Loading...
2023.04.21_Vendor_Inspection_Padsite103 III(TS, MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATE June 8, 2023 ReportPadsite Inspection Padsite No. 103(Cole Trust South 8) PROJECT 23002 Operator: BKV Location: ®City of Denton ❑ Denton ETJ ATTN City of Denton TRAKiT ID: 1108-0343T, 1108-0355T, 1108-0593T 215 East McKinney Street API: 12132619, 12132959, 12132960 Denton,Texas 76201 Insp. Date: 4/21/23 Priority: ❑ High ❑ Moderate ® Low Modern Geosciences, LLC (Modern) is pleased to provide the attached Padsite Inspection Report documenting the results of our recent inspection and monitoring events at the above-referenced padsite. A general summary of findings is presented below with detailed results provided in the attached report. ■ Field Inspection Results: As part of the field inspection efforts, Modern evaluated the padsite concerning general ordinance or operational requirements set forth by the City. No operational or ordinance compliance issues were noted by Modern during our inspection efforts other than noted below: • Bare pipe/corrosion noted on Wells A and B and Separators A through C. According to the Operator representative, all corrosion observations were addressed as of May 31, 2023, thus the corrosion observations are no longer considered Action Items. Future verification suggested. • Overgrown vegetation noted along access road. According to the Operator representative,all vegetation observations were addressed as of June 8,2023,thus the vegetation observations are no longer considered Action Items. Future verification suggested. ■ Near-Equipment Inspection Results: Our inspection efforts at this padsite included near- equipment monitoring using optical gas imaging(OGI)to identify leaks of methane and/or volatile organic compounds (VOCs) and radiation meters to identify equipment exhibiting naturally- occurring radioactive material (NORM) above applicable regulatory criteria. The accumulation of scale within equipment can cause elevated NORM levels requiring proper signage and equipment management. A summary of near-equipment findings is presented below with further detail in the attached report. Near Equipment inspection Summary: Equipment Number Leaks* Unlabeled NORM** Labeled NORM** Wells 3 0 0 0 Separators 3 0 0 0 ASTs 3 1 0 0 Other 3 0 0 0 *OGI leaks identified exclude operational low bleed components(<6 scf/hr) **NORM exceeding 50 µR/hr 5100 THOMPSON TERRACE,COLLEYVILLE TEXAS 76034 1 F 682.223.1593 1 P 682.223.1322 www.MODERNGEOSCIENCES.com �S, MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS All near-equipment inspection concerns (e.g., leaks) were communicated to the operators with a two-week period to address each. If the concerns were not addressed, these are included in the Action Items listed below. If items were addressed, this will be documented in the report. ■ Action Items: If items are identified during our inspection that remain unresolved or require future confirmation, these will be listed as individual action items for the operator until the City has confirmed further action is not required. There are no outstanding Action Items as of the date of this report. ■ Inspection Data Trends (Leak and NORM Rate): Modern performed a review of inspection data across five(5) North Texas municipalities that use similar inspection methods and data acquisition to develop benchmarks concerning padsite and/or operator performance. This included inspection of over 2,600 wells and 8,000 pieces of supporting equipment. Implementation of these inspection programs resulted in an estimated 56%decrease in leaks. Using these data sets, Modern prepared the following benchmarks for general reference purposes concerning the Leak Rate (number of leaks divided by the number of wells) and NORM Rate (amount of equipment with NORM >50 µR/hr divided by number of wells). While each padsite is unique and will have operational and equipment differences, when normalized to a "per well" basis for tracking it provides a useful benchmark. Performance Leak Rate NORM Rate Good <0.5 <0.4 Moderate >_0.5 to<1.5 >_0.4 to<1.2 Poor >1.5 >1.2 The Leak Rate and NORM Rate for this padsite over time are presented below: Leak and NORM Rate a 0.4 0.3 0 0.2 z Y 0.1 co v J 0 2018 2019 2020 2021 2022 2023 Leak Rate --K� NORM Rate 5100 THOMPSON TERRACE,COLLEYVILLE TEXAS 76034 1 F 682.223.1593 I P 682.223.1322 www.MODERNGEOSCIENCES.com 4(--!Sl MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS ■ Next Inspection Event: The City of Denton completes periodic inspections at all padsites throughout the year. In addition to this, the City has asked Modern to perform supplemental inspections with high-resolution equipment based on proximity to sensitive property uses. Based on the current prioritization,this padsite is scheduled to be inspected again by Modern in the first half of 2024. CLOSING We appreciate the opportunity to provide our services to you. Should you require additional information or have any questions regarding this report, please contact the undersigned at 682.223.1322. Respect Ily submitte , nneth .Tramm, PhD, G, CHMM Senior Program Manager MODERN GEOSCIENCES Texas Registered Geoscience Firm 50411 Texas Registered Engineering Firm F-16201 5100 THOMPSON TERRACE,COLLEYVILLE TEXAS 76034 1 F 682.223.1593 I P 682.223.1322 www.MODERNGEOSCIENCES.com <S MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATE June 8, 2023 PROJECT 23002 PADSITE INSPECTION REPORT Padsite No. 103—Cole Trust South 8 PREPARED FOR City of Denton 215 East McKinney Street Denton,Texas 76201 PREPARED BY REVIEWED BY Zacha ondr , GIT e eth S.krarrim, PhD, PG,` HMM PROJECT MANAGER SENIOR PROGRAM MANAGER 5100 THOMPSON TERRACE,COLLEYVILLE TEXAS 76034 1 E 682.223.1593 1 P 682.223.1322 ©2023 MODERN GEOSCIENCES.ALL RIGHTS RESERVED. www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Cole Trust South 8(#103) Operator:BKV Inspection Date:04121123 Inspectors:ZT, SB MODERN G E O S C I E N C E 5 TRUSTED ENVIRONMENTAL ADVISORS FIELD INSPECTION RESULTS: Pass Fail N/A General Inspection Checklist Items (per • 00i• ® ❑ ❑ Item A.4: No refining processes present (dehydrator and separator exempt). Comments: None ® ❑ ❑ Item A.5: No chemical, refuse, or wastewater discharge present. Comments: None ❑ ❑ ® Item 13.1: Light reflective sign at entrance gate present. Comments: Not applicable for this inspection period. Item B.2.a/b: Appropriate fencing, buffering, landscaping, and/or screening present ® ❑ ❑ within 300ft of all equipment (as applicable). Comments: None Item 13.3.a:"THIS IS A GAS WELL DRILLING AND PRODCUTION SITE.THIS SITE MAY BE THE SUBJECT ❑ ❑ ® OF FURTHER DRILLING AND PRODUCTION AND/OR HYDRAULIC FRACTURING' signage present. Comments: Not applicable for this inspection period. Item 13.3.b: Additional signage present (well identification number, operator name, ❑ ❑ ® telephone number, and mailing address, Site address, emergency number [911], City's Gas Well Division telephone number, and TCEQ's Regional Office telephone number). Comments: Not applicable for this inspection period. ❑ ❑ ❑ Item 13.3.c: "DANGER NO SMOKING ALLOWED" signage present. Comments: Not applicable for this inspection period. ® ❑ ❑ Item 13.4:All equipment painted with no bare pipe, rust, blisters, or stains present. Comments: Bare pipe/corrosion noted (detailed in near-equipment summary). ® ❑ ❑ Item 13.6: Compressor located at least 24ft from outer boundary of Site (as applicable). Comments: None ® ❑ ❑ Item 13.8: No rubbish or debris constituting a fire hazard present. Comments: None Item 13.9: Site and access road free of debris, pools of water/liquid, contaminated soil, ® ❑ ❑ weeds, brush,trash, or other waste material. Comments: Overgrown vegetation noted (detailed in near-equipment summary). Item E.7:Site equipped with a lightning protection system and tank battery equipped with ® ❑ ❑ a lightning arrestor system (as applicable). Comments: None ® ❑ ❑ Item E.8: Site equipped with a remote foam line (as applicable). Comments: None Item E.12: All-weather surface emergency access road at least 20 ft in width present or ® ❑ ❑ as approved by the Fire Marshall. Comments: None Item E.14: Appropriate secondary containment or oil absorbing materials present (as ® ❑ ❑ applicable). Comments: None ® ❑ ❑ Item F.1: Site and structures not dilapidated, unsightly, or unsafe. Comments: None ® ❑ ❑ Item F.3: Lighting not directed toward adjacent property/roads (as applicable). Comments: None Note:The above items represent key compliance requirements of Ordinance No. DCA19-0009e dated January 28th,2023. PROJECT 23002 1 JUNE 8,2023 1 PAGE 1 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Cole Trust South 8(#103) Operator:BKV Inspection Date:04121123 Inspectors:ZT, SB MODERN G E O S C I E N C E 5 TRUSTED ENVIRONMENTAL ADVISORS Constituent: Methane NORM At Equipment: 10,000 ppmv 1 50 µR/hr 2 Equipment: OGI Camera Radiation Meter Resolution: 3,000-10,000 ppmv 1 µR/hr Notes: 1-Utilizes the Interstate Natural Gas Association of America (INGAA) recommended leak definition within their December 4,2015 response to EPA Docket No. EPA-HQ-OAR-2010-0505 — "Oil and Natural Gas Sector: Emission Standards for New and Modified Sources," dated September 18, 2015 (80 FIR 56593). Within their response to the EPA, the INGAA noted the following, "the INGAA recommends a leak definition concentration of 10,000 ppm.This is consistent with the range of thresholds in current regulations,also consistent with the OGI performance objectives in §60.5397a(c)(7)(i)(B), and consistent with the Subpart W leak definition." This methane concentration also represents 20% of the Lower Explosive Limit and is consistent with 40 CFR §60.18(g)(6) (i) ["any emissions imaged by the optical gas instrument"].A lower leak definition and additional inspection and reporting may be required at facilities subject to 40 CFR §60 Subpart OOOOa. Documented continuous low-bleed components (<6 scf/hr) and intermittent emissions from properly functioning pneumatic devices are not considered leaks for the purposes of this inspection. The term"leak"is used within this inspection effort to define potential fugitive emissions that appear to be continuous in nature and suggestive equipment and/or components are not functioning properly. 2-The Texas Railroad Commission (RRC) regulates NORM under 16 TAC §4 (Environmental Protection, Subchapter F, Oil and Gas NORM). Subchapter F establishes the requirements for oil and gas NORM waste disposal for the purpose of protecting public health and the environment.NORM-contaminated equipment is defined in Subchapter F as"equipment that,at any accessible point,exhibits a minimum radiation exposure level greater than 50 µR/hr including background radiation level." When identified,the equipment suspected of being NORM-containing will be communicated to the City and operator(s)to allow further inspection and where appropriate compliance with RRC signage and management requirements. PROJECT 23002 1 JUNE 8,2023 1 PAGE 2 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name: Cole Trust South 8(#103) Operator: BKV Inspection Date:04121123 Inspectors:ZT, SB MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS NEAR EQUIPMENT INSPECTION RESULTS: JSPECTION RESULTS - WELL Location ID: Leaks (OG I): NORM (lLR/hr; max): Date Reported': Date Addressed': Well A None <15 NA NA Well B None <15 NA NA Well C None <15 NA NA General Notes: Bare pipe/corrosion noted on Wells A and B. According to the Operator representative, all corrosion observations were addressed as of May 31, 2023, thus the corrosion observations are no longer considered Action Items. Future verification suggested. No other concerns noted. 1—Reported to operator,•2—If reported to Modern by operator/City; *NORM exceeding 50 µR/hr not labeled INSPEG I IL Location ID: Leaks (OGI): NORM (�tRffir; max): Date Reported': Date Addressed 2 Separator A None <15 NA NA Separator B None <15 NA NA Separator C None <15 NA NA General Notes: Bare pipe/corrosion noted on Separators A through C.According to the Operator representative, all corrosion observations were addressed as of May 31, 2023, thus the corrosion observations are no longer considered Action Items. Future verification suggested. No other concerns noted. 1—Reported to operator,•z—If reported to Modern by operator/City; *NORM exceeding 50 µR/hr not labeled Location ID: Leaks (OGI): NORM (�tRffir; max): I Date Reported': Date Addressed 2 Former AST A NA NA NA NA Former AST B NA NA NA NA Former AST C NA NA NA NA Former AST D NA NA NA NA AST E None <15 NA NA AST F Thief Hatch <15 04/21/23 05/31/23 AST G None <15 NA NA General Notes: No other concerns noted. 1—Reported to operator,•z—If reported to Modern by operator/City; *NORM exceeding 50 µR/hr not labeled 'NSPECTION RESULTS — COMPRESSORS OR ANCILLARY EQUIPME— FLocation ID: Leaks (OG I): NORM (IiR/hr; max): Date Reported': Date Addressed': Former Compressor A NA NA NA NA Temporary Compressor B None <15 NA NA Ancillary A None <15 NA NA Ancillary B None <15 NA NA General Notes: Temporary Compressor B may require paint and fencing if converted to permanent. Overgrown vegetation noted along access road. According to the Operator representative, all vegetation observations were addressed as of June 8, 2023, thus the vegetation observations are no longer considered Action Items. Future verification suggested. No other concerns noted. 1—Reported to operator,•z—If reported to Modern by operator/City; *NORM exceeding 50 µR/hr not labeled PROJECT 23002 1 JUNE 8,2023 1 PAGE 3 www.MODERNGEOSCIENCES.com v MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS PHOTOGRAPHIC DOCUMENTATION www.MODERNGEOSCIENCES.com i ♦ ��'��' � �� _1� "��'� g' ��.r-.•.^rr yam, K^e• .;il�--mil .:.� �.- t s T�'•d v MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS FIGURES www.MODERNGEOSCIENCES.com Aerial Source:Microsoft Corporation©and its data suppliers Devon Well ID RRC ID Padsite Location A 229543 .O B 229544 C 214664 � Denton ra r �' o Bes— Source'.ESRI ■■ ' C) ' •- !�I D Legend: E Q Well F G Separator O -JIvI � - - - - - • • AST � OFormer AST - - - - - - Temporary Compressor OTemporary Compressor Ancillary Equipment r- -r - - Observation Path Padsite PROJECT NO. 23002 FIGURE 0 50 100 150 200 ® 05.01.23 PADSITE MAP Feet DRAWN: This figure was prepared using data from a variety of souI DRAWN BY: CS No warranty is made as to the accuracy or completeness of CHECKED BY: provided through third parties. All data contained hereinMODERN G E O S C I E N C E S ZT Cole Trust South 8 Padsite(No.103) subject to change without notice.This figure is not intended for use FILE NAME: 8333 FM 2449 legal survey or construction design document. If denoted, Denton,Texas direction represents dominant wind direction observed during field acti TRUSTED ENVIRONMENTAL ADVISORS® 103_L_BKV_CT88_Padsite_230501.mxd