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2018.02.01_Vendor_Inspection V MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATE January 23, 2018 PROJECT 17153 ReportPadsite Inspection ATTN City of Denton Padsite No. 134(Lake Dallas GSU) 215 East McKinney Street Operator: Atmos Denton,Texas 76201 Location: ® City of Denton ❑ Denton ETJ 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 Inspection Summary: Equipment Number Leaks* Unlabeled NORM** Labeled NORM** Wells 3 0 0 0 Separators 0 0 0 0 ASTs 0 0 0 0 Other 1 0 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 www.MODERNGEOSCIENCES.com MODERN GEOSCIENCES 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. No Action Items were noted by Modern during our inspection efforts. ■ 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 2020. 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. Re4nneth y submitte , 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 E 682.223.1593 I P 682.223.1322 www.MODERNGEOSCIENCES.com <S MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATE January 23, 2018 PROJECT 17153 PADSITE INSPECTION REPORT Padsite No. 134— Lake Dallas GSU PREPARED FOR City of Denton 215 East McKinney Street Denton,Texas 76201 PREPARED BY REVIEWED BY Zachar ondr ,GIT e eth S.kramm, PhD, PG, HMM PROJECT SCIENTIST SENIOR PROGRAM MANAGER 5100 THOMPSON TERRACE,COLLEYVILLE TEXAS 76034 1 IF 682.223.1593 1 r 682.223.1322 ©2018 MODERN GEOSCIENCES.ALL RIGHTS RESERVED. www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Lake Dallas GSU(#134) Operator:Atmos Inspection Date:01/09/18 Inspectors:ZT, KT MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS FIELD INSPECTION RESULTS: Pass Fail N/A General Inspection Checklist Items Item 1: Appropriate signage present at padsite entrance including operator name, ❑ ❑ ❑ site address, well names, 24 hr phone number, and no smoking. Comments: None Item 2: Appropriate signage present at padsite entrance and/or equipment including ❑ ❑ ❑ RRC/API numbers. Comments: None ❑ ❑ ❑ Item 3: Fencing present surrounding padsite and/or equipment. Comments: None ❑ ❑ ❑ Item 4: Site secured. Gates locked to control unauthorized access. Comments: None ❑ ❑ ❑ Item 5: Surface topography prevents areas with significant water collection. Comments: None ❑ ❑ ❑ Item 6: Surface free of stains or other signs of significant spills/releases. Comments: None ® ❑ ❑ Item 7: Padsite free of trash/waste debris. Comments: None ❑ ❑ ® Item 8: Lighting not directed toward adjacent property/roads (as applicable). Comments: None ® ❑ ❑ Item 9:All equipment painted with no bare pipe present. Comments: None ® ❑ ❑ Item 10: Landscaping appears well maintained (as applicable). Comments: None ❑ ❑ ❑ Item 11: Lightning arrestors present at ASTs and in good condition (as applicable). Comments: Not applicable—tank battery not present. ❑ ❑ ® Item 12: Pipeline markers present at roads (as applicable). Comments: None Item 13: Tank battery and secondary containment appear to have integrity with no ❑ ❑ ® significant corrosion. Comments: Not applicable—tank battery not present. ❑ ❑ ® Item 14: Remote compressed air foam line (fire suppression) present. Comments: None ® ❑ ❑ Item 15:Access road accommodates 20'wide emergency vehicle requirements. Comments: None Item 16: Water/oil transfer points within secondary containment or have drip control ❑ ❑ ® accessory to minimize spillage during waste transfer. Comments: Not applicable—tank battery not present. ❑ ❑ ® Item 17:Tank battery has appropriate hazardous material signage. Comments: Not applicable—tank battery not present. ❑ ❑ ® Item 18: Ponded water(Pit) has fencing and access controls. Comments: Not applicable—ponded water not present. Item 19: Other Audio, Visual, or Olfactory concerns noted during the inspection. ® ❑ ❑ Comments: To comply with homeland security concerns expressed by the operator concerning the gas storage wells and associated production facility, photographs are not included in this report. PROJECT 17153 1 JANUARY 23,2018 1 PAGE 1 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Lake Dallas GSU(#134) Operator:Atmos Inspection Date:01/09/18 Inspectors:ZT, KT MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS Constituent: Methane NORM At Equipment 10,000 ppmv 1 50 µR/hr z 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 FR 56593). Also represents 20%of the Lower Explosive Limit. 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. 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 17153 1 JANUARY 23,2018 1 PAGE 2 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Lake Dallas GSU(#134) Operator:Atmos Inspection Date:01/09/18 Inspectors:ZT, KT MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS NEAR EQUIPMENT INSPECTION RESULTS: Location ID: Leaks (OGI): NORM (pR/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: No other concerns noted. 1-Reported to operator,•2—If reported to Modern by operator/City,•*NORM exceeding 50 µR/hr not labeled INSPECTION RESULTS- SEPARATORS N/A INSPECTION RESULTS-TANK BATTERY (ASTS) N/A INSPECTION RESULTS- COMPRESSORS OR ANCILLARY EQUIPMENT N/A PROJECT 17153 1 JANUARY 23,2018 1 PAGE 3 www.MODERNGEOSCIENCES.com MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS FIGURES PROJECT 17153 1 JANUARY 23,2018 1 PAGE 4 www.MODERNGEOSCIENCES.com Aerial Source:Microsoft Corporation©and its data suppliers Atmos Well ID RRC ID Pall Location i. A 166525 B 021488 267654 �- C 267654 tESR1 t4 El Basemap - �1 Legend: Well iDenton County Parcels r- -r Observation Path A� � �Padsite izz'1111111 Lzzz PROJECT NO. 17153 FIGURE 0 100,r 200 300 ® DRAWN: 01.23.18 PADSITE MAP This figure was prepared using data from a variety of sources. DRAWN BY: CS/LM No warranty is made as to the accuracy or competeness of data CHECKED BY KT : provided through third parties. All data contained herein is Lake Dallas GSU(No. 134) subject to change without notice.This figure is not intended for use as a MODERN G E O S C I E N C E S FILE NAME: 5642 E McKinney Street legal survey or construction design document. If denoted, wind Denton,Texas direction represents dominant wind direction observed during field activities. TRUSTED ENVIRONMENTAL ADVISORS® 134_L_Atmos_LDGSU_Padsite_180123.mxd