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2019.08.13_Vendor_Inspection_City of Denton
MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS DATE August 8, 2019 PROJECT 19003 ReportPadsite Inspection ATTN City of Denton Padsite No. 062 (Rayzor West 5) 215 East McKinney Street Operator: EagleRidge 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. EquipmentNear . Equipment Number Leaks* Unlabeled NORM** Labeled NORM** Wells 6 4 0 0 Separators 7 4 0 0 ASTs 6 2 0 0 Other 1 2 1 1 101 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 V MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS ■ 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. ■ 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 2021. 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 August 8, 2019 PROJECT 19003 PADSITE INSPECTION REPORT Padsite No. 062—Rayzor West 5 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 F 682.223.1593 1 r 682.223.1322 ©2019 MODERN GEOSCIENCES.ALL RIGHTS RESERVED. www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Rayzor West 5(#062) Operator: EagleRidge Inspection Date:04129119 Inspectors:ZT, DW 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: Minor corrosion noted as potential future action item (detailed in near- equipment summary). ❑ ❑ ❑ Item 10: Landscaping appears well maintained (as applicable). Comments: None ❑ ❑ ❑ Item 11: Lightning arrestors present at ASTs and in good condition (as applicable). Comments: None ❑ ❑ ® 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: None ® ❑ ❑ 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: None ® ❑ ❑ Item 17:Tank battery has appropriate hazardous material signage. Comments: None ❑ ❑ ❑ 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: None PROJECT 19003 1 AUGUST 8,2019 1 PAGE 1 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Rayzor West S(#062) Operator:EagleRidge Inspection Date:04129119 Inspectors:ZT, DW 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 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). 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 19003 1 AUGUST 8,2019 1 PAGE 2 www.MODERNGEOSCIENCES.com PADSITE INSPECTION REPORT Padsite Name:Rayzor West 5(#062) Operator: EagleRidge Inspection Date:04129119 Inspectors:ZT, DW MODERN G E O S C I E N C E S TRUSTED ENVIRONMENTAL ADVISORS NEAR EQUIPMENT INSPECTION RESULTS: 4SPECTION RESULTS - WELL Location ID: Leaks (OG I): NORM (liRffir; max): Date Reported': Date Addressed: Well A Compression Fitting <15 05/14/19 07/31/19 Well B None <15 NA NA Well C None <15 NA NA Well D Kim ray Valve <15 05/14/19 07/31/19 Well E Compression Fitting and <15 05/14/19 07/31/19 Pressure Regulator Well F None <15 NA NA General Notes: Minor corrosion noted on wells. No other concerns noted. 1—Reported to operator,•2—If reported to Modern by operator/City; *NORM exceeding 50 µR/hr not labeled 1%jam 1\LJVL I J — aJ Lr/Y I\I Location ID: Leaks (OGI): NORM (�tRffir; max): Date Reported': Date Addressed Separator A DV Controller <15 05/14/19 07/31/19 Separator B DV Controller <15 05/14/19 07/31/19 Separator C None <15 NA NA Separator D None <15 NA NA Separator E DV Controller <15 05/14/19 07/31/19 Separator F None <15 NA NA Separator G Compression Fltting <15 05/14/19 07/31/19 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—TANK BATTERY (ASTS) Location ID: Leaks (OG I): NORM (pR/hr; max): Date Reported': Date Addressed AST A None <15 NA NA AST B None <15 NA NA AST C Thief Hatch <15 05/14/19 07/31/19 AST D None <15 NA NA AST E Enardo Valve <15 05/14/19 07/31/19 AST F 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— COMPRESSORS OR ANCILLARY EQUIPMENT Location ID: Leaks (OGI): NORM (lLR/hr; max): Date Reported': Date Addressed': Compressor A Pneumatic Liquid Level 25 05/14/19 07/31/19 Controller Ancillary A 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 PROJECT 19003 1 AUGUST 8,2019 1 PAGE 3 www.MODERNGEOSCIENCES.com MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS PHOTOGRAPHIC DOCUMENTATION PROJECT 19003 www.MODERNGEOSCIENCES.com PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS .t Vw 1, A. No. 1 Leak observed at a compression fitting No. 2 Leak observed at a compression fitting on Well A. on Well A in High Sensitivity Mode. or Aww ilk � �• -• : -� E . No. 3 Leak observed at a kimray valve on No.4 Leak observed at a kimray valve on Well D. Well D in High Sensitivity Mode. .,�u0.Ar - of ', �_4 �.,• l� �tl -lyT- .I 1�t17vAdit- •I No. 5 Leak observed at a pressure regulator No. 6 Leak observed at a pressure regulator on Well E. on Well E in High Sensitivity Mode. PROJECT 19003 www.MODERNGEOSCIENCES.com PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS No. 7 Leak observed at a compression fitting No. 8 Leak observed at a compression fitting on Well E. on Well E in High Sensitivity Mode. RMI I x No. 9 Leak observed at a DV controller on No. 10 Leak observed at a DV controller on Separator A. Separator A in High Sensitivity Mode. No. 11 Leak observed at a DV controller on No. 12 Leak observed at a DV controller on Separator B. Separator B in High Sensitivity Mode. PROJECT 19003 www.MODERNGEOSCIENCES.com PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS No. 13 Leak observed at a DV controller on No. 14 Leak observed at a DV controller on Separator E. Separator E in High Sensitivity Mode. No. 15 Leak observed at a compression fitting No. 16 Leak observed at a compression fitting on Separator G. on Separator G in High Sensitivity Mode. No. 17 Leak observed at a thief hatch on AST No. 18 Leak observed at a thief hatch on AST C C. in High Sensitivity Mode. PROJECT 19003 www.MODERNGEOSCIENCES.com ON V PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS Vim' j - r 1 No. 19 Leak observed at an enardo valve on No. 20 Leak observed at an enardo valve on AST E. AST E in High Sensitivity Mode. r t No. 21 Leak observed at pneumatic liquid No. 22 Leak observed at pneumatic liquid level controller on Compressor A. level controller on Compressor A in High Sensitivity Mode. -=a y r PdN .r No. 23 View of padsite signage. No. 24 View of foam lines. PROJECT 19003 www.MODERNGEOSCIENCES.com PHOTOGRAPHIC DOCUMENTATION MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS yy. No. 25 View of wells. No. 26 Additional view of wells. r No. 27 View of separators. No. 28 View of ASTs. C A _- 1 � r� a d •� "f rr � � _ I No. 29 View of Separator G. No. 30 View of Compressor A. PROJECT 19003 www.MODERNGEOSCIENCES.com MODERN GEOSCIENCES TRUSTED ENVIRONMENTAL ADVISORS FIGURES PROJECT 19003 www.MODERNGEOSCIENCES.com Aerial Source:Microsoft Corporation©and its data suppliers Eagle Ridge Well ID RRC ID Padsite Location A 268647 B 268645 C 268627 N + , E 266232 �J o M d D e n t F 266404El ' Ba-map Source:ESRI vi � D IN E Legend: F �` f• '• t Well ❑ Separator • G 1 .! ` ❑ AST •� Ancillary Equipment �•• r " ' ,r O Compressors Foam Lines Wind Direction(to) r- -r • - - Observation Path ED Padsite N . . . ❑ Denton County Parcels VIP 7 PROJECT NO. 19003 FIGURE 0 50 100-, 150 200 07.03.19 PADSITE MAP Feet DRAWN: This figure was prepared using data from a varie:denoted, ources. DRAWN BY: CS/LM No warranty is made as to the accuracy or complet data L62 CKED BY: KT provided through third parties. All data containein is Rayzor West 5 Padsite(No.62) subject to change without notice.This figure is not intende as a MODERN G E O S C I E N C E SNAME: 3503 Jim Christal Road legal survey or construction design document. If wind Denton,Texas direction represents dominant wind direction observed durintivities. TRUSTED ENVIRONMENTAL ADVISORS® _ER_RW5_Padsite_190703.mxd