2021.07.30_MGS_O&G V
MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
DATE July 12, 2021
PROJECT 21125
ReportPadsite Inspection
ATTN City of Denton Padsite No. 064(Tetra Pak 1)
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 other.
■ 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 1 0 0 0
Separators 1 0 0 0
ASTs 2 0 0 0
Other 1 1 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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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.
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 2022.
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.
ReAnneth
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 F 682.223.1593 I P 682.223.1322
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<S
MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
DATE
July 12, 2021
PROJECT
21125
PADSITE INSPECTION
REPORT
Padsite No. 064—Tetra Pak 1
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 MANAGER SENIOR PROGRAM MANAGER
5100 THOMPSON TERRACE,COLLEYVILLE,TEXAS 76034 1 IF 682.223.1593 1 r 682.223.1322
0 2021 MODERN GEOSCIENCES.ALL RIGHTS RESERVED.
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PADSITE INSPECTION REPORT
Padsite Name: Tetra Pak 1 (#064) Operator: EagleRidge
Inspection Date:06114121 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.
® ❑ ❑ 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 21125 1 JULY 12,20211 PAGE 1
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PADSITE INSPECTION REPORT
Padsite Name: Tetra Pak 1 (#064) Operator: EagleRidge
Inspection Date:06114121 Inspectors:ZT, DW MODERN G E O S C I E N C E S
TRUSTED ENVIRONMENTAL ADVISORS
Constituent: •R
At Equipment: 10,000 ppmv 1 50 µR/hr z
Equipment: OGI Camera Radiation Meter
Resolution: 3,000-10,000 ppmv 1 µR/hr
Constituent: Methane tV0Cs H2S NORM
Fenceline: 500 ppmv 3 0.1 ppmv n 0.08 ppmv 5 20 µR/hr 6
Equipment: DPIR Meter PID HzS 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 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.
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 TCEQ Air
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 21125 1 JULY 12,20211 PAGE 2
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PADSITE INSPECTION REPORT
Padsite Name: Tetra Pak 1 (#064) Operator: EagleRidge
Inspection Date:06114121 Inspectors:ZT, DW MODERN G E O S C I E N C E S
TRUSTED ENVIRONMENTAL ADVISORS
NEAR EQUIPMENT INSPECTION RESULTS:
INSPECTIC JILTS - UN
Location ID: Leaks (OGI): NORM (ltR/hr; max): Date Reported': Date Addressed':
Well A None I NA NA
General Notes: Minor corrosion noted on Well A. No other concerns noted.
1—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 (jiR/hr; max): Date Reported': Date Addressed
Separator A None I NA NA
General Notes: Minor corrosion noted on Separator A piping. No other concerns noted.
1—Reported to operator,•Z—If reported to Modern by operator/City,• *NORM exceeding 50 µR/hr not labeled
INSPECTION RESULTS—TANK BATTERY ASTS
Location ID: Leaks (OGI): NORM ([iR/hr; max): Date Reported': Date Addressed
AST A None <15 NA NA
AST B None <15 NA NA
General Notes: Minor corrosion noted on ASTS. No other concerns noted.
1—Reported to operator; —If reported to Modern by operator/City; *NORM exceeding 50 µR/hr not labeled
=L I IUN hCJVL 1 J - KY r-UUIP NI
Location ID: Leaks (OGI): NORM (�tRffir; max): Date Reported': Date Addressed
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 21125 1 JULY 12,20211 PAGE 3
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PADSITE INSPECTION REPORT
Padsite Name: Tetra Pak 1 (#064) Operator: EagleRidge
Inspection Date:06114121 Inspectors:ZT, DW MODERN G E O S C I E N C E S
TRUSTED ENVIRONMENTAL ADVISORS
FENCELINE INSPECTION RESULTS:
- -• • •• Avg. Wind Direction (to): 5 Avg. Wind Speed (mph): 2.5 Bar. Pressure ("Hg): 29.32
• Avg.Temp (°F): 97.4 Humidity (%): 47.7 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 21125 1 JULY 12,20211 PAGE 4
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MODERN GEOSCIENCES
TRUSTED ENVIRONMENTAL ADVISORS
PHOTOGRAPHIC
DOCUMENTATION
PROJECT 21125
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