Permit Issued Spudded Well Producing Well Violations
PermitsViolationsWasteProductionSpud
1. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
FISK HOLLOW 2454
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
May 5th, 2010
Horizontal:
Yes
County:
Potter
Municipality:
Clara Twp
There are no violations for this site.
Waste Type
Quantity
Disposal Method
DRILL CUTTINGS
1231.28 Tons
LANDFILL
DRILLING
2790.83 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FLOW-BACK FRACT
12.47 Tons
LANDFILL
BRINE
21720.20 Bbl
INJECTION DISPOSAL WELL
PRODUCED FLUID
7475.83 Bbl
INJECTION DISPOSAL WELL
Site:
FISK HOLLOW 2454
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
539,588.00
0.00
0.00
This well was drilled on Aug 9th, 2010
PermitsViolationsWasteProductionSpud
2. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
FISK HOLLOW 2453
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
May 5th, 2010
Horizontal:
Yes
County:
Potter
Municipality:
Clara Twp
There are no violations for this site.
Waste Type
Quantity
Disposal Method
DRILL CUTTINGS
917.08 Tons
LANDFILL
DRILLING
2790.83 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FLOW-BACK FRACT
12.47 Tons
LANDFILL
BRINE
21720.20 Bbl
INJECTION DISPOSAL WELL
PRODUCED FLUID
7475.83 Bbl
INJECTION DISPOSAL WELL
Site:
FISK HOLLOW 2453
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
571,796.00
0.00
0.00
This well was drilled on Aug 16th, 2010
PermitsViolationsWasteProductionSpud
3. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
FISK HOLLOW 2456
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
May 5th, 2010
Horizontal:
Yes
County:
Potter
Municipality:
Clara Twp
Nov 30th, 2010: Code: 402CSL - Failure to adopt pollution prevention measures required or prescribed by DEP by handling materials that create a danger of pollution.
Nov 30th, 2010: Code: SWMA301 - Failure to properly store, transport, process or dispose of a residual waste.
Jan 27th, 2011: Code: 78.86 - Failure to report defective, insufficient, or improperly cemented casing w/in 24 hrs or submit plan to correct w/in 30 days
Waste Type
Quantity
Disposal Method
DRILL CUTTINGS
2011.11 Tons
LANDFILL
DRILLING
3186.83 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FLOW-BACK FRACT
83.29 Tons
LANDFILL
BRINE
21720.20 Bbl
INJECTION DISPOSAL WELL
PRODUCED FLUID
7475.83 Bbl
INJECTION DISPOSAL WELL
Site:
FISK HOLLOW 2456
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
484,919.00
0.00
0.00
This well was drilled on Jul 24th, 2010
PermitsViolationsWasteProductionSpud
4. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
FISK HOLLOW 2452
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
May 4th, 2010
Horizontal:
Yes
County:
Potter
Municipality:
Clara Twp
Nov 8th, 2011: Code: 402CSL - Failure to adopt pollution prevention measures required or prescribed by DEP by handling materials that create a danger of pollution.
Nov 8th, 2011: Code: 78.57 - Failure to post pit approval number
Nov 8th, 2011: Code: SWMA301 - Failure to properly store, transport, process or dispose of a residual waste.
Waste Type
Quantity
Disposal Method
DRILL CUTTINGS
1180.42 Tons
LANDFILL
DRILLING
2790.83 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FLOW-BACK FRACT
12.47 Tons
LANDFILL
BRINE
21720.20 Bbl
INJECTION DISPOSAL WELL
PRODUCED FLUID
7475.83 Bbl
INJECTION DISPOSAL WELL
Site:
FISK HOLLOW 2452
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
218,933.00
0.00
0.00
This well was drilled on Aug 30th, 2010
PermitsViolationsWasteProductionSpud
5. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
FISK HOLLOW 2457
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
May 5th, 2010
Horizontal:
Yes
County:
Potter
Municipality:
Clara Twp
There are no violations for this site.
Waste Type
Quantity
Disposal Method
DRILL CUTTINGS
1937.67 Tons
LANDFILL
DRILLING
1626.00 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
BRINE
21720.20 Bbl
INJECTION DISPOSAL WELL
PRODUCED FLUID
7475.83 Bbl
INJECTION DISPOSAL WELL
Site:
FISK HOLLOW 2457
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
153,565.00
0.00
0.00
This well was drilled on Aug 1st, 2010
PermitsViolationsWasteProductionSpud
6. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
FISK HOLLOW 1944
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Jan 3rd, 2007
Horizontal:
No
County:
Potter
Municipality:
Clara Twp
There are no violations for this site.
Waste Type
Quantity
Disposal Method
BRINE
9548.14 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FRACKING FLUID
3504.00 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
Site:
FISK HOLLOW 1944
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
41,620.00
0.00
0.00
This well was drilled on Mar 30th, 2007
PermitsViolationsWasteProductionSpud
7. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
FISK HOLLOW 2455
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
May 5th, 2010
Horizontal:
Yes
County:
Potter
Municipality:
Clara Twp
There are no violations for this site.
Waste Type
Quantity
Disposal Method
DRILL CUTTINGS
2331.59 Tons
LANDFILL
DRILLING
3186.83 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FLOW-BACK FRACT
83.29 Tons
LANDFILL
BRINE
21720.20 Bbl
INJECTION DISPOSAL WELL
PRODUCED FLUID
7475.83 Bbl
INJECTION DISPOSAL WELL
Site:
FISK HOLLOW 2455
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
630,794.00
0.00
0.00
This well was drilled on Aug 24th, 2010
PermitsViolationsWasteProductionSpud
8. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
C O P TRACT 293 PAD A 2403
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Sep 24th, 2009
Horizontal:
Yes
County:
Lycoming
Municipality:
Cummings Twp
There are no violations for this site.
Waste Type
Quantity
Disposal Method
DRILL CUTTINGS
1539.07 Tons
LANDFILL
DRILLING
1406.60 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FLOW-BACK FRACT
19.72 Tons
TREATED ON-SITE, NPDES DISCHARGE
FLOW-BACK FLUID
1890.74 Bbl
CENTRALIZED TREATMENT PLANT FOR RECYCLE
PRODUCED FLUID
12996.77 Bbl
INJECTION DISPOSAL WELL
Site:
C O P TRACT 293 PAD A 2403
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
944,734.00
0.00
0.00
This well was drilled on May 17th, 2011
PermitsViolationsWasteProductionSpud
9. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
C O P TRACT 293 PAD A 2406
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Sep 24th, 2009
Horizontal:
Yes
County:
Lycoming
Municipality:
Cummings Twp
There are no violations for this site.
Waste Type
Quantity
Disposal Method
DRILL CUTTINGS
1781.12 Tons
LANDFILL
DRILLING
1406.60 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
Site:
C O P TRACT 293 PAD A 2406
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
0.00
0.00
0.00
This well was drilled on May 16th, 2011
PermitsViolationsWasteProductionSpud
10. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
TRACT 293 2400
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Sep 2nd, 2009
Horizontal:
No
County:
Lycoming
Municipality:
Cummings Twp
There are no violations for this site.
Waste Type
Quantity
Disposal Method
FRAC FLUID
11721.81 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
DRILLING
1348.37 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
Site:
TRACT 293 2400
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
863.00
0.00
0.00
This well was drilled on Nov 11th, 2009
PermitsViolationsWasteProductionSpud
11. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
C O P TRACT 729 PAD A 2410
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Oct 2nd, 2009
Horizontal:
Yes
County:
Lycoming
Municipality:
Cummings Twp
Mar 15th, 2010: Code: 401CSL - Discharge of pollultional material to waters of Commonwealth.
Mar 15th, 2010: Code: 691.1 - Clean Streams Law-General. Used only when a specific CLS code cannot be used
Mar 15th, 2010: Code: 601.101 - O&G Act 223-General. Used only when a specific O&G Act code cannot be used
Sep 20th, 2010: Code: 78.56(2) - Failure to maintain 2 ' of freeboard in an impoundment.
Waste Type
Quantity
Disposal Method
DRILLING
13800.95 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
BRINE
11109.92 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
DRILL CUTTINGS
8952.03 Tons
LANDFILL
FRAC FLUID
5876.81 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FLOW-BACK FRACT
4.22 Tons
LANDFILL
PRODUCED FLUID
1909.43 Bbl
REUSE OTHER THAN ROAD SPREADING
Site:
C O P TRACT 729 PAD A 2410
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
2,198,126.00
0.00
0.00
This well was drilled on Feb 17th, 2010
PermitsViolationsWasteProductionSpud
12. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
C O P TRACT 293 PAD A 2405
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Sep 24th, 2009
Horizontal:
Yes
County:
Lycoming
Municipality:
Cummings Twp
There are no violations for this site.
Waste Type
Quantity
Disposal Method
DRILL CUTTINGS
1809.15 Tons
LANDFILL
DRILLING
1406.60 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FLOW-BACK FRACT
19.69 Tons
TREATED ON-SITE, NPDES DISCHARGE
FLOW-BACK FLUID
1890.74 Bbl
CENTRALIZED TREATMENT PLANT FOR RECYCLE
PRODUCED FLUID
12996.77 Bbl
INJECTION DISPOSAL WELL
Site:
C O P TRACT 293 PAD A 2405
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
713,929.00
0.00
0.00
This well was drilled on May 18th, 2011
PermitsViolationsWasteProductionSpud
13. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
C O P TRACT 729 PAD A 2409
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Oct 2nd, 2009
Horizontal:
Yes
County:
Lycoming
Municipality:
Cummings Twp
Mar 15th, 2010: Code: 401CSL - Discharge of pollultional material to waters of Commonwealth.
Mar 15th, 2010: Code: 691.1 - Clean Streams Law-General. Used only when a specific CLS code cannot be used
Mar 15th, 2010: Code: 601.101 - O&G Act 223-General. Used only when a specific O&G Act code cannot be used
Waste Type
Quantity
Disposal Method
DRILLING
2127.57 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
DRILLING FLUID
1211.71 Bbl
CENTRALIZED TREATMENT PLANT FOR RECYCLE
DRILL CUTTINGS
1436.07 Tons
LANDFILL
Site:
C O P TRACT 729 PAD A 2409
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
330,425.00
0.00
0.00
This well was drilled on Feb 17th, 2010
PermitsViolationsWasteProductionSpud
14. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
C O P TRACT 729 PAD A 2407
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Oct 2nd, 2009
Horizontal:
Yes
County:
Lycoming
Municipality:
Cummings Twp
Mar 15th, 2010: Code: 401CSL - Discharge of pollultional material to waters of Commonwealth.
Mar 15th, 2010: Code: 691.1 - Clean Streams Law-General. Used only when a specific CLS code cannot be used
Mar 15th, 2010: Code: 601.101 - O&G Act 223-General. Used only when a specific O&G Act code cannot be used
Waste Type
Quantity
Disposal Method
DRILLING
3971.57 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
DRILL CUTTINGS
1362.54 Tons
OTHER
FLOW-BACK FRACT
19.48 Tons
LANDFILL
BRINE
10847.92 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FLOW-BACK FLUID
839.20 Bbl
REUSE OTHER THAN ROAD SPREADING
PRODUCED FLUID
1909.43 Bbl
REUSE OTHER THAN ROAD SPREADING
Site:
C O P TRACT 729 PAD A 2407
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
1,300,680.00
0.00
0.00
This well was drilled on Jan 20th, 2010
PermitsViolationsWasteProductionSpud
15. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
C O P TRACT 293 PAD A 2401
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Sep 24th, 2009
Horizontal:
Yes
County:
Lycoming
Municipality:
Cummings Twp
Aug 29th, 2011: Code: 91.33A - Failure to notify DEP of pollution incident. No phone call made forthwith
Aug 29th, 2011: Code: 691.1 - Clean Streams Law-General. Used only when a specific CLS code cannot be used
Aug 29th, 2011: Code: SWMA301 - Failure to properly store, transport, process or dispose of a residual waste.
Waste Type
Quantity
Disposal Method
DRILLING
4436.23 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
DRILL CUTTINGS
15.50 Tons
LANDFILL
PRODUCED FLUID
12996.77 Bbl
INJECTION DISPOSAL WELL
Site:
C O P TRACT 293 PAD A 2401
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
747,308.00
0.00
0.00
This well was drilled on Oct 29th, 2009
PermitsViolationsWasteProductionSpud
16. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
C O P TRACT 729 PAD A 2386
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Oct 2nd, 2009
Horizontal:
Yes
County:
Lycoming
Municipality:
Cummings Twp
Mar 15th, 2010: Code: 401CSL - Discharge of pollultional material to waters of Commonwealth.
Mar 15th, 2010: Code: 691.1 - Clean Streams Law-General. Used only when a specific CLS code cannot be used
Mar 15th, 2010: Code: 601.101 - O&G Act 223-General. Used only when a specific O&G Act code cannot be used
Waste Type
Quantity
Disposal Method
DRILLING
4708.00 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
DRILL CUTTINGS
3200.26 Tons
LANDFILL
FLOW-BACK FRACT
6.58 Tons
LANDFILL
BRINE
10847.92 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
PRODUCED FLUID
1909.43 Bbl
REUSE OTHER THAN ROAD SPREADING
Site:
C O P TRACT 729 PAD A 2386
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
1,635,310.00
0.00
0.00
This well was drilled on Feb 17th, 2010
PermitsViolationsWasteProductionSpud
17. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
C O P TRACT 729 PAD A 2387
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Oct 2nd, 2009
Horizontal:
Yes
County:
Lycoming
Municipality:
Cummings Twp
Mar 15th, 2010: Code: 401CSL - Discharge of pollultional material to waters of Commonwealth.
Mar 15th, 2010: Code: 691.1 - Clean Streams Law-General. Used only when a specific CLS code cannot be used
Mar 15th, 2010: Code: 601.101 - O&G Act 223-General. Used only when a specific O&G Act code cannot be used
Waste Type
Quantity
Disposal Method
DRILLING
4894.00 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
DRILL CUTTINGS
3868.30 Tons
LANDFILL
BRINE
10847.92 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FLOW-BACK FRACT
4.19 Tons
LANDFILL
PRODUCED FLUID
1909.43 Bbl
REUSE OTHER THAN ROAD SPREADING
Site:
C O P TRACT 729 PAD A 2387
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
2,297,464.00
0.00
0.00
This well was drilled on Jan 28th, 2010
PermitsViolationsWasteProductionSpud
18. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
C O P TRACT 293 PAD A 2404
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Sep 24th, 2009
Horizontal:
Yes
County:
Lycoming
Municipality:
Cummings Twp
There are no violations for this site.
Waste Type
Quantity
Disposal Method
DRILL CUTTINGS
846.08 Tons
LANDFILL
DRILLING
1406.60 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FLOW-BACK FRACT
19.71 Tons
TREATED ON-SITE, NPDES DISCHARGE
FLOW-BACK FLUID
1890.74 Bbl
CENTRALIZED TREATMENT PLANT FOR RECYCLE
PRODUCED FLUID
12996.77 Bbl
INJECTION DISPOSAL WELL
Site:
C O P TRACT 293 PAD A 2404
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
585,357.00
0.00
0.00
This well was drilled on May 15th, 2011
PermitsViolationsWasteProductionSpud
19. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
C O P TRACT 729 PAD A 2408
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Oct 2nd, 2009
Horizontal:
Yes
County:
Lycoming
Municipality:
Cummings Twp
Mar 15th, 2010: Code: 401CSL - Discharge of pollultional material to waters of Commonwealth.
Mar 15th, 2010: Code: 691.1 - Clean Streams Law-General. Used only when a specific CLS code cannot be used
Mar 15th, 2010: Code: 601.101 - O&G Act 223-General. Used only when a specific O&G Act code cannot be used
Waste Type
Quantity
Disposal Method
DRILLING
4441.57 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FRAC FLUID
8645.81 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
BRINE
10847.92 Bbl
BRINE OR INDUSTRIAL WASTE TREATMENT PLT
FLOW-BACK FRACT
4.20 Tons
LANDFILL
PRODUCED FLUID
1909.43 Bbl
REUSE OTHER THAN ROAD SPREADING
Site:
C O P TRACT 729 PAD A 2408
Operator:
PA GEN ENERGY CO LLC
Gas (MCF)
Condensate (Bbl)
Oil (Bbl)
Amount:
1,866,066.00
0.00
0.00
This well was drilled on Feb 17th, 2010
PermitsViolationsWasteProduction
20. PA GEN ENERGY CO LLC
Address:
120 MARKET ST
WARREN, PA 16365-2510
Site Name:
C O P TRACT 729 PAD A 2384
Well Type:
GAS
Status:
New
Marcellus:
Yes
Permit Issued:
Sep 30th, 2009
Horizontal:
No
County:
Lycoming
Municipality:
Cummings Twp
Nov 18th, 2009: Code: 102.4INADPLN - E&S Plan not adequate