through August 22, 2018, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of Amaroq Resources, LLC’s (Amaroq or Respondent),1 plans and procedures in Anchorage, Alaska. As a result of the inspection, the Director, Western Region, OPS (Director), issued to Respondent, by letter dated February 25, 2019, a Notice of Amendment (NOA). In accordance with 49 C.F.R. § 190.206, the NOA alleged certain inadequacies in Respondent’s emergency procedures and proposed requiring Amaroq to amend its procedures to comply with 49 C.F.R. § 192.615. Respondent failed to respond within 30 days of receipt of service of the NOA. Eventually, Respondent responded on August 12, 2019, well after the 30 day deadline. In its response, Amaroq did not contest the proposed NOA and further indicated that it would take measures to correct the identified inadequacies. However, to date, Amaroq has yet to provide OPS with amended procedures. Such failure to submit a timely response constitutes a waiver of Amaroq’s right to contest the alleged inadequacies in the NOA and authorizes the Associate Administrator, without further notice, to find facts as alleged in the NOA and to issue this Order Directing Amendment. Accordingly, I find that Amaroq’s procedures are inadequate to ensure safe operation of its pipeline system. Pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206, Amaroq is ordered to make the following revisions to its procedures. Respondent must: 1 Prior to the OPS inspection, Aurora Exploration, LLC changed its name to Amaroq Resources, LLC in April 2018. While the Notice of Amendment used the operator’s prior legal name, the legal entity and owner of the pipeline remains the same.#

520190011M_Order Directing Amendment_01072020_text.pdf, page 3CPF 5-2019-0011M Page 2 1. Amend and update its Emergency Response Plan to include the current positions who receive, identify, and classify notices of events which require immediate response by the operator, as required by § 192.615. 2. Amend its Emergency Response Plan to provide an overview of personnel and equipment available for an immediate callout in the event of an emergency. 3. Submit the amended procedures to the Director within 60 days following receipt of this Order Directing Amendment. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. Failure to comply with this Order may result in administrative assessment of civil penalties not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Order Directing Amendment to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of this Order Directing Amendment by Respondent. Any petition submitted must contain a statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The terms of the order, including corrective action, remain in effect unless the Associate Administrator, upon request, grants a stay. The terms and conditions of this Order Directing Amendment are effective upon service in accordance with 49 C.F.R. § 190.5. January 7, 2020 ___________________________________ ______________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#