2025.04.30_Vendor_Inspection_Padsite021 MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
Padsite Inspection Report
Padsite No. 021(Long Term Pad)
DATE May 31, 2025 Operator: EagleRidge
PROJECT 25048 Location: ®City of Denton ❑ Denton ETJ
1109-0139,1405-0183,1405-0184,1405-0185,
ATTN City of Denton TRAKiT ID: 1406-0609,1406-0617,1407-0039,1407-0398,
1407-0402,1407-0411,1407-0412,1407-0413
215 East McKinney Street 12132392,12134453,12134454,12134455,
Denton,Texas 76201 API: 12134456,12134457,12134458,12134473,
12134469,12134470,12134471,12134472
Insp. Date: 04/30/25
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.
■ 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
Equipment Number Leaks* Unlabeled NORM** Labeled NORM**
Wells 12 1 3 2
Separators 6 0 1 5
ASTs 16 2 1 5
Other 1 4 1 0 101 0
*OGI leaks identified exclude operational low bleed components(<6 scf/hr)
**NORM exceeding 50 µR/hr
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.
5100 THOMPSON TERRACE,COLLEYVILLE,TEXAS 76034 1 F 682.223.1593 1 P 682.223.1322
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TRUSTED ENVIRONMENTAL ADVISORS
■ Fenceline Inspection Results: Our inspection efforts for this padsite included an evaluation of air
quality at representative upwind and downwind points at the padsite boundary. Our approach
utilized a variety of equipment to screen for potential impacts that could affect air quality off of
the padsite or suggest additional monitoring may be warranted. Please refer to the report for
additional detail on our findings.
Fenceline inspection did not identify air quality concerns above program screening goals.
■ 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
2
41
cf6c 1.5
0 1
Z
Y 0.5
ca
a
J
0
Leak Rate (NORM Rate
5100 THOMPSON TERRACE,COLLEYVILLE,TEXAS 76034 1 F 682.223.1593 I P 682.223.1322
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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
second half of 2026.
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 I F 682.223.1593 I P 682.223.1322
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<S
MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
DATE
May 31, 2025
PROJECT
25048
PADSITE INSPECTION
REPORT
Padsite No. 021— Long Term Pad
PREPARED FOR
City of Denton
215 East McKinney Street
Denton,Texas 76201
PREPARED BY REVIEWED BY
Zacha ondr PG be /eth S.kramm, PhD, PG, HMM
PROJECT MANAGER SENIOR PROGRAM MANAGER
5100 THOMPSON TERRACE,COLLEYVILLE,TEXAS 76034 1 F 682.223.1593 r 682.223.1322
0 2025 MODERN GEOSCIENCES.ALL RIGHTS RESERVED.
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PADSITE INSPECTION REPORT
Padsite Name:Long Term Pad(#021) Operator: EagleRidge
Inspection Date:04130125 Inspectors:ZT, SP MODERN G E O S C I E N C E S
TRUSTED ENVIRONMENTAL ADVISORS
FIELD INSPECTION RESULTS:
InspectionPass Fail N/A General No. 000•
® ❑ ❑ 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 B.1: Light reflective sign at entrance gate present.
Comments: None
Item B.2.a/b: Appropriate fencing, buffering, landscaping, and/or screening present
® ❑ ❑ within 300ft of all equipment (as applicable).
Comments: None
Item B.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: None
Item B.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: None
❑ ❑ ❑ Item B.3.c: "DANGER NO SMOKING ALLOWED"signage present.
Comments: None
❑ ❑ ❑ Item B.4:All equipment painted with no bare pipe, rust, blisters, or stains present.
Comments: None
❑ ❑ ❑ Item B.6: Compressor located at least 24ft from outer boundary of Site (as applicable).
Comments: None
❑ ❑ ❑ Item B.8: No rubbish or debris constituting a fire hazard present.
Comments: None
Item B.9: Site and access road free of debris, pools of water/liquid, contaminated soil,
❑ ❑ ❑ weeds, brush,trash, or other waste material.
Comments: None
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,2020.
PROJECT 25048 1 MAY 31,2025 1 PAGE 1
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PADSITE INSPECTION REPORT
Padsite Name:Long Term Pad(#021) Operator: EagleRidge
►nspection Date:04130125 ►nspectors:ZT, SP MODERN G E O S C I E N C E S
TRUSTED ENVIRONMENTAL ADVISORS
TEAR EQUIPMENT INSPECTION C;RITERIA:
• 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
•nstituent: Methane tvOCS H2S NORM
Fenceline: 500 ppmv 3 0.1 ppmv 4 0.08 ppmv 5 20 µR/hr 6
Equipment: DPIR Meter PID H2S Meter Radiation Meter
Resolution: 1 ppmv 0.001 ppmv 0.003 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 FR 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.
3-Represent half of the American Conference of Governmental Industrial Hygienists(ACGIH)8-hour threshold limit value(TLV)of 1,000 ppmv
(0.1%by volume)set for potential cardiac sensitization and central nervous system depression.
4-Consistent fenceline concentrations of 0.1 ppmv could indicate a potential off-site air quality exceedance of applicable TCEQAir Monitoring
Comparison Values (AMCVs) or Effect Screening Levels (ESLs). Further sampling will be needed to confirm the individual compounds
present and direct regulatory comparison.
5-Indicative of possible 30 TAC§112.31(30-min avg.)exceedance of 0.08 ppmv. Further sampling will be needed to confirm the 30-minute
average and allow direct regulatory comparison.
6-EPA average background criteria established under Document No.402-R-08-005;April 2008. Reported background ranged from 10 µR/hr
to 85 µR/hr. Elevated fenceline observations may require further screening to confirm attenuated levels near sensitive receptors.
PROJECT 25048 1 MAY 31,2025 1 PAGE 2
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PADSITE INSPECTION REPORT
Padsite Name:Long Term Pad(#021) Operator: EagleRidge
Inspection Date:04130125 Inspectors:ZT, SP MODERN G E O S C I E N C E S
TRUSTED ENVIRONMENTAL ADVISORS
NEAR EQUIPMENT INSPECTION RESULTS:
INSPECTIC JLTS -11N
Location ID: Leaks (OGI): NORM (�tRffir; max): Date Reported': Date Addressed':
Well A None <15 NA NA
Well B None 70 NA NA
Well C None <15 NA NA
Well D None 65* 05/02/25 05/21/25
Well E None <15 NA NA
Well F None 20 NA NA
Well G None 75* 05/02/25 05/21/25
Well H None <15 NA NA
Well None <15 NA NA
Well None 100* 05/02/25 05/21/25
Well K Master Valve 600 05/02/25 05/21/25
Well L None <15 NA NA
General Notes: The other NORM observations were labeled prior to Modern's inspection. No other concerns
noted.
'—Reported to operator,•z—If reported to Modern by operator/City,• *NORM exceeding 50 µR/hr not labeled
INSPECTION RESULTS—SEPARATORS
Location ID: Leaks (OGI): NORM (�tRffir; max): Date Reported': Date Addressed':
Separator A None 140 NA NA
Separator B None 300 NA NA
Separator C None 65 NA NA
Separator None 110* 05/02/25 05/21/25
Separator E None 600 NA NA
Separator F None 140 NA NA
Former Separator G NA NA NA NA
General Notes: The other NORM observations were labeled prior to Modern's inspection. No other concerns
noted.
'—Reported to operator,•'—If reported to Modern by operator/City,• *NORM exceeding 50 µR/hr not labeled
PROJECT 25048 1 MAY 31,2025 1 PAGE 3
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PADSITE INSPECTION REPORT
Padsite Name:Long Term Pad(#021) Operator: EagleRidge
Inspection Date:04130125 Inspectors:ZT, SP MODERN G E O S C I E N C E S
TRUSTED ENVIRONMENTAL ADVISORS
INSPEC S — I ANr S
Location ID: Leaks (OGI): NORM (�tR/hr; max): Date Reported': Date Addressed':
AST A None <15 NA NA
AST B None <15 NA NA
AST C None 45 NA NA
AST D None 40 NA NA
AST E None 20 NA NA
AST F None 25 NA NA
AST G None 65 NA NA
AST H None <15 NA NA
AST None 30 NA NA
AST J None 80 NA NA
AST K None 250 NA NA
AST L None 20 NA NA
AST M None 190 NA NA
AST N None <15 NA NA
AST O Enardo Valve 110 05/02/25 05/21/25
Temporary AST P Thief Hatch 200* 05/02/25 05/21/25
General Notes: The other NORM observations were labeled prior to Modern's inspection. No other concerns
noted.
1—Reported to operator;'—If reported to Modern by operator/City; *NORM exceeding 50 µR/hr not labeled
iNSNtc:11UN RESULTS— COMPRESSORS OR ANCILLARY E(
Location ID: Leaks (OGI): NORM (ltR/hr; max): Date Reported': Date Addressed 2:
Compressor A None <15 NA NA
Compressor B None <15 NA NA
Ancillary A None <15 NA NA
Ancillary B 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
PROJECT 250481 MAY 31,2025 1 PAGE 4
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AWWIN
PADSITE INSPECTION REPORT
Padsite Name:Long Term Pad(#021) Operator: EagleRidge
Inspection Date:04130125 Inspectors:ZT, SP MODERN G E O S C I E N C E S
TRUSTED ENVIRONMENTAL ADVISORS
FENCELINE INSPECTION RESULTS:
- -• . •• Avg. Wind Direction (to): N Avg. Wind Speed (mph): 3.4 Bar. Pressure ("Hg): 29.12
9. Avg.Temp (DF): 61.0 Humidity(%): 91.0 Precipitation: N/A
Fenceline Screening Criteria: Yes No N/A Upwind Observations: Downwind Observations:
1 PID > 100 ppbv(0.1 ppmv)? ❑ ® ❑ <1 ppbv <1 ppbv
1 Radiation >20 µR/hr? ❑ ® ❑ <15 µR/hr <15 µR/hr
1 H2S>80 ppbv(0.08 ppmv)? ❑ ® ❑ <5 ppbv <5 ppbv
1 Methane >500 ppmv? ❑ ® ❑ <5 ppmv <5 ppmv
Other perimeter/fenceline observations suggestive of releases or concerns: None
Comments: None
Notes:
1- Represents the maximum discrete sampling result recorded by Modern across fenceline screening alignment.
General Inspection Program Notes:
1- Modern confirmed operation of all field equipment in accordance with manufacture specifications and Modern's standard operating procedures
prior to field inspection efforts. This included the use of zero and prepared calibration samples.
2- Modern's services were performed in a manner consistent with a level of care and skill ordinarily exercised by other members of our profession
practicing in the same locality,under similar conditions and at the time the services were performed. The scope of services performed was in
accordance with the scope of work agreed with by our client,as set forth in our proposal and related authorization agreement(s).
3- Laws,regulations and professional standards applicable to Modern's services are continually evolving. Techniques are,by necessity,often new
and relatively untried. Different professionals may reasonably adopt different approaches to similar problems. As such, our services are
intended to provide our client with a source of professional advice, opinions and recommendations based on a limited number of field
observations and tests,collected and performed in accordance with the generally accepted practice that exists at the time,and may depend on,
and be qualified by, information gathered previously by others and provided to Modern by our Client. Modern does not warrant the work of
third parties supplying information used in the report.
4- The monitoring results collected as part of these services represent field conditions at the time of inspection or monitoring only. Samples or
monitoring data collected at other times may reveal different results that are representative of site conditions during other periods of time. The
use of monitoring efforts is not intended to replace laboratory methodology,but rather provide data indicative of when additional efforts may
be warranted. Modern's air sampling is consistent with current regulatory guidance and/or manufacturer specification. For a higher level of
certainty,our monitoring methods can be expanded over longer periods of time and/or supplemented by use of a state-accredited laboratory
when evaluation of specific COCs is desired or further verification is needed.
PROJECT 25048 1 MAY 31,2025 1 PAGE 5
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TRUSTED ENVIRONMENTAL ADVISORS
PHOTOGRAPHIC
DOCUMENTATION
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PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
AV
• • r_ 3� t
No. 1 Leak observed at a master valve on No. 2 Leak observed at a master valve on Well
Well K. K in High Sensitivity Mode.
I I -
r.
No. 3 Leak observed at an enardo valve on No.4 Leak observed at an enardo valve on
AST O. AST O in High Sensitivity Mode.
No. 5 Leak observed at a thief hatch on No. 6 Leak observed at a thief hatch on
Temporary AST P. Temporary AST P in High Sensitivity
Mode.
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V
PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
y-rK.
ISL
I - -
Ilw ti `
( t
F�,`Y'
No. 7 View of wells. No. 8 Additional view of wells.
lift
1
No. 9 View of separators. No. 10 View of ASTs.
low
' IR
No. 11 View of compressors. No. 12 Additional view of compressors.
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MODERN GEOSCIENCES
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FIGURES
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Operator-Sage Padsite Location
Well A-API No. 12134453 +
Well B-API No. 12134454 :> q G
Well C-API No. 12134455 .a
Well D-API No. 12134456 N J•
Well E-API No. 12134457
Well F-API No. 12134458 / y�
Well G-API No. 12134473 Denton V�
Well H-API No. 12134469 j \
Well I-API No. 12134470 - �
Well J-API No. 12134471 °o
Well K-API No. 12134472 l
Well L-API No. 12132392 Corinth
1
Basemap Source:ESRI
.................................. m....................................� Legend
A Well
Separator
❑ Former Separator
----------------1 O
I AST
I
A C D E F i Temporary AST
I I I I
jL-----I O Compressor
G I /J\/K\
I
Ancillary Equipment
I
---------------
(011Foam Lines
I I
A ® Upwind Air Sampling Point
I
�-----I I P
—————————————————————————————
m Downwind Air Sampling Point
OO A D BE F H O O OK 11 f•••� Fenceline Screening Alignment
+----------� I O O�................• ® I --------E—--F---O-------------O—L—--OM—--O—N——O—O I
Wind Direction(to)
•..........................................................
Observation Path
W --
O Padsite
ti
r
0 25 50 PROJECT NO. 25048 FIGURE
DRAWN: 05.22.25 PADSITE MAP
Feet
This figure was prepared using data from a variety of sources. DRAWN BY: SP
No warranty is made as to the accuracy or completeness of data CHECKED BY: ZT
provided through third parties. All data contained herein is MODERN G E O S C I E N C E S Long Term Pad(Padsite No.21)
subject to change without notice.This figure is not intended for use as a � FILE NAME: 1896 N811 Road
legal survey or construction design document. If denoted, wind Denton,Texas
direction represents dominant wind direction observed during field activities. TRUSTED ENVIRONMENTAL ADVISORS Denton Padsites.mxd