2017-025 Gas Well Inspections
Date: April 21, 2017 Report No. 2017-025
INFORMAL STAFF REPORT
TO MAYOR AND CITY COUNCIL
SUBJECT:
The Department of Development Services Gas Well Inspections Division Business Efficiency
Assessment.
BACKGROUND:
The Gas Well Inspections (GWI) Division is presented with a unique opportunity to assess its level of
service. Since the adoption of the most recent gas well ordinance in August 2015, the GWI Division has
realized attrition resulting in 3 vacant positions. This has enabled the reassessment of the skill sets needed
to implement the ordinance. The current structure of the division is reflected in Figure 1 below.
Figure 1: Current Division Structure
Director of Development
Services
GWI Administrator
2 GWI Inspectors (vacant) Gas Well Coordinator (vacant)
The implementation and associated impacts of the ordinance were not realized until the latter part of 2015
revaluated in anticipation of increased gas well
production and to streamline the implementation of the ordinance by placing specific functions in the
appropriate arena.
There are 3 components to the current gas well ordinance which are outlined below;
1. Zoning districts and associated limitations
2. Subdivision platting
3. Gas well drilling and production
As result, the GWI Division fulfils 2 distinct and different functions necessary to achieve the regulation
of gas well development;
1. Relationship to surface development (land use compatibility)
2. Operations
Date: April 21, 2017 Report No. 2017-025
The infancy stage of gas well development is the spatial assessment of the gas well site as it relates to
surface development. It is through the permitting and project review process that the site locations are
reviewed and compatibility with the surrounding land uses is established by requiring specific setbacks
based on the nature of the uses, ensuring access routes to the site do not compromise existing
infrastructure, mitigate nuisance such as noise, notification disclosures, and environmental protection.
This function requires the expertise of a land use planning professional.
The operations function is initiated upon the approval of the gas well site plans/plats and continues through
the lifecycle of the site/well. This inspections arm of the division is unique and requires an experienced
professional in the gas well industry to be able to effectively enforce and discern gas well drilling and
production regulations described in the ordinance. Responsibilities include; evaluating for compliance
with state, federal and local regulations, site inspections, monitoring operations, environmental and
erosion controls measures, nuisance prevention, security measures, integrity of equipment, proper
equipment usage, general housekeeping, review of required testing and surveys, site visits relating to
notices of activity and responding to public complaints and emergencies.
In addition to bi-annual inspections, there are six initial inspections conducted that align with the different
stages of the gas well development lifecycle which are;
1. Predrilling
2. Drilling
3. Completion
4. Flowback
5. First sales
6. Plug & Abandonment. It is important to note that each stage of development poses unique
operations that present higher risks to safety, health, and the environment.
Recommendation
In order to enable a comprehensive and thorough method of implementation of the two primary functions
of the gas well ordinance it is recommended the GWI Division become more weighted in the operations
arena and the land use compatibility function align with the Planning Division.
It is further recommended that the Gas Well Administrator position be reclassified and tailored to Gas
Well Inspector Supervisor. This position will manage the operations function of the Gas Well Inspections
Division described above. This approach provides the operations function to align with industry standards
and responsibilities.
The City has 226 single well sites that can support additional gas well drilling, In addition, most of the
multi well sites can also support additional wells. With minimal modifications, these sites will provide
opportunities for the gas well operators to pursue in-field development at lower costs and lower risks with
infrastructure in place. It is predicted gas well development will become more active in the near future,
and it will be necessary for the Gas Well Inspections Division to fill the vacant Inspector positions. The
proposed functions are illustrated in Figure 2 below.
Date: April 21, 2017 Report No. 2017-025
Figure 2: Proposed Gas Well Division Structure
Director of Development
Services
GWI Operations Division
Planning Division
GWI Inspector Supervisor
Gas Well Land Use Planning
Supervisor
Gas Well Inspector x2
Future Predicted Activity
Over the course of the past two years drilling, completion, re-completion and workovers have been at their
lowest levels of activity. This could be attributed to the decline in natural gas pricing. In the past,
workover activities typically increase as depressed gas prices begin to improve. This has been a precursor
and a leading indicator of future drilling activity improvement. Recently gas prices appear to be modestly
rebounding and as a result workover activity has also increased. For example, from April 2016 to October
2016, there were a total of 11 workovers and from November 2016 to present, there has been a total of 31
workovers.
Exhibits
Exhibit 1 Summary of Gas Well Inspections Role
Exhibit 2 Gas Well Inspection Form
Exhibit 3 Gas Well Inspection Form ETJ
Exhibit 4 Gas Well Development Plat Checklist
Exhibit 5 Gas Well Development Site Plan
Date: April 21, 2017 Report No. 2017-025
FAQs
1. How many gas wells are located within the City of Denton? 294
2.
3. How many gas well plats are located within the City of Denton? 100
4.
5. How many gas well production sites have been created as a result of the current ordinance? 4
GWSP16-0005 Eagleridge, Scout Unit located at 2013 N. Masch Branch Road. This is a new
site and no wells drilling on the site
GWSP16-0007 Eagleridge, Tetra Pak located at 3003 Airport Road. This is an existing site that
was replatted to accommodate the Tetra Pak addition
GWSP17-0001 Eagleridge, Guyer 1 located at 7491 S. Teasley Lane. This is an existing site and
was replatted to accommodate Guyer High School expansion.
GWSP17-0002 Eagleridge, Guyer 2 located at 7501 S. Teasley Lane. This is an existing site and
was replatted to accommodate the Guyer High School expansion.
6. How many workovers by operator? Refer to Figure 3 Below
Figure 3: Workover Activity
Workover Activity - 1 Year Reported in 6 month
increments
Operator 4/16-10/16 11/16-4/17 Total
Eagleridge 10 20 30
Devon 1 2 3
Endeavor 0 4 4
Enervest 0 4 4
Trinity 0 1 1
Total 5 11 31 42
STAFF CONTACT:
Munal Mauladad
Director of Development Services
940-349-8313
Munal.Mauladad@cityofdenton.com
215 W HICKORY STREET DENTON, TEXAS 76201 940.349.8451 FAX 940.340.7707
DEVELOPMENT SERVICES
April 21, 2017
SUBJECT: Role of Gas Well
1. Inspection new and existing gas well sites:
a. There are six initial inspections made at the following phases of gas well
development:
i. Pre-drilling: Inspecting for compliance with the site plan
ii. Drilling: Inspecting for compliance with Fire codes, site plan layouts and
nuisance mitigation
iii. Completion activities: Inspecting for compliance with nuisance mitigation,
sound level reports, and site layout
iv. Flowback: Inspecting for compliance with nuisance mitigation, flaring, dust
and odor, traffic, light and sound
v. First sales: Inspecting for compliance with site layout for the production
operations of the wells, and the gas well equipment
vi. Plugging: Inspecting for compliance associated with restoration and RRC
filed reports
b. Annual inspections are conducted two times a year for all sites within the City and
its ETJ. Within the ETJ, gas well inspections are limited to inspecting only to ensure
that the number of wells drilled does not exceed what was platted and to ensure
required signage is in place.
c. Inspectors also respond to Notices of Activities reported by the operator. Activities
that require reporting to the City are;
i. Site preparation
ii. Drilling
iii. Completion
iv. Recompletion
v. Rework/Workover
vi. Setting surface casing
vii. General maintenance
2. Responding to public inquiries and complaints. The Division seeks to ensure responses are
provided in a timely manner and collaborates with other City departments and regulatory
agencies as necessary to resolve issues at gas well sites.
The Gas Well Inspection Division
gas well ordinance, but also with state and federal law. The following matrix outlines the various
regulatory bodies that influence gas well drilling and production activities in Texas.
Level Regulatory Body Scope of Influence
Environmental
National environmental regulations such as the Clean Air Act place limits
Protection Agency
on emissions and discharges from industrial operations, including oil and
(EPA)
gas.
regulate the manufacture and distribution of chemicals used and produced
Federal
by industrial operations, including oil and gas development.
Occupational
OSHA Regulates worker and site safety, including personnel training,
Safety and Health
chemical labeling, required personal protective equipment, and other
Administration
measures to limit worker exposure to operational and chemical hazards.
(OSHA)
Railroad
The RRC is responsible for regulating almost all aspects of oil and gas
Commission
development in Texas, including processes from well drilling to well
(RRC)
plugging.
RRC maintains records of operating companies as well as their mineral
leases, wells, and production levels.
RRC regional offices conduct periodic inspections of well sites and can
issue violations for improper equipment operation.
State
Texas
Commission on
TCEQ reviews air emission calculations for pad sites and issues permits
Environmental
for the maximum amount of allowable emissions of regulated pollutants.
Quality (TCEQ)
Texas Department
of Health and
exposure to naturally occurring radioactive material (NORM), which can
Human Services
be presenting in piping and storage tanks on pad sites.
Gas Well
GWI reviews and issues Gas Well Site Plans and permits.
Inspections
GWI reviews subdivision plats and other development projects for
Division (GWI)
compliance with setbacks and other provisions of the ordinance.
GWI conductions initial and bi-annual inspections of all gas well pad
sites within the City and its ETJ.
Watershed
The Watershed Protection department review Gas Well Site Plans to
Protection
ensure storm water protection and erosion control is provided.
The department conducts initial site inspections to ensure erosion control
measures are installed properly.
Fire Department
The Fire Department issues permits for gas wells and storage tanks.
Municipal
The Fire Department conducts inspections of pad sites to ensure tanks are
in good operating condition, secondary containment measures are
functional, and lightning protection is in place.
The International Fire Code establishes minimum setbacks between
production equipment (i.e. wellheads and flammable liquid containers)
and buildings.
The Fire Department reviews Gas Well Site Plans to ensure setbacks are
met and site access is adequate.
Police Department
The Police respond to citizen concerns regarding safety and noise
violations at pad sites.
2
GAS WELL INSPECTIONS DIVISION
PLANNING & DEVELOPMENT DEPARTMENT
City Hall West: 221 North Elm Street | Denton, Texas 76201
(940) 349-8372 | www.cityofdenton.com/gaswellinspections
G AS W ELL D EVELOPMENT P LAT C HECKLIST
REQUIREMENTSSPECIFICTOAGASWELLDEVELOPMENTPLAT
AnypersonproposingoramendingaDrillingandProductionSiteonatractoflandlocatedinDivisionIof
the/źƷǤƭExtraterritorialJurisdiction(ETJ)shallprepareandsubmitacompletedGasWellDevelopment
ApplicationalongwithaGasWellDevelopmentPlatChecklistform.
ThefollowingmustbeincludedineachapplicationpackagesubmittedtotheCityforreview.
1.GasWellDevelopmentApplication;
2.CompletedGasWellDevelopmentPlatchecklist;
3.Appropriateapplicationfee(s);and
4.ExhibitsAthroughDbelow*
*EachExhibitshallbesubmittedoruploadedasaseparatesheet.Includethewordͷ9ǣŷźĬźƷandthecorrespondingletterinthe
prefixofthedocumenttitle,e.g.,ExhibitAΑCoverPageandProjectInfo.
Checkif
Provided
ExhibitA:CoverpagethatincludesavicinitymapoftheDrillingandProductionSite;aSheetIndexthatidentifies
thenumberofExhibitswithtitlesforeach(exhibittitlesshallbeginwiththewordͷ9ǣŷźĬźƷandincludethe
respectiveletter);theDrillingandProductionSiteName(aka:ProjectTitle);thedateofpreparation;theƦƩĻƦğƩĻƩƭͲ
hƦĻƩğƷƚƩƭͲandpropertyƚǞƓĻƩƭnames;Cityprojectnumber;andasignatureblockforboththeGasWell
AdministratorandtheCitySecretary.AddanotetotheCoverPagestatingthereasonforamendment,ifapplicable.
ExhibitB:AmappingexhibitwithanaccuratelegaldescriptionoftheDrillingandProductionSitethatwasprepared
andcertifiedbyaRegisteredProfessionalLandSurveyoroftheStateofTexas.Provideclosuresheetofbearingsand
distancesusedinlegaldescription.Theexhibitshallincludeexactlocation,dimension,anddescriptionofallexisting
public,proposed,orprivateeasements,andpublicrightofwaywithintheleasearea,intersectingorcontiguous
withitsboundary,orformingsuchboundary.Describeandlocateallpermanentsurveymonuments,pins,and
controlpointsandtieandreferencethesurveycornerstotheTexasStatePlaneCoordinateSystemNorthCentral
Zone19831999datum.ProvideproposedpipelineƩƚǒƷĻΓƓƚƷĻthataseparateapplicationmaybenecessaryifthe
proposedrouteencroachesontoanypubliceasement,rightofwayorlandownedbytheCityofDenton.
ExhibitC:AdrawingoftheDrillingandProductionSiteshowingclearsiteboundarylinesandthelayoutofthesite.
Includea1,000footbuffercirclearoundtheboundaryoftheDrillingandProductionSiteforreference.
ExhibitD:AccessandTransportationPlanidentifyingthepointsofaccessandroutestobefollowedontheroad
networksupportinggaswelldevelopmentontheDrillingandProductionSiteovertime.
IREVIEWEDTHECHECKLISTANDALLSUBMITTALSFORCOMPLETENESSANDACCURACY.
______________________________________________________________________
SignatureDate
GAS WELL INSPECTIONS DIVISION
DEVELOPMENT SERVICES DEPARTMENT
City Hall West: 221 North Elm Street | Denton, Texas 76201
(940) 349-8372 | www.cityofdenton.com/gaswellinspections
G AS W ELL D EVELOPMENT S ITE P LAN C HECKLIST
REQUIREMENTSSPECIFICTOAGASWELLDEVELOPMENTSITEPLAN
AnypersonproposingoramendingaDrillingandProductionSiteonatractoflandlocatedwithintheCity
ofDentonshallprepareandsubmitacompletedGasWellDevelopmentApplicationalongwithaGasWell
DevelopmentSitePlanChecklistform.TheSitePlanmaybecontingentonapprovalofacorresponding
SpecificUsePermit(SUP)orWatershedProtectionPermit(WPP),ifrequiredforthesite.
ThefollowingmustbeincludedineachapplicationpackagesubmittedtotheCityforreview.
1.GasWellDevelopmentApplication;
2.CompletedGasWellDevelopmentSitePlanchecklist;
3.Appropriateapplicationfee(s);
4.ExhibitsAthroughJbelow*;and
5.ProofofrequiredInsuranceandSurety.
*EachExhibitshallbesubmittedoruploadedasaseparatesheet.Includethewordͷ9ǣŷźĬźƷandthe
correspondingletterintheprefixofthedocumenttitle,e.g.,ExhibitAΑCoverPageandProjectInfo.
Check
boxas
Provided
ExhibitA:CoverpagethatincludesavicinitymapoftheDrillingandProductionSite;aSheetIndexthatidentifies
thenumberofExhibitswithtitlesforeach(exhibittitlesshallbeginwiththewordͷ9ǣŷźĬźƷandincludethe
respectiveletter);theDrillingandProductionSiteName(aka:ProjectTitle);thedateofpreparation;theƦƩĻƦğƩĻƩƭͲ
hƦĻƩğƷƚƩƭͲandpropertyƚǞƓĻƩƭnames;Cityprojectnumber;andasignatureblockforboththeGasWell
AdministratorandtheCitySecretary.AddanotetotheCoverPagestatingthereasonforamendment,ifapplicable.
ExhibitB:AmappingexhibitwithanaccuratelegaldescriptionoftheDrillingandProductionSitethatwasprepared
andcertifiedbyaRegisteredProfessionalLandSurveyoroftheStateofTexas.Provideclosuresheetofbearingsand
distancesusedinlegaldescription.Theexhibitshallincludeexactlocation,dimension,anddescriptionofallexisting
public,proposed,orprivateeasements,andpublicrightofwaywithintheleasearea,intersectingorcontiguous
withitsboundary,orformingsuchboundary.Describeandlocateallpermanentsurveymonuments,pins,and
controlpointsandtieandreferencethesurveycornerstotheTexasStatePlaneCoordinateSystemNorthCentral
Zone19831999datum.ProvideproposedpipelineƩƚǒƷĻΓƓƚƷĻthataseparateapplicationmaybenecessaryifthe
proposedrouteencroachesontoanypubliceasement,rightofwayorlandownedbytheCityofDenton.
ExhibitC:AmapshowingthedistancefromtheboundariesoftheDrillingandProductionSitefromallProtected
UsesandResidentialSubdivisions.ThemeasurementshallbecomputedinaccordancewithDDCSection
35.5.10.2.D.Iftheseparationdistance(s)fromProtectedUsesandResidentialSubdivisionsdonotmeetthesetback
requirementsofDDCSection35.5.10.2,theapplicationalsomustincludeacopyofthewaiversapprovedpursuant
toDDCSection35.5.10.6.A,ortheapprovalofasetbackvarianceapprovedbytheBoardofAdjustmentpursuantto
DDCSection35.5.10.6.B.IftheOperatorseekstoqualifytheproposedDrillingandProductionSiteforan
administrativewaiverpursuanttoDDCSection35.5.10.6.C,theinformationthereinrequiredshallbesubmitted
withtheapplicationforsiteplanapproval.
ExhibitD:AsiteplanoftheDrillingandProductionSite,capableofbeingrecorded,showingclearsiteboundary
linesandthelocationofallƚƓΑƭźƷĻimprovementsandequipment,including:tanks,pipelines,compressors,
separators,andotherappurtenancesinrelationtotheboundariesofthesite.
GAS WELL INSPECTIONS DIVISION
DEVELOPMENT SERVICES DEPARTMENT
City Hall West: 221 North Elm Street | Denton, Texas 76201
(940) 349-8372 | www.cityofdenton.com/gaswellinspections
G AS W ELL D EVELOPMENT S ITE P LAN C HECKLIST
ExhibitE:ErosionandSedimentControlPlan.Exhibitmustincludecontactinformation;aphysicalsitedescription
including:landuses,generalvegetationandsurfacewaterinnearproximity;topography/contourlinesbothpre
andpostconstruction;hydrologicanalysisincluding:stormwaterdirectionalflow,outfalls,waterwellrelated
structuresandwatersources;receivingwaters;soils;projectnarrativewithgeneraltimeline;wellpadsiteplan
including:fuelingareas,wastedisposalcontainers,hazardousmaterialsstorage,andproductandcondensate
storagetanks;soilstabilizationanderosioncontrolmeasuresincluding:listofselectedstormwatermeasures,site
mapofselectedstormwatermeasureslocationsandfinalstabilizationplans;solidwastemanagementplan,
septic/portoletlocation;andmaintenanceplanforstormwatercontrolsincludingscheduleandtransferof
ownershipprovision.SeeGasWellErosionandSedimentControlPlanGuidanceDocumentfordetails.
ExhibitF:AnAccessandTransportationPlanidentifyingthepointsofaccessandroutestobefollowedontheroad
networksupportinggaswelldevelopmentontheDrillingandProductionSiteovertime,andtheinternalcirculation
planforthepropertycontainingtheproposedsite,includingprovisionstoprotectvehicleaccesstoNeighborhood
Streets.ThePlanshallcontainspecificationsforconstructionoftheaccessroad(s)andonsitefirelanesthatmeet
thestandardsforemergencyaccesssetforthinDDCSection35.22.2.E.Amapshowingtransportationrouteand
roadforequipment,supplies,chemicals,orwasteproductsusedorproducedbythegaswelloperationshallbe
included.Themapshallillustratethelengthofallpublicroadsthatwillbeusedforsiteingressandegress.Notethat
siteaccessviaaNeighborhoodStreet,asdefinedintheDDC,isnotpermitted.Thewatersourceproposedforboth
thedrillingandfracturingstagesshallbeidentifiedinthePlan,togetherwithadesignationwhetherthewateristo
behauledorpipedtothesite.
ExhibitG:LandscapePlan.Theprojectreviewplannerwilldetermineifabufferisrequiredbasedontheadjacent
landuse(s).IfPlannerdeterminesbufferisrequired,thenalandscapeplanmustbesubmittedinaccordancewith
theCityof5ĻƓƷƚƓƭLandscapePlanChecklist.NoteveryDrillingandProductionSiterequiresalandscapeplan.
ExhibitH:ATreeInventoryandaPreservationPlanandMitigationPlanpursuanttoDDCSection35.13.7.
ExhibitI:ANoiseManagementPlan,preparedinaccordancewithDDCSection35.22.2.F.2.
ExhibitJ:ProofofissuanceofNoticeofActivitiespursuanttoDDCSection35.22.7.
IREVIEWEDTHECHECKLISTANDALLSUBMITTALSFORCOMPLETENESSANDACCURACY.
______________________________________________________________________
SignatureDate